Home Health & Hospice Week

You'll have to report supplies by new deadline or face returned claims.

Home health agencies will have some breathing room on at least one new facet of the prospective payment system--nonroutine supplies (NRS) reporting.

The Centers for Medicare & Medicaid Services said in the final PPS rule that it would delay NRS reporting edits until April and institute a grace period before returning to provider (RTP'ing) claims.

Now the agency has set its start date for the informational NRS edits as April 7, according to Nov. 2 Transmittal No. 1371 (CR 5776). And then the Medi-care claims processing system will start RTP'ing claims for NRS problems Oct. 1, CMS reveals.

One thing at a time: HHAs will be relieved not to tackle NRS issues at the same time that all the other PPS changes are hitting in January, predicts Lynn Olson with HHA billing company Astrid Medical Services in Corpus Christi, TX. Staggered implementation of this major change will help agencies handle it.

CMS seems to want to help agencies figure out the new system, Olson praises. A delayed onset of NRS edits coupled with the informational grace period is "a learning scenario versus a hammer scenario," he tells Eli.

How the Edits Work

When PPS refinements take effect Jan. 1, part of the new system is a case mix assignment for NRS only. Based on 11 OASIS items, PPS will assign the episode to one of six supplies categories.

That NRS severity category will reflect in the new HIPPS code. The fifth digit of the new HIPPS code will represent the supplies level and whether the agency furnished supplies.

During the grace period: Between April 7 and Sept. 30, when the HIPPS code indicates the agency provided supplies but there is no NRS line item on the claim for those supplies, the system will pay the claim but include an informational edit.

The system will put remark codes M50 and N59 on the remittance advice (RA) for the claim, CMS explains in MLN Matters Article MM5676.

Avoid this pitfall: The remark codes could cause some confusion, because they are rather vague. M50 says "Missing/incomplete/invalid revenue code(s)" and N59 says "Alert: Please refer to your provider manual for additional program and provider information."

It's the combination of the two that will tip off agencies to the NRS problems. "The temporary use of the combination of these messages is intended to serve as an important alert to the HHA and to direct the attention of HHAs to the supply reporting requirements," CMS explains in the educational article.

After the deadline: After Oct. 1, when the HIPPS code indicates the agency furnished supplies but there is no NRS line item on the claim for the supplies furnished, the claims system will RTP the claim.

New message: After the deadline, intermediaries will include a message with the RTP'd claim that instructs agencies to review its records regarding supplies and correct the claim.

HHAs will have two options in correcting the problem, the message will read. They can add the appropriate supply revenue code to the claim and resubmit it. Or they can change the HIPPS code to indicate they didn't furnish supplies.

When the HIPPS code shows a provider didn't provide supplies, the claim isn't subject to the NRS edit, the transmittal explains.

Edit bypass: When there are no NRS line items on the claim, some software systems may automatically assign a HIPPS code that indicates the agency didn't furnish supplies to avoid the NRS edit, said M. Aaron Little with BKD in his recent Eli-sponsored teleconference about PPS billing changes.

But relying on that software mechanism when you really did furnish supplies could distort your internal record-keeping, critics charge. And it will deprive CMS of data it will use to set future NRS payment rates.

Start NRS Training

Even though you've got some time before the NRS edits hit, you should begin training staff on this aspect, CMS urges. "Make certain that your billing staffs are aware of these changes," the agency says in the article.

Many agencies already are tracking supplies internally, Olson notes. And some are reporting them already as well--Astrid encourages its clients to do so.

The NRS reporting requirement should spur even more agencies to track supplies accurately, Olson says. That in turn will help them arrive at more accurate internal calculations, such as costs per visit that are inclusive of indirect costs.

Olson expects most HHAs will have NRS re-porting down by the time the Oct. 1 deadline arrives. 
 
Note: The NRS transmittal is at www.cms.hhs.gov/transmittals/downloads/R1371CP.pdf and the MLN article is at www.cms.hhs.gov/MLNMattersArticles/downloads/MM5776.pdf.