Home Health & Hospice Week

Afavorite tactic of some Medicare fraudsters is to set up 'dummy' storefront operations that have billing addresses but no real health care going on. The feds are on to this trick, and that's good.

But well-meaning home health providers and suppliers that have moved recently need to take steps to make sure they don't get caught in the dragnet. According to Transmittal 306 from the Centers for Medicare & Medicaid Services, effective Nov. 2, "all providers and suppliers are subject to unannounced site visits prior to receiving Medicare billing privileges or subsequent to receiving Medicare billing privileges."

In certain cases, CMS will instruct a Medicare Administrative Contractor (MAC) to make a visit to a medical provider or supplier to determine if it's operational at the address on file. If the MAC representative can't tell from an external check-up whether the place is in operation, the MAC rep "shall conduct an unobtrusive site verification by limiting its encounter with provider or supplier personnel or medical patients."

If your office is closed when the MAC rep arrives, but it doesn't appear that the office is nonoperational, the MAC will come back to re-check. If the MAC determines that the office is not operational at the address on file, the MAC will revoke the provider's billing privileges within seven days, unless the provider has submitted a change of address to Medicare.

The transmittal most likely aims to discourage "sham" operations from setting up shop -- those storefront buildings that set up Medicare billing privileges and submit fraudulent claims but don't actually see patients. However, the new regulations could bleed over to affect legitimate providers who simply forgot to update an address change.

Tip: If you've moved recently, make sure your MAC has the right contact information on file for your practice. "The best and most effective way for providers to verify their information would be to contact customer service at the appropriate MAC," advises Sandie Becker, coding and reimbursement specialist with the Santa Clara County Medical Association and Monterey County Medical Society in California.

Resource: Read the transmittal at www.cms.hhs.gov/transmittals/downloads/R306PI.pdf.

• Bidding and registration for the Round One rebid of the Medicare Durable Medical Equipment, Prosthetics, Orthotics, and Supplies Competitive bidding program is open as of Oct. 21, the Centers for Medicare & Medicaid Services announced in its Oct. 21 Home Health, Hospice & DME Open Door Forum.

The registration period closes Nov. 4. "Suppliers that do not register by that date will not be able to bid and are not eligible for contracts," CMS stresses. Bidders must submit all bids, using the online bidding system, by 9 p.m. ET on Dec. 21, 2009, CMS says.

All bidders also must submit required hardcopy documents as specified in the request for bids instructions, CMS reminds suppliers. Bidders that submit these documents by the covered document review date (CDRD) -- postmarked by 11:59 p.m. on Nov. 21, 2009 -- will be notified if any of the required financial documents are missing, CMS' Joel Kaiser told forum listeners. CMS will notify bidders of missing documents within 45 days of the CDRD and bidders must submit the missing documents within ten business days of the notification, CMS says.

Resource: For more information, check out www.dmecompetitivebid.com.

• The Centers for Medicare & Medicaid

Services is lining up its interest rate with what private consumers pay.

Effective Oct. 22, CMS wants Medicare contractors to apply a 10.875 percent interest rate to all overpayments and underpayments to match the Treasury's fixed rate, according to Change Request 6651 and Transmittal 160 published on Oct. 15.

Why: Regulation 42 CFR Section 405.378 allows Medicare to assess interest at whichever rate is higher -- the current value of funds (which is 3 percent for 2009) or the Department of the Treasury's rate for private consumers.

Resource: Read the transmittal at www.cms.hhs.gov/transmittals/downloads/R160FM.pdf.

• Even if you have downloaded the CMS data specifications for OASIS C software, you need to download a new copy, CMS' Kim Jasmin announced at the Oct. 21 home health forum.

CMS posted HAVEN 9.3, a corrected version of the data specs on Oct. 20 at www.cms.hhs.gov/OASIS. This corrected version is the third edition of the OASIS C data specs. Refer to file BC200R3 for a list of the corrections. Changes made in the current version are designated as R3, Jasmin explained.

HAVEN 9.3 is posted at www.cms.hhs.gov/OASIS/045_HAVEN.asp. This is an updated version that corrects a few errors in HAVEN 9.2, CMS said in the forum.

Heads up: HAVEN now uses a Java-based grouper, so providers must read the release notes and installation notes prior to installing the new HAVEN program, Jasmin warned.

• Palmetto GBA wants to clear up your confusion about when Medicare is the primary or secondary payer.

The RHHI is hosting a series of Webinars to help agencies bone up on how and when to submit claims to Medicare for reimbursement. Home Health Medicare Secondary Payment Billing will be held on Tuesday, Oct. 27 at 10 a.m. and Home Health and Hospice Medicare Advisory Training will be held via teleconference on Thursday, Oct. 29 at 2 p.m. Hospice Medicare Secondary Payer Billing will also be held on Thursday, Oct. 29 at 10 a.m.

For more information, go to www.palmettogba.com/rhhi, and under the Learning & Education heading, click on Online Learning.

• CMS just awarded a special project contract to the quality improvement organization, Quality Insights of Pennsylvania, to work with home health agencies across the country. More specific information will be available soon.