Home Health & Hospice Week

The first of two crucial NPI deadlines hit March 1.

If you've been slow to implement National Provider Identifiers, you no longer have a choice.

As of March 1, the Centers for Medicare & Medicaid Services requires providers to submit an NPI in the primary provider field. Home health agencies, hospices, suppliers and other providers can submit an NPI-Medicare legacy number pair or can submit the NPI alone.

"Failure to include an NPI will cause the claim to reject," CMS warns in a message to providers.

Pitfall: Claims will also reject if the system can't find the NPI and legacy number pair on the NPI Medicare Crosswalk, CMS explains. In that case, you'll have to verify that your National Plan and Provider Enumeration System (NPPES) information is correct.

While one NPI deadline is down, there's still one to go. On May 23, CMS will require providers to cease submitting legacy numbers and instead submit only the NPI in the primary claim fields.

To get ready, providers should start submitting a small number of NPI-only claims now, CMS advises in the message. "If the claim is processed and you are paid, continue to increase the volume of claims sent with only your NPI," the agency says. "If the claims reject, go into your NPPES record and validate that the information you are sending on the claim is the same information in NPPES."

More NPI information is at www.cms.hhs.gov/NationalProvIdentStand.

• Last year's Home Health Quality Improvement (HHQI) National Campaign has wrapped up, and so has the continuing education for home health agencies that was part of the campaign, CMS points out.

The HHQI Organization Support Center has published its final package of best practice intervention tools, CMS notes. "All continuing education will end on February 28," CMS says.

Providers can still access the best practice tools and free continuing education units at www.homehealthquality.org and www.medqic.org, CMS adds.

The QIOs won't have a home health focus in their next contract, although some may choose to work with home care providers (see Eli's HCW, Vol. XVII, No. 9).

• Assuring quality of care for government program beneficiaries is a high priority for the HHS Office of Inspector General, the OIG notes in a recent report outlining its management challenges. HHAs, hospices and suppliers will see resulting scrutiny.

The OIG is investigating the "cyclical noncompliance of home health agencies with conditions of participation," the watchdog agency says. It also aims "to determine the nature and extent of hospice services provided to beneficiaries residing in nursing homes."

But the OIG saves the full force of its wrath for the DME industry, which it portrays as a hotbed of fraud. The OIG has "consistently found that the Medicare durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) benefit is vulnerable to fraud and abuse," the agency maintains.

From 2002 to 2006, civil and criminal proceedings related to DME fraud netted nearly $800 million in restitution, fines and penalties, the OIG says. The OIG excluded from Medicare and Medicaid 121 DME suppliers and 457 individuals associated with DME.

The report is available online at www.oig.hhs.gov/publications/challenges.

• You could have a place to turn for patient safety help if a proposed rule from the Department of Health and Human Services becomes final. HHS wants to establish patient safety organizations (PSOs) where health care providers, including home health agencies and hospices, could voluntarily report information for the "analysis of patient safety events," HHS says in a Feb. 12 Federal Register notice. All information reported would be confidential.

PSOs were mandated in the Patient Safety and Quality Improvement Act of 2005, the notice points out. HHS will take comments on the rule until April 14.

The proposal allows "the health care industry voluntarily to avail itself of this framework in the best manner it determines feasible," the rule notes. "At the same time, it seeks to ensure that those who do avail themselves of this framework will be afforded the legal protections that Congress intended."

• If you're confused about the new treatment authorization code required on claims under the revised prospective payment system, you're not alone. Regional home health intermediary Cahaba GBA is trying to help by offering a new tool to providers.

"Use this tool to assist in determining the structure of the treatment authorization code (Claim-OASIS Matching Key output) for home health RAPs and final claims for episodes beginning on or after January 1, 2008," Cahaba advises. The two-page worksheet highlights which digits should be letters versus numbers.

For a free copy of the tool, email editor Rebecca Johnson at rebeccaj@eliresearch.com with "Cahaba Treatment Code Tool" in the subject line.

• You could face stiffer penalties for Medicare violations if the U.S. Senate gets its way. Medicare fraud-related provisions in the Indian Health bill the Senate passed Feb. 26 would double civil fines and quadruple criminal fines related to Medicare fraud, according to press reports.

But it's not a sure thing. "The House version of the bill contains no similar amendments addressing Medicare fraud," the National Association for Home Care & Hospice notes.

• The opening shot in the official Medicare legislative debate has been fired. As required by law, legislators in both Houses of Congress introduced President Bush's Medicare savings bill Feb. 25. A 2003 law requires the bill's introduction after a Medicare trustees' funding warning "triggers" a Medicare bill.

Democratic leadership in both Houses may gut the bill and fill it with their own health care agenda items, or they may pursue separate Medicare bills, observers predict.

• Health care spending increases will continue to outstrip inflation in coming years. CMS' Office of the Actuary predicts that Medicare spending will grow 6.5 percent in 2007, which is greater than the overall growth of the economy (4.9 percent) and general inflation (2.4 percent), CMS says in a release.

Total spending on home health will go from $57.6 billion in 2007 to $119 billion in 2017, CMS estimates in its health expenditure report. Medicare home health spending during that period will increase from $21.5 billion to $42.7 billion.

Total spending on durable medical equipment will go from $24.5 billion to $36.6 billion, CMS predicts. Medicare's share of that will go from $7.3 billion to $14.8 billion, the agency says in the report.

More information is online at www.cms.hhs.gov/NationalHealthExpendData/03_NationalHealthAccountsProjected.asp.

• National Government Services' claims system for home health agencies serviced by Associated Hospital Service will go dark from March 7 to 10, NGS clarifies in a Feb. 20 message to providers. The intermediary originally told providers to expect the payment blackout from March 6 to 9 (see Eli's HCW, Vol. XVII, No. 8).

• The formula for preventable hospitalizations divides the number of hospitalizations by the number of hospitalizations minus the number of discharges to the home, explains Vince Caracci with Sta-Home Health Agency in Jackson, MS. The formula was stated in error in Eli's HCW, Vol. XVII, No. 5, p. 37.