Home Health & Hospice Week

Suppliers may start the new year off with severely restricted cash flow if they don't pay attention to a new claims edit taking effect in January. "Contractors are now comparing the [National Provider Identifier numbers] of ordering physicians listed on DME claims against a national list of Medicare-approved physician NPIs in the Medicare Provider Enrollment Chain and Ownership System (PECOS) database," warns the American Association for Homecare.

Back in April, the Centers for Medicare & Medicaid Services announced its new edits on ordering physician NPIs (see Eli's HCW, Vol. XVIII, No. 20, p. 159). Currently, contractors are just giving suppliers warnings about the invalid NPIs. But in January, Medicare will start denying payment for those claims.

Up to 60 percent of DME claims are currently receiving warnings, AAHomecare says. "These warnings will turn to rejections beginning January 4," the trade group cautions.

Resource: April 24 Transmittal No. 480 (CR 6421) detailing the new edits is online at www.cms.hhs.gov/transmittals/downloads/R480OTN.pdf.

• If you'd like more details on how the new home health agency outlier cap will work, you'll have to wait until next month. But in the meantime, you can rest assured that CMS's 10 percent cap on outlier payments per HHA won't affect your billing, the agency says in a listserv message to providers. "HH PPS billing instructions are not changing as a result of this policy," CMS stresses.

CMS finalized the cap in its 2010 prospective payment system rate update final rule (see Eli's HCW, Vol. XVIII, No. 39, p. 298). The change aims to curb fraud and abuse of outlier payments in areas such as South Florida.

You'll get more information on how the cap will be applied soon. "Final instructions (Change Request/Transmittal) describing the changes that will be made by Medicare contractors to implement this new outlier policy are currently being developed and are expected to be released sometime in early December," CMS says.

• You won't be able to furnish walkers to Medicare beneficiaries if you are in a competitive bidding area and don't win a contract, but the same isn't true for your local hospital. When bidding begins in January 2011, hospitals will be allowed to furnish walkers and related accessories to patients on the day of discharge, even if the hospitals aren't contract suppliers, CMS clarifies in a new MLN Matters article.

Pitfall: The exception doesn't apply to hospital-owned DME suppliers, CMS stresses. The hospital itself must furnish the equipment to receive Medicare payment. Contractors must receive a claim with the patient's day of discharge before they will pay a walker claim. If the contractor doesn't receive the hospital claim within 15 days of receiving the walker claim, it will deny the walker claim.

More information is at www.cms.hhs.gov/MLNMattersArticles/downloads/MM6677.pdf.

CMS has also issued bidding MLN Matters articles about repairs and replacements (www.cms.hhs.gov/MLNMattersArticles/downloads/MM6678.pdf) and oxygen (www.cms.hhs.gov/MLNMattersArticles/downloads/MM6692.pdf).

• End-of-life counseling in pending health reform legislation continues to receive mainstream notice. Increased hospice use could save on health care costs, points out a recent Associated Press article. And patients prefer to die in their homes surrounded by friends, family, and pets, VITAS medical director Joel Policzer told AP.

In the small Wisconsin town of La Crosse, 96 percent of residents have living wills thanks to a hospital-led initiative to help patients complete them, reports National Public Radio. The town's Gunderson Lutheran Hospital spends less on patients in their last two years of life than anywhere else in the nation, NPR says. Claims that government-run panels would pressure sick people to die are bizarre exaggerations, says Bud Hammes, the medical ethicist who started the advance directive program at the hospital.

• You can get paid for claims caught up in a system glitch, but it will require some extra paperwork.

Claims are being incorrectly returned to provider (RTP'd) with reason code 38107, regional home health intermediary Palmetto GBA notes on its Web site. "The system cannot find a processed RAP that corresponds to the Final claim," it explains.

As a workaround, you can request that the intermediary's Provider Contact Center cancel the claim so you can resubmit it. "Providing a spreadsheet of your affected claims will be appreciated," Palmetto says.

More details of how to complete the workaround are on Palmetto's Web site at www.palmettogba.com. Afix for the problem is scheduled for January.

• The caps for outpatient therapy in 2010 will increase by $20 to $1,860, CMS says in Nov.13 Transmittal No. 1851 (CR 6660). That's one cap for occupational therapy and one for physical therapy and speech-language pathology combined.

Remember: The therapy caps apply only to outpatient Part B therapy, not therapy furnished under home health PPS.

Patients can get a waiver to exceed those cap amounts -- but only if Congress extends the exceptions process. Currently, the exceptions are set to expire Jan. 1. "The exceptions process will continue unchanged for the time frame directed by congress," CMS says in the transmittal.

• Just because your claims don't get touched by the Recovery Audit Contractors next year doesn't mean you're in the clear. CMS has given the go-ahead to Program Safeguard Contractors (PSCs) and Zone Program Integrity Contractors (ZPICs) to suppress and exclude claims from RAC audits if they are investigating the claims.

"To prevent interference with active investigations and cases, PSCs and ZPICs shall enter suppressions in the RAC Data Warehouse to temporarily mark entire providers or subsets of a provider's claims as off-limits to the RACs," CMS explains in Nov. 13 Transmittal No. 311 (CR 6684).

Certain codes may even be suppressed across an entire geographic area when widespread fraud and abuse is suspected, CMS says.

• Ignorance is no excuse when it comes to Medicare's new cost report filing system.

"The June 30, 2009 cost report is due November 30, 2009, or 30 days from the receipt of the Summary PS&R [provider statistical & reimbursement] reports, whichever is later," intermediary Cahaba GBA notes in a message to providers.

"We will be sending PS&R reports to providers with a June 30, 2009 cost reporting period that CMS has made us aware have not registered in IACS and have not been approved in the PS&R system."

Providers need an IACS (Individuals Authorized Access to CMS Computer Systems) password to enter the new Internet-based PS&R system (see Eli's HCW, Vol. XVIII, No. 24, p. 191). CMS had previously said agencies were responsible for downloading their own PS&R reports.

• Beware changes to your patients' Medicare Advantage status. Open enrollment for prescription drug plans began Nov. 15 and ends Dec. 31. Many seniors think they're signing up for just a drug plan, but unwittingly agree to enrollment in a total Medicare Advantage health plan, observers warn. Those plans often require preauthorization for payment or don't approve home care visits.

• If you need help figuring out procedures for Change of Ownership (CHOW), Provider Enrollment, or Timely Filing Guidelines, Palmetto is lending a helping hand. The intermediary has posted new "job aids" on those topics on its Web site at www.palmettogba.com.