Advanced Search

Home Health & Hospice Week

Regulations:

M0175 Takebacks Finally To Hit In November

Published on Mon Aug 01, 2005

 CMS forum also reveals details on expedited review, outcomes and hospital referrals.

In just a few short months, you may have to pay the piper if you've made mistakes recording patients' prior inpatient stays.
 
For the first three years under the prospective payment system, the claims processing system didn't catch the mistake if a home health agency failed to mark a hospital, skilled nursing facility or rehab stay in OASIS item M0175.
 
Why it matters: That's a big deal because failing to mark a hospital stay along with a SNF or rehab stay nets the HHA an extra $200 for a non-therapy patient's episode and $600 for a therapy patient's episode. Conversely, if an HHA fails to mark the SNF or rehab stay, it shorts itself of $200 or $600 per episode.
 
A series of HHS Office of Inspector General reports projects millions in M0175 overpayments due to un-marked hospital stays, and the Centers for Medicare & Medicaid Services said last summer that it would start M0175 recoupments from the first years of PPS this year (see Eli's HCW, Vol. XIII, No. 28, p. 218).
 
After a series of delays, recoupment time is now almost nigh, CMS said in the Aug. 25 Open Door Forum for home care providers. CMS has sent the overpayment files to the regional home health intermediaries, CMS official Wil Gehne said in the forum. And the files include underpayments too - a hard-fought concession won by the industry.
 
The RHHIs first will test the M0175 files, Gehne explained. "We want to make sure that these files are right before we take any actions with them." Then starting Oct. 24, the intermediaries will post the over- and underpayments on the system so that agencies have five weeks to review them for accuracy.
 
How to correct: When an agency finds an erroneous adjustment, it should tell its RHHI. The intermediary will then remove the adjustment before it is processed if it agrees with the error, Gehne said.
 
Happy holidays: After the review period, the RHHIs will begin making the M0175 adjustments - both recoupments and refunds - the week of Nov. 28, CMS expects. After the adjustments are processed, HHAs must pursue correction through the traditional claims appeal process.

CMS: Underpayments Offset Overpayments

"The impact of these adjustments on home health agency cash flow isn't expected to be significant," Gehne said in the forum. That's partly due to the over- and underpayments offsetting each other. "If people have findings to the contrary of that, then we certainly want to know about them," he said.
 
The files will include adjustments based on patient stays in long-term care hospitals, Gehne confirmed. That's despite industry protests that LTCHs function more like SNFs than acute hospitals.
 
Other topics addressed in the forum include:

 

  • Expedited review notices. CMS has posted a Spanish version of the expedited review notice and 40 more questions-and-answers on the requirement. CMS also has clarified some of the 40 existing Q&As, CMS' Tom Kessler said in the forum. Links to the Spanish form and Q&As are at www.cms.hhs.gov/medicare/bni.

     

  • Home Health Compare. The new version of Home Health Compare will go live Sept. 1, a CMS staffer noted. The revised public outcomes comparison will add three new measures on dyspnea, urinary incontinence and discharge to the community and cut four measures on upper body dressing, bathing, toileting and confusion frequency (see Eli's HCW, Vol. XIV, No. 7, p. 50).

     

  • Hospital referrals. The proposed regulation requiring hospitals to disclose their referral statistics is on hold while the agency "explores options" about the measure. The cost of developing the referral data and putting it on a public Web site has proven higher than expected, Gehne said.

    Hospitals also argue that just because a patient is discharged from a hospital and admitted to an HHA does not mean the hospital referred the patient to that HHA.

    • Other Articles in this issue of

    Home Health & Hospice Week

    View All