Home Health & Hospice Week

But you have until May 2008 to include referring docs' new numbers.

Providers wondering how to comply with the latest NPI rules finally have some concrete information.

The Centers for Medicare & Medicaid Services announced earlier this month that because providers and other covered entities aren't ready to use National Provider Identifier numbers on their Medicare claims, it was extending the NPI deadline for a year (see Eli's HCW, Vol. XVI, No. 12).

Limit: But now CMS says the primary provider requesting payment with the claim may have to have its NPI as early as July. "As soon as the number of claims submitted with an NPI for primary providers ... is determined sufficient ... Medicare will begin rejecting claims that do not contain an NPI for primary providers," CMS says in MLN Matters article MM5595 finalized April 24.

Primary providers for NPI purposes are "billing, pay-to and rendering providers," CMS explains.

What's next: In May, CMS will assess how many providers are submitting claims with their NPIs. If the ratio is high enough, it will start requiring NPIs from the primary providers in July, the article says. If the ratio isn't yet high enough, it will reassess in June for an August implementation.

Off the hook: However, home care providers don't have to furnish referring physicians' NPIs on claims until May 2008. Providers can include "secondary" providers' legacy numbers, including UPINs, on Medicare claims until that date. "If a secondary provider's NPI is present, it will only be edited to assure it is a valid NPI," CMS assures.

Until the to-be-announced NPI deadline, providers can include NPIs, legacy numbers or a combination of NPIs and old numbers on their claims, CMS says in April 24 Change Request 5595.

Providers not in full compliance with the NPI requirement must have a contingency plan by May 23 when the NPI deadline hits, CMS says (see Eli's HCW, Vol. XVI, No. 14).

The MLN Matters article is at www.cms.hhs.gov/MLNMattersArticles/downloads/MM555.pdf. The CR is at www.cms.hhs.gov/Transmittals/downloads/R1227CP.pdf.

• CMS has released the list of HCPCS codes included in the first round of competitive bidding for durable medical equipment. Bidding is expected to begin very soon.

The information is posted on the Competitive Bidding Implementation Contractor Web site. For a list of all codes included in each category, go to www.dmecompetitivebid.com.

• You shouldn't follow the National Pressure Ulcer Advisory Panel's new pressure ulcer guidelines just yet. "We are aware of the new guidance," CMS' Pat Sevast said at the National Association for Home Care & Hospice's Washington, DC policy conference April 23. Even though OASIS instructions refer to NPUAP guidelines, the agency is looking at the guidance to see how adopting it would affect reimbursement before deciding what to do, Sevast cautioned. The guidance revises pressure ulcer stages, definitions and descriptions (see Eli's HCW, Vol. XVI, No. 9).

• Medicare's Hospital Insurance Trust Fund will be exhausted in 2019, one year later than estimated last year, according to the Medicare Trustees Report issued April 23. But despite the improvement, the trustees still issued a "Medicare funding warning" that requires President Bush to propose program cuts in February 2008 for the 2009 budget year.

"This report shows once again that we are on an unsustainable course for Medicare spending," Health and Human Services Secretary Mike Leavitt says in a release. "If Congress were to embrace the President's budget, we could not only eliminate this funding warning, we could also extend the life of the Hospital Insurance Trust Fund four years."

The President's 2008 budget includes freezes for home health agencies, hospices and DME suppliers (see Eli's HCW, Vol. XVI, No. 6).

But Democrats are quick to dismiss the funding warning. "I am concerned ... that the 'Medicare funding warning' in this report will prompt the president only to propose slashing Medicare spending, rather than to focus on the underlying factors driving costs throughout the health system," Senate Finance Committee Chair Max Baucus (D-MT) told Congressional Quarterly.

House Ways and Means Health Care Subcommittee Chair Pete Stark (D-CA) was more blunt. The financial line used to trigger the funding warning is "an arbitrary threshold designed to scare people," Stark said.

"Correcting this so-called 'problem' risks doing serious harm to Medicare beneficiaries. It will ... lead to attempts to reduce benefits, increase premiums or cap the amount Medicare will pay for premiums," Families USA's Ron Pollack told the Chicago Tribune.

• You should continue using the Medicare Notice of Non-Coverage for Medicare managed care patients, even though the form has expired, according to NAHC. Until the Office of Management and Budget and CMS approve the new form, "providers have been advised to disregard the expiration date and continue to use the current form," NAHC explains to members.

This notice is the first-step, generic notice providers give Medicare Advantage enrollees when coverage is about to end (see Eli's HCW, Vol. XII, No. 20). The form that includes the patient's name and date services will end is required two days before discharge or on the next-to-last visit.

• You may see hospice surveys tighten up after a recent OIG report on the matter. The HHS Office of Inspector General found that in 2005, 14 percent of all Medicare-certified hospices didn't get surveyed within six years as required, according to a recent report (OEI-06-05-00260).

In fact, those 14 percent averaged three years past due, so they weren't surveyed for nine years, the OIG found. Surveyors cited health deficiencies for 46 percent of hospices surveyed and for 26 percent of hospices investigated for complaints. The most frequently cited health deficiencies centered on patient care planning and quality, the OIG says in the report at www.oig.hhs.gov/oei/reports/oei-06-05-00260.pdf.

Three states account for 41 percent of all hospices with past due certifications: California (17 percent), Illinois (12 percent) and Michigan (12 percent), the OIG says. In 2006, CMS started requiring hospice surveys only every eight years.

• The Joint Commission will post on its Web site proposed changes to its standards related to the Surveillance, Prevention and Control of Infection (IC), the Oakbrook Terrace, IL-based accrediting body says.

The changes are taking place under the Standards Improvement Initiative, which "is part of a continuous effort to eliminate non-essential standards and to ensure that the remaining standards are understandable and relevant to the care setting to which they apply," explains the organization formerly known as JCAHO.