Home Health & Hospice Week

Warning: If you fail to use your NPI by March 1, your Medicare claims won't pay.

Providers have been gearing up for the May 23 deadline for submitting Medicare claims with only National Provider Identifiers in the primary fields. But an earlier March 1 requirement to use NPIs on Medicare claims, with or without an accompanying legacy number, may take providers by surprise and reduce their cash flow to a trickle.

Once March 1 arrives, "you will not be able to get paid for any Medicare services you provide until you begin using your NPI," the Centers for Medicare & Medicaid Services stresses in a recent email message to providers.

And the NPI has to match up with your old Medicare number. If it doesn't, none of your claims will pay. "If needed, you must correct any data which may be preventing an NPI/legacy match on the NPI crosswalk," CMS says.

Time drain: "The correction might require that you file a CMS-855 Medicare Provider Enrollment form with your Medicare carrier, A/B MAC, or DME MAC--a process which can take a number of months to accomplish," CMS warns in the message.

CMS is trying to "raise the level of urgency" about the March 1 deadline, it says. However, the agency already is receiving "well over 90 percent" of claims with an NPI in the primary fields, it acknowledges in the message.

If you're already using your NPI in the primary fields, it's time to set your sights on the next hurdle--NPI-only claims. "There is a very small percent of claims submitted with NPI-only," CMS reports. "The time for correcting problems, should there be any, is getting short."

Do this: Test small batches of NPI-only claims to get a preview of how your claims will fare once the May 23 NPI-only deadline takes effect.

Know where to turn: If you do run into problems with your NPI, you need to know how to solve them. The National Plan and Provider Enumeration System and NPI Enumerator may be able to help with some issues in providers' NPPES records. But the Enumerator doesn't have access to Medicare claims and systems, can't change items directly in Medicare's NPI crosswalk and doesn't have access to Medicare's enrollment system, CMS explains in a fact sheet.

Besides the obvious payment problems, NPI non-compliance could also bring administrative penalties, CMS threatens. Enforcement "penalties will be a legitimate resolution if the entity does not demonstrate compliance or corrective action," the agency says in another NPI email message.

Resource: More information about NPIs is at www.cms.hhs.gov/NationalProvIdentStand.

• CMS may shut down its pilot project on disease management. The agency launched the Medicare Health Support program in 2005 to help coordinate care for patients with chronic conditions such as diabetes and heart failure (see Eli's HCW, Vol. XIV, No. 30).

CMS originally announced Visiting Nurse Service of New York as a participant, but later rescinded the contract.

"Phase I of the program is not meeting the statutory requirements of improved clinical quality outcomes, improved beneficiary satisfaction, and the achievement of financial savings targets," CMS says in a statement on its MHS Web site. "Based on the results of the independent evaluation of all of the Phase I programs, CMS will consider whether to expand to Phase II."

But Medicare shouldn't give up on disease management, the National Association for Home Care & Hospice urges. "Disease management can prevent the necessity of hospitalization, which is the major expense in health care," NAHC President Val Halamandaris says. "It should be done by existing home care agencies without the need to create a whole new infrastructure." Such a program could "achieve results of better health care and cost savings to Medicare with very little if any additional costs."

CMS' statement is at www.cms.hhs.gov/CCIP/downloads/EOP_Fact_Sheet_FINAL_012808.pdf.

• The number of home health agencies in Texas has increased 32 percent since 2002, reports the Amarillo Daily News. The increase in providers coupled with the decrease in surveyors--Texas now has 19 for all provider types--is limiting access to care, providers charge.

The backlog hurts rural and underserved areas, Ken Cargle, the president of the Texas Association for Home Care, told the newspaper.

Texas is one of a number of states that now directs home health agencies to private accrediting organizations for initial certifications (see Eli's HCW, Vol. XVI, No. 40).

• Be wary of lawsuits from employees you let go. Oklahoma's Supreme Court has given a former HHA employee the go-ahead to proceed with a wrongful termination suit against Integris Health Inc.

In 2005, plaintiff Chris Darrow was an ad-ministrative assistant for Samaritan Home Care, which Integris acquired in 2007, according to a Supreme Court decision issued Jan. 15 in Darrow v. Integris. Darrow learned of a patient's death in a home fire from another Samaritan employee and noted discrepancies between the press reports and the medical record on items including the patient's age and the presence of fire detectors in the home. Five days after Darrow brought the issues to the attention of the agency's quality assurance supervisor, Samaritan terminated his employment for an alleged HIPAA violation in the course of his chart review, according to the opinion.

Darrow filed a lawsuit claiming the termination was in retaliation for his inquiries. A state trial court dismissed the suit and a state appeals court upheld the dismissal, but the Supreme Court reinstated it based on state law.

The decision is at www.oscn.net/applications/oscn/DeliverDocument.asp?CiteID=451190.

• Rhode Island is looking to home care to help solve its Medicaid budget problems. Gov. Don Carcieri (R) is proposing a number of cuts in the face of a state budget deficit, but he wants to put more emphasis on home care, according to an Associated Press article.

Under Carcieri's proposal, state agencies would screen almost 11,800 patients referred to nursing homes every year to determine if some could remain at home with support, such as home care nursing visits, medication assistance or delivered meals, AP says. Carcieri's administration is hoping that 10 percent of those patients could instead receive care at home or other non-institutional settings.

• CMS is still trying to educate hospice providers about the recent slew of changes to hospice Medicare claims. The agency recently updated MLN Matters articles on the topic. "Billing Instructions Regarding Payment for Hospice Care Based on Location Where Care is Furnished" (MM5745) is available at www.cms.hhs.gov/MLNMattersArticles/downloads/MM5745.pdf. "Instructions for Reporting Hospice Services in Greater Line Item Detail" (MM-5245) is available at www.cms.hhs.gov/MLNMattersArticles/downloads/MM5245.pdf.

• Gentiva Health Services Inc. will acquire Home Health Care Affiliates Inc. and certain of its subsidiaries and affiliates for $55 million in cash, the Melville, NY-based national chain says in a release.

HHCA operates home health and hospice agencies in Mississippi under the brand names of Gilbert's Home Health and Gilbert's Hospice Care, the company says. The purchase would expand Gentiva's service area to 37 states.

Gilbert's has 500 employees, 14 locations covering 50 counties, 81 percent Medicare revenues and $37 million in revenues for 2007. About $33 million of that is for the HHA business, according to the release. Mississippi is a certificate of need state.

• For-profit hospice chain Odyssey HealthCare Inc. is proceeding with its plans to purchase VistaCare Inc., according to a release.

Dallas-based Odyssey has made its cash tender offer, which is the first of its two-step acquisition of Scottsdale, AZ-based VistaCare, the company says. Odyssey announced last month that it planned to buy VistaCare for about $147 million (see Eli's HCW, Vol. XVII, No. 3).