Home Health & Hospice Week

Hint:  Don't apply for that branch NPI just yet.

Stay focused to fare well under Medicare's new enrollment process. Take these steps to ensure compliance and smooth billing:

1. Do your homework on the National Provider Identifier (NPI). Why? The new enrollment process requires that you have to have an NPI to file the main enrollment form--CMS Form 855. That means you may need to apply for an NPI well in advance of the May 2007 deadline for including the new identifier on your Medicare claims.

"Many people are still confused by the application itself," says Denise Bonn, an attorney with the Center for Health Care Law at the National Association for Home Care & Hospice.

Best advice: Bite the bullet and apply now for your number. You can apply in one of three ways:

• Apply through a Web-based application at https://nppes.cms.hhs.gov;
• Prepare and send a paper application form, available at the same Web address;
• Request an application by calling 800-465-3203 (TYY 800-692-2326).

2. Hold off on NPI applications for your branches. Secure an NPI for your business, but hold off on following CMS' manual guidance to apply for distinct NPIs for your branches, coaches Bonn.

"It may be unnecessary," she allows. NAHC is working with CMS to rescind the requirement.

3. Get ready for electronic funds transmission (EFT). If you are not already receiving your payments electronically, take preliminary steps toward making your business EFT-friendly, advises Rose Kimball, president of Med-Care Administrative Services in Dallas, TX.

The new Medicare enrollment process requires that any entity filing Form 855 move to electronic funds transmission--even if you are only filing the form to report a routine change.

Tip: If you decide to move to electronic billing as well as e-payments, and opt to use the free software provided by your Medicare contractor, get the program on a disk rather than downloading it, advises Kimball. Installing the program from the disk will help you avoid some of the problems that come with the downloaded version, she reports.

If you don't plan to use the free software--and instead opt for a more sophisticated program--count on a monthly cost of between $350 to $1,500 to lease the software you'll need, estimates Kimball.

4. Read the fine print if you're a prospective owner. The June 30 manual update spells out some new rules about how to bill in change of ownership situations--and some could spell cash-flow woes for new owners.

In the manual update, CMS clarifies that if the new owner of a home health agency or hospice accepts assignment of the provider agreement, the old owner may continue to bill Medicare for services from the date of the closing or sale date, until the new owner is notified that the CMS regional office has approved the ownership change.

Protect yourself: In this situation, the old owner will be receiving payment for services you render as the new owner, so draft a contract spelling out terms for transferring the funds. In the same contract, spell out a process and timeframe for shifting over copies of records, so you can confirm the accuracy of the payments you receive.