Home Health & Hospice Week

M0175, Medicare Advantage also addressed in Open Door Forum.

You may be months ahead of the curve on acquiring your National Provider Identifier number, but your claims could still get frozen in May when the NPI deadline hits.

That's because you'll also need the NPI of your referring physicians on the claim, and many docs haven't gotten around to applying for their NPI yet, providers told the Centers for Medicare & Medicaid Services in the Jan. 30 Home Health Open Door Forum.

Home health agencies are losing sleep over whether their referring physicians will get their NPIs by May, Bob Wardwell of the Visiting Nurse Associations of America said in the forum. Agencies want to make sure their claims won't be "held hostage" by physicians who've been negligent in acquiring their numbers, said Wardwell, a former top CMS official.

Durable medical equipment suppliers are under the same gun, attorney Seth Lundy noted in the call. And when furnishing equipment to chronically ill patients, the order may be years old, said Lundy with Fulbright & Jaworski in Washington, DC. Suppliers want to know whether CMS will accept the old UPINs if an NPI isn't available.

"This is going to be a growing concern as that May date comes closer," Lundy told CMS officials in the forum that drew 569 participants.

Providers Call For NPI Registry

Even if your referring physicians all get their NPIs, it will be a big administrative burden to contact them all individually to get the new number. One Tennessee agency called in asking for further information on CMS possibly furnishing a registry of physician NPIs so providers can merely look them up.

Nothing to offer: CMS doesn't have any information on an NPI registry, CMS' Natalie High-smith told listeners.

More than 1.6 million providers have obtained their NPIs so far, Highsmith noted. CMS estimates it may take 120 days to fully implement the number into your current business practices. With the May 23 due date looming, providers need to act now to acquire their NPI and "to avoid disruption in cash flow," she urged.

More information on NPIs is at www.cms.hhs.gov/nationalprovidentstand.

Other issues addressed in the forum include:

• PPS refinements. CMS still hasn't issued the highly anticipated proposed rule on prospective payment system refinements. The agency can't say specifically when the rule will come out but expects it "soon," an official noted. The latest Department of Health & Human Services' semiannual regulatory agenda, published Dec. 11, 2006, sets a new date of May 2007 for the proposed rule.

However, industry observers expect the rule may come much earlier than that new deadline. A May release would leave insufficient time for the process of public comment, final rule and necessary steps for implementation, the National Association for Home Care & Hospice says in its member newsletter.

The refinements rule is expected to make changes to the 10-visit therapy threshold. It also may address unbundling of certain medical supplies for billing, notes consultant Pat Laff with Laff Associates in Hilton Head Island, SC. "I wish they could issue it soon," Laff tells Eli.

Note: For more information on the PPS refinements rule, tune into the Feb. 28 Eli Research-sponsored teleconference, "2007 PPS Refinements," presented by Mark Sharp with BKD. To sign up online, go to www.audioeducator.com or call 1-800-508-2582.

• M0175. If you're going to receive a M0175 overpayment demand letter for the first year of PPS, you probably should have gotten it by now, said CMS' Wil Gehne.

Intermediaries on Jan. 18 began sending out the letters, which assess overpayments for incorrect answers to the OASIS question on prior inpatient stays (see Eli's HCW, Vol. XVI, No. 2).

• Managed care. Home care providers continue to have trouble accessing accurate eligibility information for Medicare Advantage patients. Pro-viders need a way to access managed care enrollment information because the Common Working File is often not up to date, one caller said.

CMS is in discussions over how to help providers alleviate this problem, Highsmith assured the caller. The agency is working on a "plan of action" for providers.

Crisis: This problem is experienced by many providers, Wardwell stressed. They need to find out what to do when they accept a patient in good faith, then can't obtain payment from a managed care plan for her.

• Bundling. If you're a home health agency getting heat over bundled items and services from suppliers and Part B therapists serving your patients, there's a solution to offer them. Under the old system, only Part A providers could access home health episode information for patients under the Common Working File, Gehne told listeners.

New tool: Now Part B therapists and suppliers can use the HIPAA Electronic Transaction System (HETS) to search for patients' home health episode information. Providers will have to sign up to use HETS, then learn how to send a 270 inquiry and read the 271 response that comes back, Gehne instructed. Information on doing so is online at www.cms.hhs.gov/HETShelp.