Home Health & Hospice Week

Plus: Be aware that 2021 date rules don’t apply to 2022 claims.

Reminder: A number of NOA processing glitches have occurred since the new form debuted Jan. 1. They range from the claims system stripping notices of ZIP codes (see HCW, Vol. XXXI, No. 1) to the system failing to recognize discharges and returning NOAs for overlapping periods of care (see HCW, Vol. XXXI, No. 7).

Medicare officials don’t seem too fussed about the problems. Implementation of HH NOAs “has been largely successful, given the scope of changes to Medicare systems it required,” a Centers for Medicare & Medicaid Services official said in the Feb. 24 Home Health Open Door Forum. CMS identified and speedily resolved several NOA processing issues in January, he pointed out.

However, the CMS staffer did acknowledge that the implementation “hasn’t been perfect though.”

For instance: At the time of the forum, edit U537S continued to incorrectly return NOAs. Under the error, Medicare systems were not correctly recognizing that patients were previously discharged or were interpreting home health stays that ended before 2022 as open admission periods, the CMS source explained to forum attendees.

The CMS official said a fix was expected to be installed on Mon. Feb. 28. But on that day, HHH Medicare Adminis­trative Contractor Palmetto GBA reported on its Claims Payment Issues Log webpage that “a system fix to correct this issue is still being created and an implementation date has not been established.” HHH MACs National Government Services and CGS also continue to report the issue as “Open” rather than “Resolved” on their CPIL webpages.

NGS says it “will remain in communication with CWF as [the fix] progresses and notify providers once the fix has been implemented,” according to its CPIL.

Required action: Once a fix is actually installed and successful, HHAs will have work to do. “NOAs that were returned in error can be resubmitted after that date,” the CMS official instructed in the forum. In other words, agencies will have to determine which NOAs fall under this error and resubmit them after the fix is final.

The problem: The U537S error is delaying NOA submissions past the five-day limit, reducing a billing period’s reimbursement by 1/30 each day the notice is late.

The solution: “When necessary, the corresponding claims will qualify for NOA timeliness exceptions,” the CMS official noted in the forum. “If an NOA is late due to this issue, request a late NOA exception and indicate the following in the Remarks field of the claim(s) ‘2022 NOA REASON CODE U537F ISSUE,’” Palmetto instructs in its log.

Now, HHAs just have to wait for notification of successful implementation of the fix.

“I want to thank all of our providers for your patience as we work through these growing pains with the new system,” the CMS official remarked in the forum.

Match These 2 Dates

Another reimbursement problem isn’t hitting HHAs’ bottom lines yet — but it will in a big way if agencies aren’t careful.

Background: During 2021, Medicare allowed future-dated Requests for Anticipated Payment, turning off edit 31755, the CMS staffer explained. That’s the edit that checks for the revenue code 0023 line item date and the first visit date on the claim to be the same. For NOAs, that edit is no longer suspended because those dates must once again match.

“I want to stress that this was a temporary process for 2021 only,” the CMS source says of turning off the 31755 edit. “For claims with 2022 dates of service, these claim dates should match.”

The problem: Edit 31755 remains off for this calendar year to allow for processing of 2021 claims that are still timely, the CMS official notes. So agencies may not realize they are not matching the revenue code 0023 line and visit dates as is now required.

The solution: HHAs should ensure they are billing claims with 2022 dates of service, as is spelled out in Medicare Claims Processing Manual instructions, the CMS staffer directed. “Failure to do so could cause problems with claim adjustments after the edit is reactivated in 2023,” he warned.

See the billing instructions in Chapter 10, Section 40.2 of the Medicare Claims Processing Manual at https://www.cms.gov/regulations-and-guidance/guidance/manuals/downloads/clm104c10.pdf.

HH, Hospice Pricers Switch To Web-Hosted Versions

CMS also announced in the forum new versions of both the grouper and pricer software for home health agencies.

HH PPS Grouper software version 03.2.22, which takes effect in April, is now available for download on the Grouper software webpage at https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/HomeHealthPPS/CaseMixGrouperSoftware.

 The new version adds three new ICD-10-CM diagnosis codes effective April 1, deletes one ICD-10-CM diagnosis code, and updates the clinical group assignment for one applicable diagnosis code, CMS details.

“Please be sure your billing staff and software vendors are aware of the new release,” the CMS official said in the forum.

And as CMS announced last year, the Home Health and Hospice PC Pricer software are moving to web-hosted versions, the CMS staffer noted. Being web-hosted means the pricer software will always be available and always have the most current updates automatically. Thus, agencies won’t have to repeatedly download updates, he said.

The new versions should roll out in the next couple of weeks at https://webpricer.cms.gov/.