Home Health & Hospice Week

You're going to have to wait a bit longer to get your rightful M0110 money from Medicare.

The Centers for Medicare & Medicaid Services announced back in March that the claims system wasn't counting 2007 episodes when calculating "early" or "later" status for episodes under the prospective payment system refinements that took effect Jan. 1 (see Eli's HCW, Vol. XVII, No. 10, p. 77). That error underpaid many agencies when episodes that were really "later" were downcoded to "early."

But CMS didn't implement the software fix for the problem until July. And it still hasn't an-nounced a date for making claims adjustments for the M0110 sequencing problem and other PPS re-finement errors.

"Due to the number and complexity of those issues, CMS is still developing the schedule for all of the adjustments," CMS' Wil Gehne said in the Aug. 13 Open Door Forum for home care. "A one-time notification instruction will be issued very soon that outlines the final schedule."

HHAs are frustrated at the delay, since CMS said it would make the adjustments after correcting the problem. "July has come and gone and we have no payments or further guidance on when or how the problem will be resolved," DJ Murdoch with Able Home Health in Rockford, IL tells Eli.

"We understand that home health agencies are particularly interested in the adjustments to correct the 2007 episode sequencing issue," Gehne acknowledged in the forum. "CMS will correct all those claims and we appreciate your patience."

CMS is "still developing instructions for intermediary initiated adjustments that will take place to resolve payment issues with home health claims since the January 2008 implementation of the HH PPS refinement," regional home health intermediary Cahaba GBA adds in a message to providers.

CMS might be holding off on making the mass adjustments because it is still correcting PPS refinement problems, experts say.

July and August software updates fixed the M0110 sequencing problem and other errors such as problems related to payment rates for speech language pathology and clinical domain scores being recoded, Gehne explained. But the fixes also introduced another new glitch.

After the Aug. 4 claims system software update, a missing wage index file caused claims to be paid at 2007 rates, Cahaba explains in its message to providers.

The correction was scheduled for implementation by Aug. 17. The system will adjust final claims paid during this time period -- "therefore, providers do not need to take any action," Cahaba instructs. "In addition, providers do not need to take action with RAPs affected by this issue as any payment issues will be resolved when the final claim for the episode is reimbursed."

One less thing: At least agencies don't need to download another new PC Pricer. The wage index problem was only in the intermediaries' software, Gehne explained.

Medicare's software problems are affecting Medicare Advantage payments too, several providers complained in the forum. Due to the multiple corrections, the managed care plans "don't know what to pay or when to pay it," said Joy Sandelier from Ministry Home Care in Marshfield, WI.

Pennsylvania MA plans are having trouble adjusting claims for therapy variations and don't pay correctly, a provider calling from that state added.

Other issues raised in the forum include:

• OASIS-C. Agencies anxious to see the revamped OASIS tool won't have long to wait. Field testing of the new assessment tool should wrap up this month, reported CMS' Debbie Turkay. CMS will conduct some data analysis and testing, then will submit any new quality measures to the National Quality Forum for endorsement, she said.

Then CMS plans to post the new OASIS instrument by October, Turkay revealed in the forum. Agencies will begin using the new OASIS document by January 2010 if all goes as planned.

• Coding guidance. HHAs struggling to improve or perfect their diagnosis coding may soon have help from CMS. The agency is working on updating its guidelines for home care diagnosis coding, said CMS' Lori Anderson. "We hope to have it out there soon."

• Stamped signatures. CMS is still getting questions about stamped signatures, CMS' Sandra Bastinelli acknowledged in the forum. The agency's prohibition on stamped physician signatures applies to all providers and documentation, not just hospices and terminal illness certification, Bastinelli reiterated to a caller. "It's for everybody," she said.