Home Health & Hospice Week

More hospice claims data means more billing rules for hospice providers. Now that hospices report site-of-service data on their hospice claims, Medicare is going to start editing claims to make sure different levels of hospice care have the correct site, the Centers for Medicare & Medicaid Services says in Feb. 5 Transmittal No. 121 (CR 6778). Starting in July, you can expect to see claims returned if your level of care doesn't correspond to the correct site of service.

For example: Hospices may furnish general inpatient (GIP) care only in a hospice inpatient unit, a participating hospital, or skilled nursing facility, CMS explains in the transmittal. The system will also check for correct sites for respite care, which must occur in a hospice facility, SNF, regular nursing facility, or participating hospital, and continuous home care (CHC), which must occur at home.

CMS is also correcting its regulations to state that for continuous home care, nursing care from an RN or LPN must make up at least 50 percent of the time billed, CMS adds in Feb. 5 Transmittal 1907 (CR 6778).

The transmittals are at www.cms.hhs.gov/transmittals/downloads/R121BP.pdf and www.cms.hhs.gov/transmittals/downloads/R1907CP.pdf.

closets in physicians' offices are on hold. Suppliers would have to transfer their equipment to physicians if they kept a supply closet at the doctor's office, under the rules CMS issued last August (see Eli's HCW, Vol. XVIII, No. 30, p. 239). Then docs would have to bill for the equipment under their own supplier numbers.

Now CMS has withdrawn the transmittal that contains those rules. "CMS is rescinding this change request to consider other implementation dates," the agency says in an e-mail message to providers.

The rules would be "impractical for physicians and Medicare beneficiaries," the American Association for Homecare notes. And "such an arrangement would have likely violated the physician ownership and referral statute -- known as the Stark law."

"The rule would have created serious disruptions in services for Medicare beneficiaries," the trade group says. "We are very pleased with the decision that CMS has made."

• Don't let U538F claims returns hang up your cash flow. Your claims receive this return to provider (RTP) reason code when the request for anticipated payment (RAP) has the same start date as another RAP you've submitted, regional home health intermediary Cahaba GBA explains on its Web site. Or you'll see it when a line-item date of service on your final claim overlaps another episode established by another agency, or a new episode you established.

Try this: If your final claim for an episode gets rejected, don't submit a second RAP for the episode, Cahaba instructs. Instead, adjust or resubmit the final claim.

If another legitimate episode exists, remove your overlapping line item dates of service from the claim, Cahaba advises. RHHI Palmetto GBA still has claims that were edited incorrectly with this reason code on hold, the intermediary notes on its Web site. Related adjustments are suspended in SMRADJ or SMU538.

• Do you seem to get stuck holding the

bag when a Medicare Advantage patient elects hospice care? Now the Medicare fee for service program will pick up some of the slack.

Problem: "Problems arise regarding payment responsibility when services are provided on the date of election," CMS acknowledges in Feb. 5 Transmittal No. 121 (CR 6778). "As a result, services provided on the date of election are often rejected by both the MA plan and traditional Medicare, leaving the provider uncertain as to which entity should be responsible for the claim payment."

Solution: Now CMS makes clear who should pay. Starting July 6, the Medicare claims system won't reject claims for FFS Medicare on the date benes elect hospice. Currently, FFS claims are rejected as an MA plan responsibility.

That means Medicare will pay for ambulance transport under FFS, CMS explains. An ambulance ride is not the MA plan's responsibility once the patient elects hospice, but it's not the hospice's responsibility until it has admitted the patient and completed an initial assessment and plan of care, CMS clarifies.

Tip: Hospices will have to resubmit affected claims after July 6. "Contractors will not be required to provide automated adjustments," the transmittal notes.

The transmittal is at www.cms.hhs.gov/transmittals/downloads/R121BP.pdf.

• Medicare spending on home care will go

from $30 billion in 2009 to $55 billion in 2019, CMS says in its latest health spending projections. That's up from $15.6 billion in 2004. Total spending on home care services from both public and private sources will reach $72 billion in 2009 and $154 billion by 2019, CMS's

Office of the Actuary forecasts. CMS's health spending projections are at www.cms.hhs.gov/NationalHealthExpendData/downloads/proj2009.pdf -- scroll down to Table 10 for home care data.

• The stalled health care reform bill means therapy caps are still in effect. The cap exceptions process expired Dec. 31 (see Eli's HCW, Vol. XIX, No. 2, p. 16).

Beneficiaries now face annual limits of $1,860 for physical and speech therapy (combined) and $1,860 for occupational therapy. The caps apply only to outpatient Part B therapy, not therapy furnished under a home health plan of care.

• Suppliers won't be seeing much compensation for the service and maintenance of oxygen rental equipment after the 36-month cap passes. Medicare will pay suppliers $66 every six months. "The payment covers all maintenance and servicing through the following 6 months that is needed in order to keep the oxygen equipment in good working order," CMS explains in Feb. 5 Transmittal No. 635 (CR 6792).

Detail: Suppliers will receive one payment per beneficiary, regardless of how many pieces of oxygen rental equipment the bene has. During the first month of each six-month period, the supplier must make at least one visit to inspect the equipment and provide any maintenance and servicing needed at that time.

More information, including the HCPCS codes suppliers can use to bill the visits, is at www.cms.hhs.gov/transmittals/downloads/R635OTN.pdf.

• If you're having trouble with enrollment revalidation, your referring physicians not being in PECOS, or other enrollment issues, you may want to dial in to a special Open Door Forum for Medicare enrollment topics on Feb. 17.

The call from 2 p.m. to 3:30 p.m. will include time for public questions and comment, CMS says. Dial 1-800-837-1935 with conference ID 52537484 to participate.

• Home care acquisitions in the new year continue at a brisk pace.

Baton Rouge, La.-based Amedisys Inc. acquired De Queen Home Health Agency in De Queen, Ark. The deal will expand Amedisys' service area in the Permit of Approval state to eight new counties, for a total of 32, the national chain says in a release. De Queen has annual revenues of $2.9 million, Amedisys says.

LHC Group Inc. will acquire the assets of Hutcheson Home Health in Fort Oglethorpe, Ga. Hutcheson serves six counties in the certificate of need (CON) state and has $3.5 million in annual revenues, the Lafayette, La.-based regional chain says in a release.

LHC also is entering into a joint venture with Hardin Medical Center in Savannah, Tenn. Hardin's home health agency serves six counties in the CON state and has $1.1 million in annual revenues, LHC says.

Gentiva Health Services Inc. has sold its respiratory therapy, home medical equipment, and infusion therapy business to a subsidiary of Lincare Holdings Inc. in an all-cash transaction. The deal involves 40 locations in seven states with $55 million in annual revenues.

"The transaction continues our efforts to focus Gentiva on our core expertise in providing inhome geriatric care services," Gentiva CEO Tony Strange says in a release. And durable medical equipment supplier All-Med Services of Florida Inc. bought Visiting Nurse Managed Care Corporation and Southeast Homecare Corporation, All-Med says in a release.

The Miami Lakes, Fla.-based supplier formerly contracted with the agencies to fulfill the home health agency portion of its managed care contracts. "This union ... creates the largest home care provider in the state of Florida and the Caribbean,"

All-Med's Jorge Pereda claims in the release. All-Med contracts with managed care organizations under capitation.