Home Health & Hospice Week

But you still need to report new Q codes starting July 1.

Home health agencies have one less billing duty to deal with this summer.

Then: Back in February, the Centers for Medicare & Medicaid Services published a transmittal that would have required home health agencies to start reporting a new modifier on claims beginning July 1. The modifier would identify non-certifying physicians who order home care services (see Eli’s HCW, Vol. XXII, No. 6).

CMS had been looking to capture data on how often additional orders are added to the plan of care by another doctor, says consulting firm Frost, Ruttenberg & Rothblatt on its website. The intention appeared to be "that they will require reporting of changes/additions to the plan of care by a physician other than the attending physician (described in the claims processing manual as the physician that has established the plan of care)." But there was confusion over who would fall under this definition.

Now: CMS is dropping the requirement, it says in an April 2 update to CR 8136.

The change is good news, cheers the National Association for Home Care & Hospice. The requirement "would have created a new burden for home health agencies, clinicians, and software vendors," the trade group says.

Site Of Service Codes Deadline Remains July 1

The CR keeps in place the requirement for HHAs to report site of service Q codes for episodes beginning on or after July 1, however.

Hospices currently use Q5001 through Q5009 to report on the claim where they furnish services, CMS notes in the updated CR. They’ve reported such codes since 2007.

Starting in July, HHAs must use Q5001 (Hospice or home health care provided in patient’s home/residence); Q5002 (…in assisted living facility); or Q5009 (…in place not otherwise specified) to indicate where they furnish services.

Tip: "Q Codes will be required to identify where the services were provided, not necessarily the place of residence," points out software and billing company Select Data on its website.

Watch out: The method for reporting these codes is likely to confuse many HHAs, predicts billing expert M. Aaron Little with BKD in Springfield, Mo.

"The location where services were provided should be reported along with the first billable visit in a HH PPS episode," CMS instructs in revised MLN Matters article MM8136. "In addition to reporting a service line according to current instructions, HHAs must report an additional line item with the same revenue code and date of service, reporting one of the three Q codes (Q5001, Q5002, and Q5009), one unit, and a nominal charge (e.g., a penny)."

Plus: "If the location where services were provided changes during the episode, the new location should be reported with an additional line corresponding to the first visit provided in the new location," CMS continues in the MLN Matters article.

For episodes beginning on or after July 1, claims will be returned if they lack a Q code line and if that line doesn’t correspond to the earliest home health visit, CMS cautions.

HHAs will also see claims returned when more than one line on an HH PPS claim reports Q5001, Q5002, or Q5009 and the same HCPCS code is reported on consecutive dates, CMS adds.

Remember: "Claim lines reporting Q5001, Q5002, or Q5009 are not included in the visit counts passed to the HH Pricer, nor are they counted in medical policy parameters that count number of visits," CMS explains.

Observers think CMS is likely to use these new codes to target duplicate services for patients in assisted living facilities, Select Data notes.

Get Your Billers The Right Info

NAHC saw a big problem with the original instructions. A place of service code that did not define "assisted living facility" would result in unreliable data, the trade group told CMS. "There are various facility titles and definitions across the country."

CMS has now defined ALFs in Q5002 "as defined by the State in which the beneficiary is located," according to the transmittal.

Beware: "These codes … can interrupt productivity if your agency does not have a process in place by July 1 for documenting these services and supplying your [billers] with the necessary information," Select Data warns.

Note: The revised transmittal is at www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/Downloads/R2680CP.pdf and the re-vised MLN Matters article is at www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/MM8136.pdf.