Home Health & Hospice Week

Coding, quality measures, and OASIS-C also addressed in Open Door Forum.

The recoupments for M0175 you saw last year might be your last.

The Centers for Medicare & Medicaid Services is suspending M0175 takebacks for 2001 to 2004 altogether and limiting them drastically for 2005 to 2007, CMS's Wil Gehne noted in the Dec. 9 Open Door Forum for home care providers.

Background: Prior to 2008, M0175 overpayments came about when HHAs failed to mark all the correct responses to the OASIS item on prior inpatient stays. If they marked that the patient had a rehab or skilled nursing facility discharge without also marking that the patient had a hospital discharge in the 14-day time period prior to admission, they were overpaid by about $200 for a non-therapy patient and $600 for a therapy patient. Underpay-ments occurred when the reverse happened -- agencies marked a hospital stay without a rehab or SNF stay when one occurred.

CMS already made M0175 recoupments for 2001, the first year of the prospective payment system, last year (see Eli's HCW, Vol. XVI, No. 2, p. 2). But "a significant volume of recoveries have been reversed on grounds that providers did not receive timely notice of the reopening of their claims," CMS notes in Dec. 5 CR 6275 (Transmittal No. 410).

"As a result of these findings, M0175 recoveries for services provided in 2004 and earlier are also now beyond the timely notice period," CMS adds. "Medicare contractors shall take no action on ... M0175 overpayment for services in calendar years 2001 through 2004, since reopening these claims is no longer timely," CMS instructs regional home health intermediaries in the transmittal.

After 2004, M0175 over- and underpayments were much less significant due to pre-payment edits CMS implemented. Thus, CMS directs the RHHIs to collect only on M0175 overpayments that the HHS Office of Inspector General specifically pointed out in relation to its series of reports on the item.

Up to the OIG: "There are currently findings for 2005 in a few HHA-specific OIG reports ... but no regional or national findings," a CMS staffer tells Eli. "So the number of HHAs affected will really be driven by whether or not OIG does further work in this area," the CMS source says.

That means at least for now, everyone else is off the hook for M0175. That's a positive for the larger contingent of agencies that were set to undergo takebacks, but a negative for the smaller group of HHAs expecting refunds.

Unlucky HHAs singled out for OIG review should find out by March that they are slated for M0175 corrections. "Medicare contractors shall provide notice to each HHA with claims identified in OIG reports regarding M0175 overpayments for services in calendar years 2005 through 2007 that their claims will be reopened in response to the reports," CMS says in the transmittal.

Other topics addressed in the forum include:

• Diagnosis coding guidance. When CMS revamped the OASIS User's Manual in October 2007, it skipped over Chapter 8, attachment D that addresses diagnosis coding. Now the agency plans to issue the attachment with new coding guidance and examples, CMS's Kathy Walch said in the forum.

HHAs can look for the posting any day on www.cms.hhs.gov/center/hha.asp in the "Spotlights" section, she advised.

• OASIS submission errors. A large volume of OASIS submission errors is still occurring, noted CMS's Randy Throndset in the forum. Agen-cies often receive OASIS warning message 257 when they aren't using up-to-date pricer software (see Eli's HCW, Vol. XVII, No. 35, p. 275).

"We continue to be concerned by the volume of these OASIS submission errors that we're seeing," Throndset said in the forum that drew 452 callers.

Although the payment system allows HHAs to bill despite the warning message, you shouldn't ignore it, Throndset urged. "Agencies should take action to resolve these errors." Providers are responsible for billing accurately, he reminded listeners.

• Quality measures. The National Quality Forum is considering new quality measures for HHAs in relation to the new OASIS-C proposal, CMS's Debbie Terkay said. After a November steering committee meeting, the NQF whittled down the number of possible new measures from 55 to 22.

Starting very soon, the NQF will take public comments on its draft report. Then it will likely make final recommendations by March, Terkay said.

CMS may continue to provide non-NQF-endorsed measures as part of the outcome-based quality improvement (OBQI) reports, Terkay added. But non-endorsed measures probably won't make it onto Home Health Compare.

• OASIS-C. Don't forget to submit your comments on the drastically revamped OASIS form proposal, Terkay urged. Comments are due Jan. 13, she reminded agencies. The new form contains additional process measures and reworks activity of daily living items, among many other changes (see Eli's HCW, Vol. XVII, No. 42, p. 330).