Home Health & Hospice Week

Documentation requirements are inconsistent, senators blast.

Two U.S. senators want mobility documentation requirements clarified.

In an Aug. 5 letter, Sens. Rick Santorum and Arlen Specter, both Pennsylvania Republicans, asked the Centers for Medicare & Medicaid Services to provide clear documentation instructions for mobility equipment. Providers "regularly encounter inconsistencies within the four DMERC regions on how documentation is interpreted," the letter stated.

Durable medical equipment regional carriers emphasize physician chart notes, which often lack the specificity DMERCs require, the letter noted.

Therefore, "evaluations from other healthcare clinicians or letters of medical necessity from the patient's ordering practitioner should be considered part of the medical record and used by claims processors in the event of an audit," the senators wrote.  Home health agencies that furnish Part B therapy services will find themselves subject to National Correct Coding Initiative (NCCI) edits come Jan. 1. Hospitals and outpatient therapists have been under NCCI edits for outpatient therapy since 2000, and CMS is expanding the edits to HHAs, skilled nursing facilities, comprehensive outpatient rehabilitation facilities and rehab agencies.

The NCCI edits, which prevent billing of certain CPT codes simultaneously, will apply only to therapy services NOT under a plan of care, CMS makes clear in a Medlearn Matters article revised Aug. 8. You can look up the edits at www.cms.hhs.gov/providers/hopps/cciedits.

Senate Finance Committee Chair Charles Grassley (R-IA) has introduced a bill that would remove the requirement for states to seek a waiver for including home care as a Medicaid benefit. Instead, S. 1602 would make home care an optional benefit with looser eligibility requirements. Sens. Evan Bayh (D-IN) and Hillary Rodham Clinton (D-NY) cosponsored the legislation filed July 29.

The home care proposal is just one segment of a larger bill addressing long-term care financing issues.
  New billing resources are but a click away for suppliers in Region B. DMERC AdminaStar Federal's Medical Review Unit has created a new page on its Web site with a documentation checklist, answers to frequently asked questions, quick reference guides and billing information on various medical policies.

The page is at www.adminastar.com/Providers/DMERC/MedicalReview/MedicalReview.cfm.
  Home care providers should prepare for static on their Medicare Part B claims that meet or exceed $50,000. CMS has directed fiscal intermediaries to take a closer look at all Part B claims they receive on or after Jan. 3, 2006 that cross the $50,000 threshold, according to a July 29 transmittal.

This means that you won't see quick reimbursement on these claims, as your FI tries to identify - and prevent - any potentially excessive payments. The edit comes after the HHS Office of Inspector General uncovered millions in provider overpayments due to clerical billing errors. More information is at www.cms.hhs.gov/manuals/pm_trans/R620CP.pdf.
  Apria Healthcare Group Inc. will pay $17.6 million [...]