Regulations:
PEP TAKEBACKS COST ONE HHA $400,000 - YOU COULD BE NEXT
Published on Mon May 19, 2003
If the Centers for Medicare & Medicaid Services doesn't steer home health agencies clear of dangerous V code waters, agencies could sink come October. The looming problem is with patient episodes that will span the Oct. 1 implementation date for use of V codes as primary diagnoses, noted Mary St. Pierre with the National Association for Home Care & Hospice in the May 7 Open Door Forum for home health and durable medical equipment. HHAs could find themselves with patients who have one primary diagnosis on a request for anticipated payment (RAP) before Oct. 1, then a V code as the primary diagnosis on the final claim after Oct. 1. CMS currently doesn't allow agencies to use V codes for aftercare on OASIS, but the Health Insurance Portability and Accountability Act requires HHAs to use them by October. CMS and the intermediaries must work out the problem in the Medicare claims processing system, notes consultant Pat Sevast with American Express Tax & Business Services in Timonium, MD. Even if Medicare claims processing systems allow for claims split on the V code implementation date, many providers' billing systems won't allow that split, St. Pierre maintained. But having a different diagnosis code on the RAP and final claim shouldn't hold up claims in the billing process, says M. Aaron Little, supervising consultant in BKD's Springfield, MO office. And "intermediaries actually do accept V/E codes on billing transactions, so I wouldn't foresee any significant billing processing problems," Little tells Eli. Indeed, the claims processing system doesn't edit as "far down" as diagnosis codes, agrees consultant Rose Kimball with Med-Care Administrative Services in Dallas. "Unless it changes the HIPPS code" with a significant change in condition (SCIC), any diagnosis coding changes before and after Oct. 1 "don't matter" billing-wise, she reassures agencies. Many HHAs haven't thought far enough ahead to anticipate V code billing problems, says coding consultant Prinny Rose Abraham with Minneapolis-based HIQM Consulting. Agencies have been focusing on furnishing V and E code training to their staff instead of billing issues. But it's likely providers will get confused when the October date rolls around, worries Little. A CMS official promised in the forum that the agency is aware of the problem and is working on a solution with other HIPAA staffers. Little hopes the regional home health intermediaries will "release some information in their monthly provider publications to proactively address any potential misunderstandings" surrounding the V code switch. PEPs: System Fixed Since April HHAs bracing themselves for the coming recoupments for partial episode payment (PEP) adjustments don't have much to look forward to. One member of the Home & Health Care Association of Massachusetts saw more than $400,000 withheld for 338 PEP'd [...]
