Home Health & Hospice Week

Reimbursement:

Beware This CHOW Billing Change

You’ll need a good relationship with the seller or buyer under a new restriction.

If you’re buying or selling, a new Medicare change could make your life a hassle.

The Centers for Medicare & Medicaid Services is changing how its contractors handle

Changes in Ownership, particularly “when a provider’s CMS Certification Number (CCN) and provider agreement are transferred to another entity as a result of the latter’s purchase of the provider,” according to a new MLN Matters article.

“Once the CHOW processes and the MAC: 1) receives the tie-in notice from the CMS Regional Office; and 2) updates the Provider Enrollment Chain and Ownership System (PECOS), claims will only be paid under the new owner’s tax identification number, National Provider Identifier and CCN, or provider transaction number,” CMS stresses in the article. “MACs will no longer have the ability to update the crosswalk in order for the Seller to complete their billing.”

Bottom line: “The old and new owners are responsible for working together on payment arrangements for claims for services furnished during and before the CHOW is processed,” CMS stresses.

“The change can have a significant effect on provisions of purchase agreements,” warns The Health Group in Morgantown, W. Va. in its newsletter.

CMS adds more detail in the CR implementing the change, CR 9953. “Among other things, this means that the contractor will continue to adjust payments to the provider to account for prior overpayments and underpayments, even if they relate to services provided before the sale/transfer,” the transmittal says. “If the Buyer rejects assignment of the provider agreement, the Buyer must file an initial application to participate in the Medicare program. In this situation, Medicare will never pay the applicant for services the prospective provides before the date on which the provider qualifies for Medicare participation as an initial applicant.”

Note: See the MLN Matters article at www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/downloads/SE17012.pdf and the CR at www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/2017Downloads/R715PI.pdf.

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