Home Health & Hospice Week

Nonroutine Supplies:

NRS Edits Hit HHAs' Claims

Overcome confusing remittance advice codes with NRS know-how.

Don’t ignore the new nonroutine supplies edits or you could pay a steep price very soon.

The Centers for Medicare & Medicaid Services drastically changed how home health agencies receive payment for NRS when prospective payment system revisions took effect Jan. 1.

Then: CMS included the same flat $52.53 rate for supplies in all episodes.

Now: Agencies receive payment at six severity levels ranging from $14 to $551 based on 11 OASIS items including diagnosis coding. “Points translate into … NRS revenue, which is a whole different concept than we’re used to,” consultant Lynda Laff said in a March Eli-sponsored audioconference, “A Closer Look at Supply Management in the 2008 PPS Era.”

Seventy-six diagnosis codes now can trigger NRS points, said Laff, with Laff Associates in Hilton Head Island, SC. Relevant OASIS items are M0230, M0240, M0250, M0450, M0470, M0474, M0476, M0488, M0520, M0540 and M0550.

Is that right? A hard concept for agencies to understand is that they receive the same NRS payment regardless of the supplies they furnish to the patient or report on the claim.

The NRS payment is based on how you answer the underlying OASIS questions, not on what supplies you include on the claim, emphasized billing expert M. Aaron Little in another recent Eli-sponsored audioconference, “Crash Course: Crucial Lessons Your HHA Billing Staff Must Know For 2008.” When you use the HIPPS code saying you furnished no supplies to the patient, you still receive the full NRS payment.

“That may not be that way forever,” cautioned Little, with BKD in Springfield, MO. “But as it stands today, that is how it works.”

Details: HHAs must report NRS on claims using two revenue codes, CMS noted in Nov. 2, 2007 Transmittal No. 1371 (CR 5776). When the agency doesn’t furnish supplies, it indicates that by using a number instead of a letter in the fifth position of the HIPPS code.

New edits: Beginning April 7, the intermediaries implemented informational claims edits that check for supplies codes, a CMS source confirms to Eli. If a claim has a HIPPS code that indicates the agency furnished supplies by using a letter in the fifth position, the claim must also include a line item for NRS and related charges.

If the claim includes a HIPPS code ending in a number, which indicates the submitting agency did not furnish NRS to the patient, then the claim won’t undergo the NRS edit check.

Currently, when an agency submits a claim with an alphabetic fifth HIPPS code digit (S-X) but doesn’t report supplies charges on that claim, the system places codes M50 and N59 on its remittance advice, explains reimbursement consultant Michelle Enger with Optimal Reimbursement Strategies in Clearwater, FL.

But many agencies probably won’t even notice the codes or bother to look up the descriptions, Little predicts. Even if they do look up the codes, “the descriptions are so generic and ambiguous that many may not understand why the codes were assigned to the claim,” he says.

Home care providers would have to already know about the NRS edits to understand the RA codes, Little maintains.

Tip: HHAs can look up RA remark codes they don’t know at
www.wpc-edi.com/content/view/507/228, Little offers.

RA remark M50 says “Missing/incomplete/ invalid revenue code(s)” and RA remark N59 says “Alert: Please refer to your provider manual for additional program and provider information,” Enger points out.

Translation: What those codes are really telling providers is “Hey, we recognize we paid you even though there were no supplies. We’re not going to do this forever, so you need to be getting your systems prepared not to do this any longer,” Little told audioconference attendees.

Use NRS Grace Period Wisely

Unfortunately, providers will find it “very tempting to ignore the edits, especially during the grace period since there’s no immediate negative consequences,” Little expects.

Get serious: Starting Oct. 1, the NRS edits will change from being informational to returning to provider (RTP’ing) claims. If you report a claim with an NRS-provided HIPPS code and no NRS line item, it will come back to you and you’ll have to correct it and resubmit. “That is something you definitely want to avoid because it would significantly slow down your cash,” Little warned.

“The grace period between April 7th and October 1, 2008 provides you a great period in which home health agencies may use the alert messages on their remittance to target examples of claims that were required to supply reporting,” regional home health intermediary Palmetto GBA urged in a recent Ask-The-Contractor teleconference about PPS billing changes.

Note: See the breakdown of NRS points for each OASIS item and diagnosis code in Table 10A of the PPS final rule. The list of specific diagnosis codes used to add NRS points is in Table 10B. For a free copy of the PPS final rule, email editor Rebecca Johnson with “PPS Final Rule” in the subject line.