Medicare Compliance & Reimbursement

Most practices are quite aware of the fact that Medicare beneficiaries hate seeing their Social Security number (SSN) printed right on their Medicare identification cards — but that’s about to change. Due to the risk of identity theft, CMS will discontinue printing SSNs on beneficiary cards within the next four years.

The OIG’s Deputy Inspector General Gary Cantrell testified before Congress about Medicare fraud, and recommended removing SSNs from the documents to curb the growing problem of medical identity theft. Fortunately, Congress took note and included language in the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) that will eliminate the problem.

“The Secretary of Health and Human Services, in consultation with the Commissioner of Social Security, shall establish cost-effective procedures to ensure that a Social Security account number (or derivative thereof) is not displayed, coded, or embedded on the Medicare card issued to an individual who is entitled to benefits under Part A of title XVIII or enrolled under Part B of title XVIII and that any other identifier displayed on such card is not identifiable as a Social Security account number,” the bill says.

The bill goes on to say that the agencies have four years to make the transition to SSN-free cards.

CMS: You May Get Partial Payments if You Code Incorrectly

If your Medicare contractor currently finds one of your claims to be coded incorrectly, the MAC probably denies the whole claim and then you have to either appeal it or resubmit it with a different code. Going forward, however, you might find that your contractor pays you for the code it believes you should have billed.

“In certain situations, it is appropriate for contractors to up code or down code a claim (or items or services on a claim) and adjust the payment,” CMS says in Transmittal 585, which has an implementation date of May 4, 2015.

When the medical record supports a higher or lower level code, the MACs and auditors from organizations such as the ZPIC or CERT “shall not deny the entire claim but instead shall adjust the code and adjust the payment,” CMS says in the transmittal.

Therefore, if you start seeing partial payments on your claims, you should inquire with your MAC about why your claim was upcoded or downcoded and appeal as necessary.

Resource: To read Transmittal 585, visit www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/Downloads/R585PI.pdf.

Surety Bond Requirement for HHAs Signed Into Law

Now that the Medicare Access and CHIP Reauthorization Act of 2015 is law, you need to start thinking about how to prepare for the surety bond requirements it contains. The mandate hurts agencies struggling to comply.

The legislation contains a 2018 payment update reduction for both HHAs and hospices, as well as a $50,000 surety bond requirement for HHAs. The payment update will be limited to 1 percent in 2018, and the surety bond will have a minimum $50,000 amount — and the amount will increase corresponding to an agency’s revenues.

The bill also extends rural add-ons, praised Val Halamandaris with the National Association for Home Care & Hospice (NAHC).

NAHC will “continue looking for opportunities to repeal” the bond provision, he pledged in a statement. The requirement “would further hurt providers currently struggling to comply with expensive regulations; it would threaten access to care especially in rural areas; it is effectively a tax on the vast majority of providers to cover the cost of a few bad actors; [and] it provides too much discretion to CMS in setting the bond amount and implementing the requirement.”

Plus: “Any surety bond requirement should be time-limited and targeted to new providers only,” Halamandaris said. “Longstanding providers rarely present a risk to Medicare.”