Home Health & Hospice Week

Don’t waste time and money on unnecessary RAP cancellations?

Are you sure you’re billing nonroutine supplies correctly so your claims don’t start bouncing back next month?

On Oct. 1 the Centers for Medicare & Med-icaid Services will begin returning claims with a HIPPS code that indicates NRS use but no supplies charges, home health agency reimbursement consultant Michelle Enger pointed out in an Eli-sponsored audioconference this summer.

"The claims will start to RTP on Oct. 1, 2008, and that could be substantial amounts for home health agencies and a negative cash flow," warned Enger, with Optimal Reimbursement Strategies in Clearwater, FL.

Tip: Pay attention to whether you are re-ceiving informational remark codes M50 and N59 on your current claims, suggested Enger in the audioconference, "Home Health PPS 2008 Reim-bursement Issues and How to Deal With Them Effectively." Those will be the reasons the claims system bounces back your claims when the Oct. 1 edit starts.

Other tips for PPS billing success Enger of-fered include:

• Don’t waste time on unnecessary adjustments. One great thing about the major prospective payment system revisions that took place in 2008 is that the claims system now automatically adjusts up and down for number of therapy visits, Enger cheered. That means you don’t have to spend time adjusting a request for anticipated payment (RAP) that had no therapy utilization indicated when you submitted it, but then the patient needed therapy later.

"There is no need to go in and cancel the RAP and resubmit it with a newer HIPPS code," Enger told a call participant.

• Avoid losing patients when they go into the hospital. A frequent complaint Enger hears from clients is that other HHAs pick up their patients when those patients come out of an inpatient stay.

Strong communication with the patient, her caregiver and the hospital discharge planner is the key to retaining patients in these situations, Enger advised. Some agencies use form letters to the patient and hospital informing them that the patient is on service with their agency and requesting notification when the patient is discharged so the agency can resume care.

HHAs often keep a list of patients in the hospital and communicate regularly with their families and representatives to keep tabs on the patients, Enger added.

• Educate staff on OASIS. Your patients’ reimbursement levels come directly from the OASIS assessments your staff fills out, Enger reminded listeners. "A lot of clinicians really need to have a firm grasp of how to score those questions because they are very important," she stressed. That’s particularly true under the PPS revisions, when multiple M0 items work together to determine scoring.

Hot spot: A thorough understanding of diagnosis coding is particularly important now that codes down to the sixth level can affect reimbursement, Enger pointed out. Some codes that never affected reimbursement before, such as those in cardiac categories, now can mean extra money for the episode.

Try this: If you have questions about how you should fill out OASIS, try your state OASIS coordinator for answers, Enger suggested. They’ll be much more knowledgeable than your regional home health intermediary, for example, she said.

• Avoid no-RAP LUPAs. CMS gives you the option of sending in a final claim with no previous RAP if you know your patient’s episode will be a low utilization payment adjustment (LUPA) -- four or fewer visits. But Enger advised against using this option.

A RAP "holds open" the episode and prevents another agency from coming in to "claim it," she said. "I would seriously think twice about it and send in a RAP."

• Bill on time. One thing the PPS revisions didn’t change is the auto-cancel policy, Enger noted. Agencies have 120 days from the date of service or 60 days from the RAP paid date to submit the final claim. Otherwise, the RAP will auto-cancel and the final claim will get rejected.

"That’s why it’s very important to be sure and have your billing processes and work flow so that you get the RAP out timely and the final claim is submitted timely," she emphasized.

• Understand M0110. HHAs are still confused about the definition of an adjacent episode. It didn’t help that the claims system was classifying some episodes incorrectly in the beginning of 2008 due to a software problem that didn’t count 2007 episodes toward the early/later episode designation.

Crucial: Agencies need to be responsible for keeping track of their own claims and whether they pay correctly, Enger urged. (See related story, this page, for how to do so.)

Staff should count adjacent episodes as no more than 60 days between the "to" date on the last claim and the "from" date on the current one, Enger advised. When the previous episode was a partial episode payment (PEP) adjustment, use the date of last billing activity (DOLBA) to calculate, she added.

"The information that you see in HIQH or ELGA is very important for the date of last billing activity," she said in the audioconference. "That’s the date CMS will actually use to determine whether it’s an adjacent episode."

• Know your treatment authorization code. Now that the treatment authorization code has gotten so complicated, some agencies have thrown up their hands at trying to figure it out. But the code is very important because the claims system uses it to recode a claim in the event of an up- or downcode. The system will also kick out your claim if the code isn’t in the correct format.

Under old PPS, the code was all numbers, Enger noted. But now it is a mix of numbers and letters. If "N" represents numbers and "A" represents letters, the code should always look like this: "NNAANNAANNAAAAAAAA," she explained.

A further confusing factor is that letter "O"s and zeroes are difficult to distinguish, she added.

• Be ready for adjustments. CMS is preparing to make adjustments for the billing glitches in the PPS revisions for the first half of 2008. In the latest Open Door Forum, a CMS rep said it’s working on setting a date for the adjustments.

The most significant adjustments will be for the early/later episode error and for the LUPA add-ons incorrectly paid for ineligible episodes. While the LUPA add-on adjustment will recoup money from agencies, hopefully the M0110 adjustment will balance that out, Enger noted.

• Bill 329. One caller asked when to bill a type of bill 329 versus 339. You might have noticed your bills sometimes flip between the two after submission, Enger noted.

HHAs should always bill 329, Enger counseled. Medicare wants to change the type of bill itself depending on whether the patient is eligible for Part A and B (329) or just Part B (339).

• Prepare now for 2009 changes. It’s never too early to start gearing up for the next set of PPS changes, Enger advised. As soon as CMS issues the 2009 payment rule -- which it hasn’t done yet -- you should read it and begin any preparation and business planning that results from the changes. Of course, changes in 2009 will be much less drastic than the ones in 2008.

"It really matters to get a head start on the changes that are going to occur ... so you can best plan your agencies’ growth and the reimbursements for the following year," she said. "Start early so the time does not run out on you." v