Home Health & Hospice Week

Reimbursement:

Use These 6 Tips To Keep On Top Of PPS Adjustments.

Pay the most attention to the therapy corrections, experts advise.

Tracking your claims payments under 2008 PPS refinements may be about to pay off.

The Centers for Medicare & Medicaid Services has directed regional home health intermediaries to correct payment errors made when the prospective payment system refinements took place this year (see Eli's HCW, Vol. XVII, No. 39, p. 307).

CMS lists nine PPS errors that the intermediaries will correct in the coming adjustments in Oct. 31 CR 6250 (Transmittal No. 397) (see story, p. 315, for error details).

That highlights just how rocky the transition to the PPS refinements system has been, points out Abilene, Texas-based consultant Bobby Dusek. The sheer number of errors and frequent PPS grouper software updates are confusing to providers.

Making the adjustments all at once will be helpful to even out over- and underpayments, Dusek believes. But saving them all for a year after the refinements went into place means many agencies will have lost track of the original errors.

CMS is "giving them a long time to correct from over a year back," Dusek notes of the Feb. 2 deadline in the transmittal.

Get the upper hand with the myriad of adjustments with these tips from the experts:

1. Evaluate the impact. If you've been tracking your claims payment so far in 2008, you're about to receive the reward for it. You'll be able to estimate the overall net financial impact of these errors, points out consultant M. Aaron Little with BKD in Springfield, Mo..

In general: If you had a lot of later episodes designated as early ones due to error #6 in the transmittal, you'll likely be looking at some extra money. If you had a lot of low utilization payment adjustment (LUPA) episodes near the five-visit limit,  you're more apt to have to repay money due to error #5 in the transmittal.

2. Prepare your cash flow. Be sure you are ready in this tight credit environment if your evaluation shows that you'll be receiving an overpayment request. "Make financial preparations so that cash flow isn't hurt when the adjustments are made," Little suggests.

3. Research the 20-therapy-visit error. It's worth it to spend some time working on error #2 from the transmittal, Little and Dusek agree. This is one of two errors that agencies must bring to RHHIs' attention manually for correction, and an  adjustment will net you more than $1,000.

HHAs that have tracked payment errors can simply consult their list of claims that were paid incorrectly and contact their intermediary for in-structions on how to get them fixed, Little advises.

Providers that haven't tracked payments will have a tougher time preparing for the adjustments, Little says. They'll have to go back and look at claims processed from Jan. 1 to Feb. 4 to look for the error. Error #2 occurred only when claims were projected to have less than 20 therapy visits but actually had exactly 20 therapy visits.

Tip: Dusek advises widening your search window to all of February, just to catch stragglers.

The small window of time to search should help agencies keep this task manageable. "Enough money is tied up in this error to definitely make it worth bringing it to the intermediaries' attention," Dusek says.

4. Scrutinize LUPAs. Error # 5 is the next-biggest reimbursement-affecting adjustment, Dusek believes. You could get slapped with a $265 overpayment for a four-visit LUPA processed from Feb. 4 to March 10, since the nearly $88 add-on would  have been incorrectly added for each visit in the episode.

If you have a lot of LUPA episodes that approach the limit, "it might be worthwhile to check those" to make sure you really must refund the overpayment, Dusek suggests.

5. Know what to ignore. If you haven't been tracking and reconciling PPS adjustments, it's probably not worth your time to pursue the other item that requires providers to bring incorrectly paid claims to intermediaries.

Error #7 shortchanged agencies just 11 cents for speech language pathology visits used in LUPA and outlier calculations, CMS notes. That's probably not worth your time.

6. Track and reconcile claims adjustments going forward. The complexity of the PPS refinements has thrown many agencies for a loop this year, Dusek tells Eli. "People don't really know what they're supposed to get," he laments.

If you've been tracking your claims, keep up the good work, Little praises.

If not, don't let the system's intricacies intimidate you. Thoroughly evaluate any episodes that pay differently than expected, Little urges. You should determine whether discrepancies are due to payment error or routine adjustments like LUPAs, partial episode payments (PEPs), outliers, therapy changes, or episode timing recoding.

"The only way to determine this with certainty is by reconciling the key claim elements," Little stresses. Those elements are billed versus paid HIPPS codes, the billed OASIS matching string, the actual Common Working File record of episode  timing, and actual therapy visits billed and provided.

(For more information on how to reconcile those key claim elements, sign up for Little's Eli-sponsored audioconference on Nov. 20, "2009 PPS Refinements: Troubleshooting Tips for Your Home Health Agency's Billing Processes," at  www.audioeducator.com/industry_conference.php?id=1300 or call 1-866-458-2965.)

Timeline: CMS has set a Feb. 2 deadline for completing the adjustments, but RHHIs are considering processing the adjustments earlier, a CMS source says.

The agency's directive to balance out all the over- and underpayments by processing the claims at once will actually slow down the process, Dusek notes. RHHIs won't be able to process one type of error while still researching another.

Note: The transmittal describing in detail the nine errors slated for correction is at http://www.cms.hhs.gov/transmittals/downloads/R397OTN.pdf.