Home Health & Hospice Week

Are you doing all you can to coordinate your patients' supplies in the home under consolidated billing? If not, the feds aren't happy with you.

The Centers for Medicare & Medicaid Services is giving home health agencies the full court press about supplies coordination. Soon CMS will issue new manual instructions and a provider education article on the topic, CMS's RandyThrondset said in the April 14 Open Door Forum for home care providers.

The problem: Under the prospective payment system, a number of supplies are bundled into the home health PPS payment. When a DMEPOS supplier furnishes those items, it can not receive payment from Medicare for them because the supplies payment is included in the HHA consolidated billing payment. The supplier can seek payment from the HHA, but the agency is under no obligation to pay the supplier if they didn't have a prior arrangement. Suppliers have been complaining to CMS about denials due to bundling, Throndset related.

The solution: Under law, CMS cannot pay suppliers separately for supplies whose codes are included on the PPS consolidated billing list, Throndset noted. That means HHAs and suppliers are going to have to get better at coordinating supplies provision during a home health episode. "There's not a silver bullet answer here," noted CMS's Lori Anderson in the call. "Everybody needs to take a little bit of responsibility."

For HHAs, that means checking on where a patient is getting her supplies and coordinating with the ordering physician about what supplies are used in the home. "It absolutely is very, very important for the home health agency to be coordinating that care and be responsible for that," Throndset said of supplies.

If patients have lots of supplies sitting around the house, ask where they got them and follow up, CMS urged.

And agencies must be sure to submit their request for anticipated payment (RAP) as soon as possible so that DMEPOS suppliers can check in the system to see whether a patient has an open home health episode, Throndset said. CMS's upcoming manual revisions and provider education article will stress the importance of timely RAP submissions, he promised in the forum.

On the other hand: Suppliers have their part to do too. Besides checking the Medicare system for an open HHA episode, they need to ask the patients and their caregivers periodically if they are in a home health episode, Throndset directed. The Medicare claims manual says the same thing, he reminded suppliers.

Both HHA and DMEPOS callers told CMS how difficult it is to coordinate supplies care due to factors ranging from patient and caregiver language limitations to supplies timing to patients intentionally withholding information to secure supplies. Another caller related how some HHAs don't think they are responsible for supplies payment if they aren't addressing the condition the supplies are for in the plan of care.

HHAs are responsible for all supplies in the consolidated billing list during an episode, whether they use the supplies or address the condition they're for or not. The bundling code list is at www.cms.gov/HomeHealthPPS/03_coding_billing.asp -- scroll down to the "Downloads" section and click on the "Home Health Consolidated Billing Master Code List" to download the file, or e-mail editor Rebecca Johnson at rebeccaj@eliresearch.com with "Bundling List" in the subject line to receive a free copy of the file.

The bottom line: "It's definitely a shared responsibility," Throndset emphasized of supplies coordination. "It's going to take all those things happening together to fill those gaps."