Home Health & Hospice Week

Surprise: HHAs must use them too.

If you thought hospice payment reform only affects hospices, think again.

In order to facilitate Service-Intensity Addon payments in the last seven days of a patient’s life, the Centers for Medicare & Medicaid Services has issued two new nursing G codes to replace the current single G-code of G0154 for “Direct skilled nursing services of a licensed nurse (LPN or RN) in the home health or hospice setting.”

The new codes are:

• G0299 — “direct skilled nursing services of a registered nurse (RN) in the home health or hospice setting;” and
• G0300 — “direct skilled nursing of a licensed practical nurse (LPN) in the home health or hospice setting,” the Centers for Medicare & Medicaid Services says in Oct. 16 Change Request 9360.

Rationale: Under hospice payment reform, Medicare will furnish SIA payments only for RN visits, not for LPNs, CMS reminds providers in the accompanying MLN Matters article. Thus, the current single nursing G-code had to be split.

The new codes will take effect, and the old one will retire, for hospice claims dated Jan. 1 or later.

Hospices have a compelling incentive to comply with the requirement, since their SIA payments depend on it, notes Lynn Olson of billing company Astrid Medical Services in Corpus Christi, Texas.

Beware Nov. 1 Deadline For HHAs

In what may be a surprise to many HHAs, “since G0154 is used in both the home health and hospice settings, home health agencies and hospices will be required to use” the new codes, CMS instructs.

Heads up: For home health agencies, the CR says the new codes will apply for episodes ending Jan. 1 and later. That means HHAs would have to bill “all episodes beginning in November and December — which have the opportunity to end on or after January 1 … using the new codes,” warns billing expert M. Aaron Little with BKD in Springfield, Mo.

Medicare Administrative Contractors need to give agencies specific directions on these “overlap” claims and how to handle the billing, Olson says. For example, agencies will want to know if they should use the G0154 code through Dec. 31 and then change to G0299 on Jan. 1 when the claim spans Jan. 1, Olson offers.

Agencies hope with industry input, “CMS can adjust its expectations related to the home health implementation of the new codes,” Little says. “Otherwise, it will be difficult for home health agencies to comply.”

You can expect policy-makers at CMS, the Medicare Payment Advisory Commission, and elsewhere to analyze the data provided by the new codes when making reimbursement decisions such as setting new rates, etc., observers warn.

Watch for: The new codes “may be applicable to Medicaid and other payer claims where reporting of nursing visits is required,” cautions the National Association for Home Care & Hospice.

Prepare Your Systems Now

Head start: “Some organizations I know have already been separately tracking RN versus LPN visits,” Little relates. “But that tracking has not been differentiated on the claims, so even those organizations will now need to ensure that they have their software systems correctly coded and mapped with the new codes.”

Agencies that have not been separately recording RN and LPN visits will need to start from scratch. “They will need to ensure they have systems in place” to track the visits, Little advises. For smooth implementation, stay tuned for further guidance from CMS and its MACs, Olson recommends.

Note: The CR is at www.cms.gov/RegulationsandGuidance/Guidance/Transmittals/Downloads/R3378CP.pdf and the MLN Matters article is at www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/MM9369.pdf.