Home Health & Hospice Week

Which of these trouble spots puts your agency’s claims most at risk?

Knowing every single one of your claims will be undergoing review is a strong incentive to make sure you’re dotting all your i’s and crossing all your t’s.

Whether you’ll be starting Review Choice Demonstration review this month, or will undergo various other types of medical review that the Centers for Medicare & Medicaid Services has recently resumed, following this expert advice will help get your claims paid quickly and efficiently:

1. Watch for notices. “With the resumption of RCD, agencies should anticipate receiving notices of overpayments from CMS,” advises attorney Lesley Arca with Roetzel & Andress in Chicago. These notices will “have strict deadlines for appeal and may involve CMS working to recoup paid claims,” Arca cautions.

In addition to ongoing RCD review, “following the resumption of the demonstration, [RCD contractor Palmetto GBA] will conduct postpayment review on claims subject to the demonstration that were submitted and paid during the pause,” CMS said when it announced RCD’s resumption. But it doesn’t look like that postpayment review is taking place quite yet. “CMS will post more information on the postpayment review process in the near future,” the agency said last month.

2. Understand which claims are included. Don’t fall into the trap of mixing up billing periods and episodes of care when determining which claims you need to submit for RCD, warns consultant Lisa Selman-Holman with Selman-Holman in Denton, Texas. The effective date applies to “billing periods, not episodes,” Selman-Holman stresses on the firm’s blog. “That means if you have a 60-day episode that began August 1, the second billing period in that episode begins August 31 and that second billing period in the episode is subject to the review,” she explains.

3. Check for potential clinical trouble spots. RCD review will hit on all the usual vulnerabilities ranging from homebound to skilled necessity to plan of care support.

Use this tool: Palmetto has already issued “a cheat sheet — a list of exactly what Medicare Administrative Contractor Palmetto GBA reviewers will look for” under RCD, highlights J’non Griffin with Home Health Solutions in Carbon Hill, Alabama, which has merged with Simione Healthcare Consultants in Hamden, Connecticut. “Palmetto has released a tool it calls the ‘Pre-Claim Review Initial Checklist’ to help home health providers make certain they have in place all required documentation,” Griffin says on the firm's blog.

Access the checklist, which covers everything from face-to-face documentation to fall risk assessments, at www.palmettogba.com/Palmetto/Providers.Nsf/files/RCD_Pre-Claim_Review_Start_of_Care_Early_Period_Checklist.pdf/$File/RCD_Pre-Claim_Review_Start_of_Care_Early_Period_Checklist.pdf.

HHAs often run into trouble with documenting therapy goals; correct F2F forms and documentation; and missing documentation for resumptions of care in orders, reports consulting firm McBee in its blog.

4. Check operational trouble spots. Claims end up just as denied when you have operational breakdowns as clinical ones. You should make sure you are staffed up to the required level to ensure smooth RCD submission, McBee urges. Ask yourself “if your billing team is adequately staffed to account for this increased work,” the firm advises.

Also make sure things like unsigned orders and pending discharges aren’t slowing down your billing and clash flow, McBee adds. And confirming your electronic medical records system is up to the RCD task is also paramount.

5. Focus on training. Both existing and new staff will need to be on top of RCD to avoid punishing denials, returns, penalties, and cash flow problems. Staff from the intake, clinical, administrative, and billing departments all need to work together to make sure RCD submission and responses run smoothly, McBee says.