Home Health & Hospice Week

Plus: U5210/U5220, RCD exclusions, and ongoing 31755 problems burden HHAs — and their cash flow.

Home health agencies trying to get a jump on telehealth billing procedures that will become mandatory in July have an annoyance to deal with.

Review: In its 2023 home health final rule issued last fall, the Centers for Medicare & Medicaid Services finalized a proposal for HHAs to use three new G codes to report telehealth services — G0320, G0321, and G0322 (see HHHW, Vol. XXXI, No. 39-40). HHAs were cleared to start “voluntary reporting of the new G-codes beginning with HH periods of care that start on or after January 1, 2023,” according to the transmittal implementing the change. Then HHAs must begin “mandatory reporting beginning with HH periods of care that start on or after July 1, 2023,” the transmittal indicated.

But early adopters of the new codes have run into problems.      

“From January 1 - February 6, 2023, CMS incorrectly returned claims with telehealth services if they didn’t include an in-person visit with the same revenue code (reason code 31869),” CMS reveals in a message to providers. “If we returned your claim, re-submit it to your Medicare Adminis­trative Contractor,” CMS instructs.

Resource: The 20-page CR is at www.cms.gov/files/document/r11502cp.pdf.

Watch Out For These New Claims Snafus

Meanwhile, other claims glitches have recently plagued home health claims too. They include:

• Reason codes U5210 and U5220. “Some home health [Notices of Admission] and claims are being incorrectly rejected for Reason Codes U5210 and U5220, no Medicare entitlement for the dates of service when the beneficiary only has Part B eligibility for the dates of services submitted,” HHH Medicare Administrative Contractors Palmetto GBA and CGS report on their Claims Payment/Processing Issues Logs (CPILs).

Part B-only eligibility shouldn’t be a problem for home health patients, because “Medicare’s entitlement to Medicare coverage for home health services only requires a beneficiary to have Part A or Part B, not both,” the MACs explain in their logs. “If a beneficiary is enrolled only in Part A and qualifies for the Medicare home health benefit, then all the home health services are financed under Part A. If a beneficiary is enrolled only in Part B and qualifies for the Medicare home health benefit, then all of the home health services are financed under Part B,” Palmetto and CGS elaborate.

The solution: For now, HHAs need to sit tight on these claims. “This issue has been identified and a fix is in development,” the MACs say. “Once an implementation date for the fix is scheduled, we will provide an update and provider direction,” they add.

• RCD exclusion errors. “Choice 1 (Pre-Claim Review) providers who were previously excluded from the home health Review Choice Demonstration (RCD) at the request of the Unified Program Integrity Contractor (UPIC) and have since been added back to the demonstration, have erroneously had their status changed to excluded again which impacts the PCR submission process through eservices,” Palmetto explains in its CPIL. “Due to this status change, claims submitted without a Unique Tracking Number (UTN) will generate an Additional Documentation Request (ADR) for these providers.”

The solution: “Providers are encouraged to use other submission options to submit their Pre-Claim Review requests until this issue is resolved,” Palmetto directs. “Palmetto GBA is diligently working to correct the status to allow future PCR submissions through eservices,” the MAC adds.

• Reason code 31755. HHAs are correcting most claims returned due to a reactivated edit requiring a match between the “Admission” date, “From” date, 0023 revenue code’s “Service” date and the first visit (earliest GXXXX code) date for initial episodes, and the 0023 revenue code date and the first visit date (earliest GXXXX code) for subsequent periods (see HHHW by AAPC, Vol. XXXII, No. 4).

But they continue to be unable to do so for a subset of claims denied with RC 31755. “Medicare still is receiving claims for January 2022 that used an artificial admission date, causing the claims to RTP with RC 31755. These claims are being researched to determine what action is required,” MAC National Government Services says on its website.

For now, agencies must hold onto those affected claims, the MACs indicate.