Home Health & Hospice Week

If you want to protect your reimbursement for patients who transfer from another home health agency during their 60-day episodes, you're going to have to take some pretty laborious measures.

Situations where patients transfer HHAs within an episode can get downright nasty, acknowledges Lynn Olson with billing company Astrid Medical Services in Corpus Christi, TX. Agencies that feel another provider stole a patient can "get mad and want to make that other provider suffer," Olson warns.

The way they do it: refuse to either cancel an already-filed request for anticipated payment or submit the final claim that closes out the episode. Until "Agency 1" does one or the other, "Agency 2" - the agency that admitted the transfer patient - can't file its own RAP for the patient. Under the prospective payment system, only one HHA at a time can receive payment for the patient.

"Agencies will hold onto that RAP money for the 60- to 75-day loan" it represents while the second agency must cool its heels, Olson tells Eli. In extreme situations, Agency 2 must call in the regional home health intermediary to cancel Agency 1's claims so it can bill for the patient.

Or sometimes Agency 1 argues that it should be paid for all of its visits to the patient, even if they overlap with Agency 2's visits. The RHHI also is called in to settle those types of cases.

When settling transfer patient disputes, RHHI Palmetto GBA says it requires the agency that accepted the transfer patient to have three pieces of documentation.

1. A printout of the Health Insurance Query for Home Health (HIQH) screen. HHAs should check this screen for every patient and print it out even if it doesn't show an open episode for the patient, Palmetto says in a March 3 question-and-answer document with its 12-state home health coalition. If the patient later turns out to be a transfer patient and you failed to print out and save the HIQH screen documenting that no episode showed up, the other agency is entitled to the reimbursement.

2. Documentation that it informed the patient that two HHAs can't receive payment for the patient's services simultaneously. Even if the agency had no idea the patient was also being seen by another HHA, Agency 2 won't receive payment for the patient unless it informed the patient of this basic concept - and documented it in the record, Palmetto says in the Q&A posted March 24.

3. Documentation showing the name of the individual contacted at Agency 1, the telephone number, the date of contact and a brief description of the conversation. Palmetto requires this item only if another episode did show up in the HIQH screen.

These three pieces of documentation are fairly easy to assemble if you know the patient is a transfer patient from the start, says consultant Pat Sevast with American Express Tax & Business Services in Timonium, MD. But if no open episode shows up on the HIQH screen upon a patient's admission, few agencies are going to go through the trouble of explaining to the patient the reimbursement situation for two HHAs seeing a patient at the same time and documenting that explanation.

"That's an awful lot to have to do for every single patient, because you never know who's a transfer patient," Sevast comments.

To cut down on the transfer burden while still protecting reimbursement for those patients, Sevast suggests screening patients by asking if they've ever had clinicians come to their home. If patients don't seem clear on the dates or other details of the services, it might be a good idea to go through the above steps and call the other company if the patient identifies one to make sure the episode really is closed.

HHAs should address potential transfer situations up front, Sevast insists, because it's more efficient to work out reimbursement problems from the get-go than to dispute them afterward.

Palmetto's stringent documentation requirements seem aimed at doing exactly that - forcing HHAs to work out their own transfer patient problems most of the time, surmises Olson. Chiefly, it gives agencies a big incentive to do an HIQH search for every new admission.