Reimbursement:
M0175 Corrections Might Work For You As Well As Against You
Published on Thu Nov 13, 2003
CMS mulls adding positive corrections for prior SNF and rehab stays. Takebacks for incorrect M0175 answers will begin sooner than you think, but may also be less than expected. Regional home health intermediaries are waiting on the HHS Office of Inspector General reports on the issue before taking action, the Centers for Medicare & Medicaid Services said in a Nov. 5 Open Door Forum for home health. The OIG already has issued its report regarding M0175 overpayments for home health agencies served by RHHI Associated Hospital Service of Maine (see Eli's HCW, Vol. XII, No. 27, p. 210). AHS agencies will see an estimated $1.9 million recouped for fiscal year 2001 overpayments related to M0175, according to the report. Reports for the other three RHHIs - Palmetto GBA, Cahaba GBA and United Government Services - are expected to follow shortly, a CMS official tells Eli. Once the intermediaries receive the reports, they will work quickly to institute the takebacks. The first round of recoupments will encompass fiscal year 2001 spanning from Oct. 1, 2000 (when the prospective payment system began) to Sept. 30, 2001, the CMS source explains. Some HHAs are likely to receive notification about their M0175 recoupments by the end of this month, CMS says. HHAs served by AHS are likely to receive notification about their recoupments by the end of this month, the CMS official adds - not next April when the pre-payment edits begin (see Eli's HCW, Vol. XII, No. 39, p. 306). The takebacks are expected to occur all at once, unlike partial episode payment (PEP) recoupments that are processing gradually over a two-year period, with some unforeseen exceptions (see Eli's HCW, Vol. XII, No. 39, p. 309). M0175 recoupments are estimated to be only about one-tenth the amount of PEP recoupments, experts say. But that still will mean millions in takebacks just for FY 2001 alone. Agencies do appear to be getting a break on the time between FY 2001 and the present. RHHIs likely will begin the annual post-payment audits of M0175-related billing in mid 2004, the CMS source indicates. And those audits will go back only one year. Thus, claims from FY 2002 and most of FY 2003 likely will escape the takebacks.
Rehab & SNF Stays Also Hard to ID Another factor that could mitigate the recoupments is CMS' willingness to make M0175 corrections in providers' favor as well as against them. The agency's Oct. 24 instructions to intermediaries in Trans. No. 13 tells them only to make corrections when a hospital stay within 14 days of admission or resumption of care was missed in M0175, and thus a higher amount was billed, confirms a Palmetto official. But in the [...]
