Home Health & Hospice Week

Hospice coding change still taking effect Jan. 1, CMS says in forum.

The feds are expecting smooth sailing for home health agencies billing under prospective payment system refinements Jan. 1.

The Centers for Medicare & Medicaid Services has been extensively testing the claims system changes with its regional home health intermediaries, reported CMS' Carol Blackford in the Nov. 28 home health Open Door Forum.

"We are very comfortable that our systems here will be able to process claims and pay ... based on the information provided in the claim itself," Blackford told the 280 forum callers.

The trickiest part of the billing changes is the recoding of claims when the therapy visit number or episode sequence changes, CMS' Wil Gehne noted in the forum. Medicare now will automatically upcode or downcode claims for such changes, which often require a completely different HIPPS code.

After weeks of pricer software testing, "we're feeling very comfortable with it now," Gehne said. "With that key piece in place, I think folks can be pretty well assured."

Stay vigilent: Home care experts aren't quite as sanguine and warn providers to be prepared for claims and cash flow delays resulting from problems with Medicare's systems or providers' own programs.

Get Your NRS Facts Straight Before Transition

Gehne also reminded listeners that they don't have to stress about Nonroutine Supplies (NRS) edits quite yet.

Although PPS will pay agencies for NRS starting in January, the edits for NRS charges on claims won't begin until April.

Even then, they'll only be informational until October. Agencies will receive a warning message when they submit a claim with a HIPPS code that indicates supply usage but with no accompanying NRS charges on the claim.

Then, starting in October, the system will start returning to provider (RTP'ing) claims with that discrepancy, Gehne explained.

Tip: When the HIPPS code ends in a letter, it indicates you did furnish NRS to the patient. A code ending in a number tells CMS that you did not furnish supplies and don't need line item supplies charges on the claim.

Use the time: The warning messages that apply during the grace period from April to September should spur agencies to take action about NRS problems before they result in cash-draining claims delays. HHAs receiving the error messages should "look at their administrative processes and see if they can find reasons why the supplies may have been omitted," Gehne advised.

And don't forget that beyond the possible claims delays, these edits won't make any difference to your payment for episodes. "There's no payment impact in any of this. That's been the major confusion," Gehne stressed.

Bottom line: Medicare will pay you the same amount for an episode whether you use the HIPPS code that says you furnished the supplies or the one that indicates you did not furnish supplies.

"The goal ... is just to improve the accuracy and completeness of our supply data for future analysis," Gehne reminded providers.

Other issues raised in the forum include:

• Hospice billing and coding. As previously announced, CMS has moved the deadline for additional hospice data reporting from Jan. 1 to July 1 (see Eli's HCW, Vol. XVI, No. 39). Hospices may begin reporting the visit data in January if they wish, Blackford noted.

But the requirement that hospices cannot use V codes as the primary terminal diagnosis continues to take effect Jan. 1, Blackford pointed out.

Problem: One caller expressed frustration at how to count visits in an inpatient setting with contractors. Blackford referred her to the questions and answers on the requirement online at www.cms.hhs.gov/center/hospice.asp.

• HAVEN. CMS has not yet set a release date for the new version of HAVEN that is compatible with the PPS changes. The agency is working to release HAVEN 1.60 as quickly as possible, Blackford told a forum caller.

• NPIs. With all the other payment changes happening Jan. 1, don't forget that you'll need to submit your National Provider Identifier number on Medicare claims too. CMS will allow you to continue using a legacy ID number in the billing and pay-to fields as long as it's accompanied by an NPI, instructed CMS' Geraldine Nicholson.

CMS hasn't set a date for the complete switchover to NPIs without legacy numbers, Nicholson added. But providers may want to test a small number of NPI-only claims to make sure payment will remain smooth when that requirement eventually takes effect.

• Hospice COPs. The long-awaited conditions of participation for hospice providers may finally come out. CMS is on track to publish the COPs in May 2008. The standards "are not being held for any reason," a staffer assured forum callers. 

Note: The next home health Open Door Forum is scheduled for Jan. 9.