Home Health & Hospice Week

Don't be surprised if you start getting medical review requests from somebody new.

AdvanceMed Corp. started operating as the Zone Program Integrity Contractor (ZPIC) Dec. 16, reports regional home health intermediaries Cahaba GBA and Palmetto GBA on their Web sites.

CMS is transitioning fraud-fighting contractor functions over to ZPICs. AdvanceMed has been a Program Safeguard Contractor (PSC) since 2002. "As the ZPIC for Zone 5, AdvanceMed will perform benefit integrity activities aimed to reduce fraud, waste, and abuse," the intermediaries say.

Rockville, Md.-based AdvanceMed's Zone 5 contract includes West Virginia, Virginia, North Carolina, South Carolina, Georgia, Alabama, Mississippi, Tennessee, Arkansas, and Louisiana.

The ZPIC has offices in Nashville, Tenn., Richmond, Va., and Baltimore, Md.

ZPICs in Zones 4 and 7 began operating earlier this year (see Eli's HCW, Vol. XVIII, No. 13, p. 99). In June, CMS issued its request for proposal for ZPICs in Zones 3 (Minnesota, Wisconsin, Illinois, Michigan, Ohio, and Kentucky) and 6 (Pennsylvania, New York, Maryland, DC, Delaware, Maine, Massachusetts, New Jersey, Connecticut, Rhode Island, New Hampshire, and Vermont).

An announcement of the winner of those contracts is expected soon.

Do this: You should still report suspected fraud and abuse to your main Medicare contractor, the notice says. "Once screened by the [contractor] to rule out billing errors or misunderstandings, referrals will be forwarded to the ZPIC."

• The competitive bidding deadline is almost upon suppliers. All bids must be in the DBidS online bidding system by 9 p.m. on Dec. 21, the Centers for Medicare & Medicaid Services reminds suppliers in an e-mail message. Hard-copy documents to support the bid package must be postmarked by Dec. 21 as well, CMS says.

You also have until Dec. 21 to amend hardcopy documents you already submitted, CMS adds. Don't forget to include your bidder number on each page of the hard-copy documents.

Watch for: Suppliers who submitted financial documents by Nov. 21 will receive an e-mail from the competitive bidding implementation contractor (CBIC) by Dec. 29 confirming their submission. If you are missing documents, the CBIC will mail a letter by Jan. 4 informing you of what's missing and you'll have 10 business days to submit them.

CMS is also warning suppliers again about violating antitrust laws in their bidding efforts -- particularly when utilizing consulting services.

Using a consultant is OK, but a supplier must validate and submit its own bid, CMS instructs in a new question-and-answer set on the topic. And the consultants must stay on the right side of antitrust regulations. "The supplier may not knowingly use a consultant that compares that supplier's bid with, or knowingly makes bid item prices identical or substantially the same as, the bid of another bidder(s)," CMS warns in the Q&A.

"Consultants must not violate any Federal antitrust law or engage in anticompetitive behavior ... in preparing bids."

That anticompetitive behavior includes "comparing different suppliers' bids or knowingly advising different suppliers to submit identical or substantially identical bid prices," CMS explains.

"CMS will reject a bid that is not bona fide or does not otherwise comply with the law, regulations, or RFB," the agency stresses. CMS asks suppliers to report consultants suspected of antitrust behavior to the CBIC.

• It's OK for a home health agency to serve a hospice patient (and bill Medicare) for reasons not related to the terminal illness, but you'd better get your coding right.

So says RHHI Cahaba GBA in its December newsletter for providers. HHAs "are inappropriately including diagnosis codes that are related to a hospice beneficiary's terminal illness as the primary diagnosis on their claims when the HHA is providing services to the beneficiary that are unrelated to the terminal illness," Cahaba says.

Using the terminal illness diagnosis may be OK for the secondary diagnosis (in M0240), but the primary diagnosis needs to be the chief reason for home care, Cahaba explains. If you are serving the patient for reasons related to the terminal illness, payment must come from the hospice.

Tip: "To determine whether the beneficiary has elected the hospice benefit and whether this election impacts your dates of service, Cahaba encourages HHAs to review ELGH page 9 or ELGA page 2 at the time of admission and prior to submitting any billing transactions to Medicare," the newsletter urges.

• Home care providers are keeping their eyes on Congress to see if a health care reform bill will pass, and if so, how much it will affect their Medicare payments. Senators continued to debate pending reform legislation at press time, with the reform bill's status still up in the air.

Senators already passed an amendment that prohibits the health reform bill from reducing or eroding the home care benefit, notes the National Association for Home Care & Hospice. Senators plan to introduce at least one more amendment reducing HHA cuts, NAHC reports.

• Hospices looking for guidance on how physicians should write their attestations of hospice patients' terminal illnesses aren't getting much help from a recent CMS Q&A on the matter. "We have not mandated that specific language be included in the physician's attestation,"

CMS says of the new requirement that took effect on Oct. 1. "Any language under the physician's signature which attests that by signing, the physician confirms that he/she composed the narrative based on his/her review of the patient's medical record or, if applicable, his or her examination of the patient meets the attestation regulatory requirement," CMS says in Q&A 9917.

Tool: For a sample attestation form from Cahaba, go to www.cahabagba.com/rhhi/education/materials/quick_hospice_certification.pdf (see Eli's HCW, Vol. XVIII, No. 32, p. 252).

• The Visiting Nurse Association of Greater Philadelphia is expanding its service area. The VNA will begin serving patients in Bucks County, Pa., it says in a release.

"VNA also is introducing a new personalized telehealth service in Bucks County for its patients with congestive heart failure and chronic obstructive pulmonary disease," the release says.

The telehealth program is provided in conjunction with home nursing visits.

• Get ready to give your two cents on your Medicare contractor. CMS is conducting its fifth annual Medicare Contractor Provider Satisfaction Survey (MCPSS).

"This survey offers Medicare FFS providers and suppliers an opportunity to give CMS feedback on their interactions with Medicare FFS contractors," the agency says in an announcement to providers.

The catch: To give feedback, you have to be one of the 30,000 providers CMS randomly selects for the survey. Watch for a notice in January. More information about the survey is online at www.cms.hhs.gov/MCPSS.