Home Health & Hospice Week

If you fail to respond quickly, your bottom line could suffer.

As soon as the busy holiday season is over, you'll receive an unwelcome gift--M0175 adjustments. How you respond could determine whether you hold onto money that's rightfully yours.

Intermediaries will issue demand letters for the OASIS item on patients' prior inpatient stays in January, the Centers for Medicare & Medicaid Services says  (see Eli's HCW, Vol. XV, No. 38). The overpayments for all agencies in fiscal year 2001 amount to about $30 million while underpayments are about $15 million, the National Association for Home Care & Hospice reports.

Experts recommend taking these steps when the M0175 demand letters hit your mailbox:

1. Review the letters. Consultant M. Aaron Little with BKD in Springfield, MO expects the letters usually to be right. But "we will be advising our clients to confirm that the amount Medicare identifies as overpayments are indeed correct," Little reports.

Do this: Examine medical record documentation and review relevant common working file (CWF) data to double-check the adjustments, Little advises.

Potential trap: For example, the CWF may be wrong if a discharging skilled nursing facility didn't successfully bill its claim, he explains. "Because the CWF is only updated as claims are billed ... the OASIS is correct but the CWF is incorrect." This example could result in Medicare incorrectly identifying an overpayment of $200 to $500, Little warns.

2. Respond quickly. If you want to hold onto the cash that's rightfully yours, you'll have to be lightning fast in responding to the M0175 demand letters when they go out Jan. 18, 2007. Providers must have an appeal lodged with the intermediary within 16 days of the intermediary sending out the letter. "That's incredibly quick," notes William Dombi with NAHC's Center for Health Care Law.

"It will be critical that agencies closely review their letters immediately upon receipt to verify whether the overpayments are indeed correct," Little urges.

3. Polish your M0175 skills. The Centers for Medicare & Medicaid Services is paying back agencies for M0175 mistakes in their favor only through fiscal year 2003 (see Eli's HCW, Vol. XIII, No. 28). But it will continue making overpayment demands for the following years.

That means your M0175 accuracy must be as high as possible to avoid losing money when post-payment audit time rolls around for FY 2004 and later.