Home Health & Hospice Week

Make sure your clinicians know the difference between M0030 and M0090.

If you don’t want to kiss an entire episode’s reimbursement goodbye based on a technicality, you’d better double-check your OASIS submission status for every claim you submit.

So advised a Centers for Medicare & Medicaid Services official in the March 22 Home Health Open Door Forum. The CMS staffer reviewed the OASIS matching edit the agency unveiled in a transmittal issued last October, which takes effect April 1 (see Eli’s HCW, Vol. XXVI, No. 39-40). Under the edit, the Medicare claims system will deny a claim if there is no corresponding OASIS and edit date is more than 40 days from the OASIS completion date. (That timeframe will shorten to 30 days after an unspecified introductory period.)

To keep your end of episode claims in the clear, make sure you have successfully submitted the OASIS matching the claim to the QIES national database, the CMS official instructed. That means checking the Final Validation Report.

In the Final Validation Report, you’ll find the confirmation of the OASIS assessment’s receipt, the date of the receipt, and any warning or fatal errors related to the assessment, he explained.

Failing to submit an OASIS assessment isn’t the only reason for a denial. Mismatching information on the OASIS assessment and claim can also lead to losses. To avoid such unnecessary denials, “HHAs should ensure, prior to submission of the OASIS assessment and the claim, that the following information is correct,” CMS recommends in a new MLN Matters article about the edit:

1. HHA CMS Certification Number (OASIS item M0010)
2. Beneficiary Medicare Number (OASIS item M0063)
3. Assessment Completion Date (OASIS item M0090)
4. Reason for Assessment (OASIS Item M0100) equal to 01, 03 or 04.

“These items will be used to match claims and assessments, so accuracy of submission can help prevent claim denials,” says the article released March 24.

Another tip: Remember, Medicare won’t deny your claim for a late OASIS unless the OASIS still isn’t in the system when you submit the claim. As long as you make sure the OASIS goes in before your claim, you’re good, the CMS staffer reminded agencies in the call.

Also remember that claims will process without checking for an OASIS if you submit the claim before the 40-day (and later, 30-day) OASIS deadline. The edit calculates that deadline using the M0090 date, not the date of discharge, the CMS official told a caller in the question-and-answer portion of the call.

The deadline is also not calculated based on the M0030 (Start of Care) date. M0030 and M0090 are often the same date, but not always.

Refresher: “M0030, SOC Date, is the date that the first reimbursable service is delivered,” analytics vendor PPS Plus says on its website. “This is the beginning of payment episode and should be reported as the ‘from date’ on the RAP and final bill.” On the other hand, “M0090, Date Assessment Completed, specifies the actual date that the assessment, the paperwork, is completed. You have up to five days after the SOC date (with the SOC date being day 0) to complete the paperwork.”

Important: “M0090 may not always coincide with a home visit,” PPS Plus says. “It may be the date that the last bit of information is received from the MD/family.”

CMS elaborates in its OASIS-C2 Guidance Manual that was effective Jan. 1. “If the clinician needs to follow-up, off site, with the patient’s family or physician in order to complete an OASIS or non-OASIS portion of the comprehensive assessment, M0090 should reflect the date that last needed information is collected,” the agency says in the response-specific instructions for the item.

The date for M0090 would also change “if the original assessing clinician gathers additional information during the SOC 5-day assessment time frame that would change a data item response,” CMS continues. In that case, “the M0090 date would be changed to reflect the date the information was gathered and the response change was made.”

The edit may impact your claims sooner than you think. It will apply to claims with dates of service on or after April 1, according to the MLN Matters article — not “through” dates of April 1.

Watch for: You’ll be able to identify claims denied due to this edit because Medicare will apply remittance messages of Group Code CO and Claim Adjustment Reason Code 272, the article says.

Note: See the new MLN Matters article at www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/SE17009.pdf. For tips on protecting against the edit, see Eli’s HCW, Vol. XXVI, No. 9.