Home Health & Hospice Week

Don’t forget: Valid HIPPS code, diagnoses not required.

It will take time and effort to make sure you can access your rightful reimbursement as home health Notices of Admission take effect. Consider advice from the experts to seal the deal.

“Just when you thought you understood all the payment rules and claims requirements — whoops! — they changed again,” says consulting firm Corridor on its website.

And unfortunately, home health agencies have to hit the ground running to make sure they don’t lose reimbursement based on late NOAs.

Industry experts offer this advice:

1. Make the five-day deadline every time. Every day you’re late will cost you money. “Remember that the penalty for late submission of NOA starts from the first day of the 60-day episode of care or five days after the initial visit, not the first day after the agency missed the deadline,” emphasizes Qavalo on its website. Submitting the NOA even a day late “represents a potential loss of 20 percent or more,” since the first five days are dinged at 1/30^th each, says the Philippines-based provider of home health billing services. “This will particularly affect you if non-billable visits reduce the full payment to a Low Utilization Payment Adjustment (LUPA),” Qavalo points out.

Be sure you know what that five-day deadline really means as well. “The ‘From’ date on the claim (the first date of the payment period) is Day 0,” Qavalo explains. “For a NOA to be considered timely, it needs to be accepted by the MAC by Day 6, or five (5) days after the ‘From’ date.”

Or even earlier: To make sure you avoid late NOAs, consulting firm SimiTree “recommends agencies follow best practices and try to submit within 24-48 hours,” it says in analysis on its website.

2. Always submit an NOA. You might be tempted to save a little work by not submitting NOAs to Medicare for Medicare Advantage or other-payor patients. Don’t, advises HealthRev Partners, which offers home health billing services. “Even if Medicare isn’t the patient’s primary insurance, we recommend that you still send a NOA,” the Ozark, Missouri-based firm says on its website.

“Our rule of thumb is to always submit the NOA so that it is on file with Medicare. In that case, if the payer is changed, we’ve already established care with Medicare and can release the final claim,” HealthRev advises.

3. Know what you don’t have to submit. Streamline your process by skipping the things that used to be required for no-pay RAPs, but are no longer required for NOAs — namely, a diagnosis and HIPPS code.

“When billing electronically, use a placeholder HIPPS of ‘1AA11,’” recommends HHH Medicare Administrative Contractor Palmetto GBA in a new Frequently Asked Questions document on NOAs. The claims system won’t match the HIPPS code field on the NOA and final claim, Palmetto explains in another FAQ.

As for diagnoses, “the principal diagnosis code reported on the NOA does not need to match the principal diagnosis reported on the initial period of care claim,” Palmetto adds. “Also, secondary diagnoses are not required on an NOA. Please remember, the principal diagnosis reported on a period of care claim is what drives the clinical grouping under PDGM for the HIPPS,” the MAC stresses.

In light of these changes, “remember that it isn’t necessary to wait on the OASIS to be completed” before filing an NOA, offers SimiTree’s Jess Stover.

4. Don’t submit too soon, either. While you definitely don’t want to submit late, you also don’t want to submit early. “NOAs with future dates will not be accepted,” says HHH MAC CGS in a Jan. 4 post to its website.

5. Check on MAC acceptance. Submitting the NOA isn’t enough. You must check that the MAC also accepts it within the five-day timeframe, points out Melinda Gaboury with Healthcare Provider Solutions in Nashville, Tenn.

HHAs should “have in place a follow-up procedure to make certain the MAC has accepted the NOA after submission, so that appropriate action can be taken quickly when needed,” Stover recommends in online analysis.

6. Don’t let the details trip up your timeliness. Make sure you know the ins and outs of NOAs so problems don’t take you by surprise.

For example, the National Provider Identifier number entered in the Attending Physician field “must be the individual physician’s NPI — not a group NPI,” says a joint HHH MAC job aid from Palmetto, National Government Services, and CGS. “Please visit the NPI registry to verify this information, https://npiregistry.cms.hhs.gov/,” Palmetto directs in its FAQs.

Another example is entering the patient name. Don’t give up if the whole name doesn’t fit. “Enter the number of characters allowed in the patient’s last name (as it appears on their Medicare card) in the Last Name field,” CGS directs in a Jan. 5 message to providers. “Enter the number of characters allowed in the patient’s first name (as it appears on their Medicare card) in the First Name field.”

7. File for exemptions — but don’t expect them. The Centers for Medicare & Medicaid Services indicates it will grant exceptions to the five-day deadline in only four fairly narrow situations: “1. Fires, floods, earthquakes, or other unusual events that inflict extensive damage to the HHA’s ability to operate, 2. An event that produces a data filing problem due to a CMS or MAC systems issue that is beyond your control, 3. You are a newly Medicare-certified HHA that is notified of that certification after the Medicare certification date, or which is awaiting its user ID from its MAC, 4. Other circumstances that we or your MAC determines to be beyond your control.”

Palmetto says it won’t grant exceptions when:

• The HHA can correct the NOA without waiting for Medicare systems actions
• The HHA submits a partial/incomplete NOA to fulfill the timely-filing requirement (CMS has clarified that a partial NOA would be a submission that is missing required fields or has invalid values in those fields)
• The HHA has multiple provider identifiers and submits the identifier of a location that didn’t actually provide the service.

Note: A free one-hour NOA webinar from Gaboury is at https://healthcareprovidersolutions.com/free-webinar-the-notice-of-admission-are-you-prepared-122021-2/.