Home Health & Hospice Week

A new billing privileges regulation that hit the books Jan. 1 could stop your Medicare billing in its tracks, unless you know the ropes.

Under the new rule, if your home health agency Medicare billing privileges are deactivated for any reason, you will have to undergo a state or accreditation survey to obtain reactivation, the Centers for Medicare & Medicaid Services says in Dec. 18, 2009 Transmittal No. 318 (CR 6750).

That goes for planned changes such as changes in ownership (see related story, this page) or deactivations for problems ranging from fraud suspicions to incorrect enrollment paperwork to not submitting claims for 12 months.

Pitfall: Don't forget to send in changes to your enrollment information within 90 days of their occurrence. If you fail to report things such as a change in location, management, or billing service, your contractor will deactivate your billing privileges, CMS notes in the transmittal.

You'd better get your enrollment paperwork right or you could get stuck in a billing quagmire, warns attorney Shirley Morrigan with Foley & Lardner in Los Angeles. Once you're deactivated, you'll most likely go to the bottom of surveyors' to-do lists, meaning months or years before you get reactivated unless you choose accreditation. "It's going to be very hard to get back in," Morrigan tells Eli.

Tip: And if you're considering voluntary deactivation for a CHOW or other event, you should be very, very sure of the choice before pulling the trigger, Morrigan advises.