Home Health & Hospice Week

Plus: PIPR reports for VBP, reactivated claims edit, and more addressed in latest forum.

Billing for telehealth and remote patient monitoring may be trickier than you think in 2023.

Why? CR 12805 issued last month carries two important billing instructions, noted a Centers for Medicare & Medicaid Services official in the Dec. 7 Home Health Open Door Forum.

Instruction No. 1: “The use of remote patient monitoring that spans a number of days shall be reported as a single line item reporting the beginning date of monitoring and the number of days of monitoring in the unit’s field,” the transmittal instructs.

In other words, G0322 is reported as a single line item than can span a number of days, the CMS staffer highlighted. For example, for a period of remote monitoring beginning on Jan. 1 and lasting 10 days, it should be reported as a single line item on the first date and 10 units.

Instruction No. 2: “HHAs shall submit services fur­nished via telecommunications technology in line item detail and each service must be reported as a separate line under the appropriate revenue code for each discipline furnishing the service,” the transmittal says.

G0320 and G0321 are reported as a separate line item, the CMS source confirmed in the forum.

More instructions are in the CR at www.cms.gov/files/document/r11502cp.pdf.

Other home health topics addressed in the forum include:

• VBP. HHAs that have been busy using their Value-Based Purchasing Pre-Implementation Performance Reports (PIPRs) will have an updated version soon.

CMS plans to issue additional, updated PIPRs in January and April, an agency official reminded forum attendees. The reports will use the most current data available, CMS assured.

PIPRs provide each HHA “with their specific performance data for the quality measure set used in the expanded model in comparison to the HHA’s nationally within their peer cohorts,” the CMS staffer explained. They also include preliminary achievement thresholds and benchmarks for each measure.

Resource: Links to a PIPR webinar and other materials are online at https://innovation.cms.gov/innovation-models/expanded-home-health-value-based-purchasing-model under the “Model Reports” section.

• Edit 31755. A claims edit requiring the line item date on revenue code 0023 and the first visit date on the claim to be the same will be back, as of Jan. 1.

CMS turned off that edit in 2021, when Medicare allowed future-dated Requests for Anticipated Payment. Then CMS kept it turned off in 2022, while timely 2021 claims still processed, a CMS official explained in the forum.

Medicare is turning the edit back on next month, and it will apply to 2022 claims as well as those going forward, the CMS source noted.

• Quality reduction reconsiderations. CMS is working its way through the rate reduction reconsideration requests it received by the Nov. 16 deadline. Medicare allowed reconsiderations when home health agencies were notified of rate reductions due to failing to submit required quality data (see HHHW, Vol. XXXI, No. 41).

CMS will notify HHAs of its decision on their requests by Jan. 1, a CMS staffer said in the forum. Those decisions will be placed in agencies’ CASPER folders.

While the reconsideration period is closed, agencies can still ask CMS about the process at HHAPUReconsiderations@cms.hhs.gov, the CMS official offered.

• CAHPS. You should be checking every month to make sure your CAHPS data vendor is submitting your CAHPS data as required, a CMS staffer recommended in the forum. “Make sure that your vendor is submitting your survey data on time,” she urged.

Plus: If your patient census looks like it will be below 60 this year, that’s not a signal to stop collecting and submitting CAHPS data, the CMS source warned. An agency’s CAHPS exemption status is based on the previous year’s number, not the current year’s, she cautioned. The CAHPS year runs from April through March, she noted.

• Care Compare. The next refresh for HHAs on the quality website will be in January, CMS reminded.