Home Health & Hospice Week

Know which forms and code set to use for episodes spanning the transition date.

Oct. 1 is the big day for home health agencies’ transition to ICD-10 and OASIS-C1/ICD-10. But you should be coding under the new system already, experts urge.

Home health coders should have started “real” dual coding episodes that started Aug. 3 and later, says Lisa Selman-Holman, AHIMA Approved ICD-10-CM Trainer/Ambassador of Selman-Holman & Associates, CoDR — Coding Done Right and Code Pro University in Denton, Texas (see Eli’s HCW, Vol. XXIV, No. 25). That’s because you must submit a request for anticipated payment (RAP) at the start of care and an end of episode claim (EOE) at the end of the 60-day episode of care. Patients admitted Aug. 3 to Sept. 30 will require a RAP completed with ICD-9 codes an EOE claim with ICD-10 codes (if the episode spans the entire 60 days).

As soon as you or your vendor has successfully tested the coding and OASIS-C1/ICD-10 changes, “I would definitely begin both ICD-10 coding and use of OASIS-C1/ICD-10,” advises Lynda Laff with Laff Associates in Hilton Head Island, S.C.

Good news: “The changes in ICD-10 make the OASIS much more understandable and I believe will reduce many errors,” Laff says.

Know The Impact On Transition Billing

Three factors affect how you’ll use ICD-10 on episodes for services that span the Oct. 1 date, says Selman-Holman. These factors are:

• The Outcome and Assessment Information Set (OASIS) assessment completion date (OASIS item M0090 date);

• The claim “From” date (episode start date); and

• The claim “Through” date.

Pick your OASIS: You’ll use the OASIS-C1/ICD-9 for M0090 (Date assessment completed) dates through Sept. 30. This assessment form accepts only ICD-9 codes. You’ll use the OASIS-C1/ICD-10 for M0090 dates Oct. 1 and later. This assessment form accepts only ICD-10 codes.

Choose your code set: For home health claims (type of bill 032x), you must report ICD-10 codes based on the claim “Through” date, Selman-Holman says.

With Requests for Anticipated Payment (RAPs), Medicare billing instructions require that the “From” and “Through” dates are the same, Selman-Holman says. So, if the episode begins in September 2015, the “From” and “Through” dates on the RAP would report the same date in September. You would report ICD-9 diagnosis codes on these RAPs using codes that match the OASIS assessment, she says.

On final claims, the HIPPS code must match the HIPPS code that was reported on the RAP, Selman-Holman says. For episodes beginning in September and ending after Oct. 1, the HIPPS code on the RAP is based on the ICD-9 codes matching the OASIS assessment. But the final claim in October 2015 will include ICD-10 codes, she says.

The Centers for Medicare & Medicaid Services had originally indicated that home health agencies should use General Equivalence Mappings (GEMs) or other translation tables to derive ICD-10 codes for use on claims for episodes that span Oct. 1, 2015. But a revision to MLN Matters SE1410 removed this instruction.

“This means that any episode that crosses over the Oct. 1, 2015 implementation date will need to be coded in ICD-9 and ICD-10 based on the M0090 date of the OASIS, the ‘from’ date on the episode and the ‘through’ date on the episode,” Selman-Holman says. Rather than relying on inexact codes that GEMs would provide, “actual coding processes must be used,” she says.

Good side: “This does increase the burden to agencies, however it will result in fewer errors and rejections of claims,” Selman Holman says. “Because the GEMs are not complete codes in some cases and include only 7th character ‘A,’” Selman-Holman had been concerned that “the MAC systems would not accept the codes and/or HIPPS codes would be affected.”

Other assessments: These same procedures will apply to resumption of care (ROC) as-sessments (M0100 = 03) and recertification (M0100 = 04) and follow-up (M0100 = 05) assessments when the episode start date and the M0090 date on those assessments are both before Oct. 1, 2015, but the episode ends in October 2015, Selman-Holman says.

Note: More details are in MLN Matters SE1410 at www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/SE1410.pdf. For more information on OASIS and diagnosis coding, subscribe to Eli’s Home Health Coding and OASIS Expert at https://www.aapc.com/codes/.