Home Health & Hospice Week

Reimbursement:

New Medicare Accounting System to Delay RAP Payments

'HIGLAS' system in place at one RHHI, on deck for the rest.

Get ready to take on more billing confusion, thanks to a new Medicare accounting system known as HIGLAS.

Regional home health intermediary Palmetto GBA implemented the Healthcare Integrated General Ledger Accounting System on May 4, the Department of Health and Human Services says in a May 24 release about the change. HIGLAS is part of a wider accounting system change for all the departments under HHS.

"HIGLAS centralizes one duplicative processing for collecting and reporting financial data to allow for the better detection and resolution of errors in a timelier manner," HHS says. "We have taken aggressive steps to ensure that we are paying Medicare claims appropriately," Centers for Medicare & Medicaid Services Administrator Mark McClellan says in the release.

HIGLAS doesn't replace the Fiscal Intermedi-ary Shared System (FISS) for claims processing, Palmetto stresses in an April 22 letter to providers. Rather, "this transition is only for the financial accounting system," the RHHI emphasizes.

The new system is pushing back RAP payments, saddling some unlucky providers with debts that aren't theirs and generally causing confusion. HIGLAS also is instituting minor procedural changes (see related story, later in this issue). The other three RHHIs are scheduled to implement HIGLAS within four years, a CMS spokesperson says.

But the RHHIs don't know yet exactly when that implementation will occur. "We have received no dates on HIGLAS," a Cahaba GBA official tells Eli.

You'll Have to Wait Extra Day for RAPs

The most widespread effect of the change will be a delay to request for anticipated payment (RAP) reimbursement. Palmetto currently takes seven days to process RAPs, and under HIGLAS it will add a day to that schedule, the intermediary explains in a May 23 posting to its Web site.

Old way: Status/location PB9996 used to mean "on the payment floor" and applied only to claims waiting to meet the payment time limit, Palmetto explains. Because RAPs aren't subject to a payment floor, they never used to be in PB9996.

New way: Now PB9996 indicates that the claim has "adjudicated" through FISS claims processing and is awaiting payment, and so the code can apply to both RAPs and final claims. "When a RAP is loaded to HIGLAS, it will be paid immediately because there are no payment floor requirements on RAPs," Palmetto instructs. But loading the RAP into HIGLAS adds the extra day, a Palmetto official explains to Eli.

Palmetto is already the slowest of the RHHIs at paying RAPs, says Abilene, TX-based reimbursement consultant Bobby Dusek. While other intermediaries take three to five days on average to pay RAPs, Pal-metto takes seven.

Palmetto used to pay RAPs faster when the prospective payment system began, points out Lynn Olson with billing company Astrid Medical Services in Corpus Christi, TX. But over time, Palmetto's RAP payments slipped from around four days on average to its current figure, agrees Rose Kimball with Dallas-based billing company Med-Care Administrative Services.

Payment delays have caused a bit of a "cash concern" for her clients, says Kimball, who used to work in the medical review department of former RHHI Well-mark, Cahaba's predecessor. "They didn't get the money when they thought they would get it."

A one-day delay to RAPs probably doesn't bother a lot of home health agencies, expects consultant Pat Laff with Laff Associates in Hilton Head Island, SC. "But for others it means a lot," especially considering that RAPs for initial episodes represent 60 percent of that episode's payment, Laff says.

When the other intermediaries adopt HIGLAS, they will probably adopt the one-day delay to their average RAP processing time as well, Dusek predicts.

Jump start: The delay may motivate agencies to submit their RAPs one day faster to receive their funds at the time to which they are accustomed, Laff forecasts. HHAs will have to sharpen their billing processes to make that happen, he notes.

HHAs Not Web Savvy

Kimball says she has been "bombarded" with calls from clients who are confused by the changes.

Since HIGLAS implementation, the contractual charge field that usually shows the difference between a provider's charges and Medicare payments has been showing drastically inflated figures, Kimball reports. Even though the contractual charges field has no direct reimbursement impact, this has providers confused, she says.

But Dixon says the contractual charge errors are actually unrelated to HIGLAS and instead can be traced to another claims system change that went into place in April.

Many providers have no idea about the HIGLAS details because they aren't Internet savvy, Kimball protests. Palmetto posts the bulk of its educational information on its Web site, which many providers never check.

Even faithful Web site checkers were caught unawares by the change, Dusek contends. Initial information indicated the change would be an internal accounting one with few effects noticeable by providers.

Guinea pigs: HHAs in 17 states and hospitals in South Carolina served by Palmetto are testing the HIGLAS implementation. "CMS will fully integrate Medicare's 52 different accounting systems into HIGLAS during the next four years," HHS says.

In preparation for the transition, Palmetto waived the payment floor for reimbursement that normally would have gone out May 4 through May 9. Instead, the intermediary paid those claims early and RAs were unavailable for that period. "We were dark for a week," Olson confirms.

As a result of the early payments, agencies may have seen lower payment amounts May 10 through May 17 when Palmetto reinstated the payment floor, the RHHI says in the letter.

HIGLAS is a part of the larger Unified Finan-cial Management System (UFMS) HHS is putting into place in all of its 11 agencies. 

Editor's Note: To see Palmetto's HIGLAS communications, go to
www.palmettogba.com - click on 'RHHI,' then click on 'HIGLAS' in the left-hand column.