Home Health & Hospice Week

Heads up, HHAs:  Don't let the Jan. 1 billing change catch you by surprise.

If you aren't up to speed on the new wage index change taking effect in 2006, you could be throwing money down the drain.

The Centers for Medicare & Medicaid Services has adopted the new Core-Based Statistical Areas (CBSAs) for wage index purposes in calendar year 2006, meaning home health agencies won't use the old Metropolitan Statistical Area (MSA) designations anymore (see Eli's HCW, Vol. XIV, No. 40).

Hospices had some major billing problems when they switched over to CBSAs Oct. 1 (see Eli's HCW, Vol. XIV, No. 36), and HHAs could too, warns Abilene, TX-based consultant Bobby Dusek.

A sizeable portion of HHAs don't seem to realize there is a switch to CBSAs at all, experts note. That may be because unlike hospices, agencies don't receive rate letters from their regional home health intermediaries, offers consultant M. Aaron Little with BKD in Springfield, MO. "When the CBSA codes were initiated for hospice, the rate letters contained detailed information on how to properly code claims with the appropriate CBSA codes," Little recounts.

Even HHAs that know about the CBSA change are puzzling over unanswered questions, maintains Lynn Olson with billing company Astrid Medical Services in Corpus Christi, TX.

Go to the source: The best way to get a handle on the new CBSA billing rules is to thoroughly read and understand the prospective payment system final rule published in the Nov. 9 Federal Register, experts recommend. "If you haven't downloaded the Federal Register notice, this will be confusing," Dusek warns.

Many HHAs were happy CMS approved a one-year transition to the new wage index categories in the final rule. But the requirement to use a blended rate--50 percent old MSA/50 percent new CBSA--and a special code that goes with that rate will make the billing process even more chaotic, observers predict.

Free Software Requires Manual Entry

Agencies using the free PC-ACE PRO32 software to bill will have some extra work on their hands. The software won't accept a five-digit CBSA code, so agencies must perform a workaround manually, RHHI Palmetto GBA says in its CBSA billing instructions.

HHAs must delete the MSA code from the patient's Reference Files and leave that field blank, Palmetto instructs. Then they must manually key the new five-digit code into the appropriate Value Code field.

Use a dollar amount: To make matters even more confusing, the Value Code field is a monetary field, so agencies must enter the CBSA code as a money amount. For example, HHAs must enter CBSA code 11340 as "Value Code: 61 11340.00."

"If the CBSA is submitted without the .00, the processing system will justify the amount to 113.40, which is an invalid value," Palmetto warns. "The HH claim will return to provider for corrections indicating cents were billed with the Value Code 61."

Extra Visits Required?

Agencies are also confused by another part of Palmetto's directions: "To receive the CBSA wage in-dex, there must be at least one line item date of service (LIDOS) for January 1, 2006 or after on the Final Claim."

In the past, agencies have been able to claim the new year's higher rate as long as the episode ended after the transition date, regardless of whether there was a visit after that date, Dusek notes. Agencies commonly furnish a visit three or four days before the end of the episode, especially now when they need to deliver expedited review notices, he points out.

"It's very possible to make a visit on Dec. 30th and have the episode end Jan. 2nd," Dusek notes. Under Palmetto's instructions, "we don't know how to bill that. Will agencies be forced to make another visit for the new rate?" 

Note: The Federal Register notice is at www.access.gpo.gov/su_docs/fedreg/a051109c.html. For a copy of Palmetto's CBSA billing instructions, email Executive Editor Rebecca Johnson at rebeccaj@eliresearch.com with "CBSA Instructions" in the subject line.