Home Health & Hospice Week

Home health agencies shouldn't have too much longer to wait for the money they are owed due to prospective payment system revision errors.

The Centers for Medicare & Medicaid Services indicated it would make adjustments for M0110 and other claims problems this summer. But when summer rolled around, PPS claims system problems were still cropping up and the agency pushed back that schedule (see Eli's HCW, Vol. XVII, No. 30, p. 234).

The question: HHAs have been asking "when will CMS finish sweeping up from the earlier issues?" acknowledged CMS' Wil Gehne in the Sept. 17 Open Door Forum for home care providers.

The answer: CMS plans to make the adjustments by the end of the year, Gehne related in the forum. More details will be in a forthcoming transmittal that is in the "final stages" of the clearance process, he pledged.

Some agencies expect to receive payments from the claims errors, namely the M0110 sequencing problems, while others expect to see takebacks from errors such as inaccurate LUPA add-ons.

Other issues addressed in the forum include:

• OASIS warning message 257. Lots of HHAs are getting this message and they shouldn't ignore it, warned CMS' Randy Throndset in the forum that drew 355 callers. The message indicates that the HIPPS code isn't accurate.

Translation: Often that message means that you are using outdated PPS Pricer software, Thrond-set explained. Make sure you or your software vendor is using the most up to date version of the pricer (see related story, p. 279).

The message is a warning only, so the claim still pays, which allows agencies to ignore the warning and still receive reimbursement. But HHAs "should look into the reason ... why their grouper software is producing an inaccurate HIPPS code and correct it," Throndset urged.

NRS wrinkle: One acceptable reason for the error message is the change in HIPPS codes due to nonroutine supply status, Throndset said in response to a caller. If an agency reports that it is furnishing NRS with an alphabetic fifth HIPPS code digit on the RAP and then changes it to a numeric one on the final claim because it didn't furnish NRS -- or vice versa -- the warning message will appear, he noted. That's OK.

NRS edits for HHAs hit Oct. 1, Gehne added. Those edits return claims to providers if they fail to bill for NRS on the claim but use a HIPPS code indicating NRS usage (see Eli's HCW, Vol. XVII, No. 34, p. 266).

Claims will pay if the HIPPS code fifth digits on the RAP and claim don't match because under PPS revisions that took effect in January, the claims system only checks that the first four HIPPS code digits match, Gehne explained to the caller.

• MAC transition. You may be saying goodbye to your regional home health intermediary sooner than you think. CMS is in the midst of the process of revamping the Medicare contractor system and the RHHI contracts will be up for change next year, a CMS rep said in the forum.

There will remain four home care regions for Medicare claims processing. But those workloads will be integrated into the assignments for the Part A and B Medicare Administrative Contractors.

The contracting process is "free and open," the CMS rep said, so any company could win the new RHHI contracts.

Change: Home care provider chains will be in for more billing headaches. Under the new system, provider locations will be assigned to a contractor geographically, so chain locations will have to submit to different contractors if they are in separate regions.

Maps of the jurisdictions are at http://www.cms.hhs.gov/OpenDoorForums/17_ODF_HHHDME.asp under "Related Links Inside CMS."

• Hurricane relief. HHAs adjacent to disaster areas don't get to take advantage of Medicare waivers, CMS' Pat Sevast confirmed in the forum.

HHAs and other providers that accept the crush of disaster area evacuees would benefit greatly from the relaxed OASIS standards, protested a National Association for Home Care & Hospice representative.

Clarification: HHAs can have their medical directors sign orders for evacuee patients only if the physicians are willing to accept complete responsibility for the care, just as a usual physician ordering home care would, Sevast explained.

• Social worker visits. Hospices should not include telephone calls from social workers in their visit tallies for billing purposes, CMS reiterated to a forum caller.

Social workers perform the same functions over the phone and many family members are not available for in-person visits, a California hospice caller said. And CMS manual instructions don't mention in-person requirements.

But CMS is collecting only in-person visit data now, CMS' Lori Anderson explained. The agency "may collect it in the future," she added.