PPS, OBQI also addressed in forum. • PPS billing. CMS has yet to set a date for resolving the episode sequencing problem discovered more than a month ago (see Eli's HCW, Vol. XVII, No. 10). Under that problem, the Common Working File isn't recognizing 2007 episodes when determining episode sequence for M0110. As a result, the system is coding all episodes as early even when they really are later episodes. • OBQI risk adjustment. CMS and its outcome-based quality improvement standards contractor will risk adjust all 41 OBQI measures, reported CMS' Debbie Turkay. Currently 30 of the measures are risk adjusted while 11 are not. • Hospice billing. Hospices have run into another road block to successfully including the new visit data CMS wants on claims. Many hospice claims have been returned to provider in error due to a problem with reporting the visit data, Gehne said. • Post-acute demo. The demonstration project for post-acute care reform has kicked off in Boston, a CMS staffer noted. The demo will take place in nine other cities by the end of the year and CMS is still recruiting HHA participants in those areas. Next up are Chicago, Rapid City, SD and Rochester, NY.
You might have to transition to a new Medicare contractor as early as next year, thanks to a revamp of the contracting reform strategy.
Medicare's switch to Medicare Administrative Contractors from intermediaries and carriers has been going on a while. Durable medical equipment regional carriers (DMERCs) switched to DME MACs last summer.
But home health agencies and hospices thought they were fairly insulated from the MAC transition because the Centers for Medicare & Medicaid Services originally planned to keep the four regional home health intermediary regions about the same and to bid the RHHI-to-home health MAC business separately from the Part A and Part B MACs.
But CMS has changed its mind about that. Now the agency will integrate the home health and hospice workload into four of the remaining seven Part A/Part B MAC contracts awarded this year, said a CMS staffer at the April 2 Open Door Forum for home care providers. "There was a shift in the procurement strategy," he informed attendees.
Bad news: And unfortunately for chains, CMS will require home health agencies and hospices to submit their claims to their MAC based on geography. Chain locations will no longer be allowed to send claims all to one contractor, the staffer confirmed.
CMS has a chain option with MACs, but it's only for institutional providers, he explained.
The switch could prove very disruptive for HHAs and hospices, fears Bob Wardwell with the Visiting Nurse Associations of America. Providers could wind up with a different intermediary/MAC, and even a contractor with no home health or hospice experience.
The new MAC regions vary from the current ones, Wardwell tells Eli. That means lots of providers will see changes even if the current RHHIs win the bids. "While the systems are more standardized than they were 10 years ago, there are still unique front-end and rear-end systems at each RHHI," he says. "Not to mention a whole new set of staff relationships to develop."
Timeline: CMS will award contracts for the home health work by the end of the year and would expect all claims to transition to the new contractors by the end of 2009, the CMS official said.
Other issues raised in the forum include:
"CMS is working with our contractors to get this problem corrected, but I don't have a date for the correction to the problem at this time," CMS' Wil Gehne told the forum.
Money back: CMS also has yet to set a date for running adjustments based on the PPS billing errors so far. The agency wants to wait until all the errors are resolved, then will run the adjustments correcting those errors all at once.
Hopefully agencies will see more positive than negative adjustments and thus won't see any cash flow disruption due to the corrections, Gehne said.
The adjustments will run automatically, he added. "HHAs won't have to take any special action."
Pricer instructions: HHAs also may be wondering about the new fields in the PC Pricer CMS issued recently. The pricer has three new fields, but the instructions for those new spots aren't out yet due to regulatory holdups, Gehne explained.
The recoding indicator field should nearly always contain a zero, Gehne instructed. The episode time field should say "1" for early or "2" for later episode. And the severity points field should contain the last eight digits of the treatment authorization code on the claim.
The new risk adjustment will begin in June. Contractor reps will be on the May 14 Open Door Forum call to explain the process, Turkay said.
Contractors soon will install the fix that went out April 10, Gehne reported. Meanwhile, hospices can omit visit data from claims to secure payment.
Value code G8 on hospice claims had also been rejecting at Cahaba GBA, the intermediary reports in a message to providers.
However, the G8 problem has been resolved, it says.