Home Health & Hospice Week

Old way: Currently home health agencies use six G codes to bill for visits by nurses, physical therapists, occupational therapists, speech therapists, medical social workers, and home health aides.

New way: Starting Jan. 1, you'll add eight codes to bill visits for nursing management and evaluation, nursing observation and assessment, nursing education and training, PT assistant, PT maintenance program, OT assistant, OT maintenance program,and speech therapy maintenance program (see chart,this page).

The Centers for Medicare & Medicaid Services finalized the new HCPCS codes in the prospective payment system final rule for 2011, published in the Nov. 17 Federal Register. CMS takes aim at two perceived problems with the codes -- overuse of therapy assistants and provision of medically unnecessary visits, experts say.

HHAs waiting for official instructions from CMS on how to use the code before the Jan. 1 deadline are about out of time. In the Dec. 1 Open Door Forum, CMS's Randy Throndset said he hoped the transmittal about the codes would be out "shortly," but at press time it wasn't yet released.

In the meantime: Agencies can find the new codes and their descriptions in the HCPCS code update online at www.cms.gov/hcpcsreleasecode sets/anhcpcs, Throndset pointed out.

Regardless of the instructions' release date, agencies must be up to speed and ready to bill the new codes in days. But that may not always be straightforward.

The codes for assistants are pretty clear, but the codes for different nursing and therapy services can cause confusion, suggested a caller in the forum.

The question: When there is more than one reason for a visit, which happens often, how should agencies determine the appropriate visit code, the caller asked CMS. Should providers use more than one code?

The answer: "Only one visit code can be billed for that nursing or therapy visit," a CMS official said. "We would expect that clinicians would use their clinical judgment in categorizing their visit in a manner similar to how they plan and prioritize an individual visit ... based on an individual patient's needs. Only one code can be billed and that should be the code that reflects the primary service being rendered in that home health visit, i.e., the primary reason for the visit."

Agencies can hope for more detailed guidance, including examples, in the coming transmittal, says billing consultant M. Aaron Little with BKD in Springfield, Mo.

No. 1: On the IT side, "the new codes will need to be set up within agency billing systems such that the codes correctly flow over to the claims," Little tells Eli. And don't forget, "billing personnel will need to monitor to make sure that the new codes do appear to be flowing over to the claims."

No. 2: On the clinical side, personnel will need training to help them understand how to correctly categorize each visit so that it is matched to the correct HCPCS code for billing. "Depending on how individual agencies have their billing systems set up, this change could be nominal or it could require significant adjustments to software setup," Little says.

It won't only be HHAs that have to deal with the new codes. Contract therapists also may need to tighten up their processes to accommodate the new billing requirements.

HHAs that use contract therapists "need to make sure that the therapists understand that they need to be very distinctly indicating visits performed by a therapist versus an assistant," Little advises. The contract therapists also will have to make the distinction of which visits should be coded as maintenance therapy.

This could end up being the biggest headache, agencies worry, since contract therapists can prove resistant to making process changes.