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Home Health & Hospice Week

Regulations:

TAKE ANOTHER LOOK AT YOUR WAGE INDEX FOR NEXT YEAR

Published on Fri Jul 30, 2004

Physician stamps, consolidated billing details revealed at Open Door Forum.

If you thought your wage index for 2005 looked funny, chances are you were right.

The Centers forMedicare & Medicaid Services goofed up and put the wrong wage index in its June 2 Federal Register notice of the 2005 update to the home health prospective payment system, CMS admitted in the June 23 Open Door Forum for home health.

CMS included the 2004 instead of the 2005 wage index in the notice, a staffer explained in the forum that drew more than 260 attendees. The wage index is used to calculate the labor portion of the PPS payment rate.

Because swapping out the wage index tables is viewed as merely a technical correction, CMS doesn't plan on granting any more time for comments on the notice. Comments are due Aug. 2 (see Eli's HCW, Vol. XIII, No. 21). An advance notice of the corrected wage index tables is at www.cms.hhs.gov/providers/hha/ in the "Highlights" box.

Other home health agency topics discussed in the forum include:

  • Physician stamps. Just because CMS has given the OK for physician rubber signature stamps doesn't mean it's kosher in your state. Texas is one state that is not accepting doc signature stamps, Heather Vasek of the Texas Association forHome Care reported in the forum.

    If states have more restrictive rules on rubber stamps, they don't have to accept them, CMS made clear in its survey and certification letter (see Eli's HCW, Vol. XIII, No. 26) and at the forum. But confused HHAs in Texas and other states with similar rules may adopt use of stamped signatures without realizing that, Vasek worried.

    Bob Wardwell of the Visiting Nurse Associations of America also protested the requirement for agencies to obtain statements from physicians attesting only they use the stamps. Such a rule defeats the purpose of making documentation easier for the HHA and physician by having the physician's staff use the stamp.

  • Consolidated billing. If a physician sends supplies home with a patient, he is on the hook for payment for those supplies, CMS confirmed in the forum.

    Supplies furnished incident-to a physician's services during the course of an office visit can be billed to the physician's Part B carrier and paid, staffers explained. But physicians' claims to durable medical equipment regional carriers for supplies sent home with a patient will be denied under home health bundling rules.

    As with any other provider, HHAs don't have to pay for the supplies unless they have a contract and orders for the items from the physician. If those aren't in place, the physician will be left holding the bag for the supplies' cost, noted Mary St. Pierre with the National Association forHome Care & Hospice.

  • Patient notices. CMS may have to make some substantive changes to the new Notice of Exclusions from Medicare Benefits (NEMB). The proposed form tells beneficiaries they can continue paying for care if Medicare denies it, but the HHA conditions of participation don't allow agencies to continue care without a physician's orders, Wardwell noted in the forum.

    And a caller pointed out that the new NEMB will be different than the Notice of Medicare Non-Coverage (NOMNC) used for Medicare Advantage patients. The NEMB will be a fee-for-service form while the NOMNC, which goes into effect Aug. 1, will apply to Medicare managed care patients only.

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