April next target date for millions of dollars in retroactive recoupments. If you had trouble answering the OASIS question on patients' prior hospital stays when PPS began, your financial punishment has been put off a little while longer.
Home health agencies expected M0175 recoupments from the first three years of the prospective payment system to start this month (see Eli's HCW, Vol. XIII, No. 28, p. 219). The HHS Office of Inspector General has estimated takebacks for fiscal year 2001 alone at $23 million.
But now April appears to be the earliest date agencies will see the bite, according to regional home health intermediary sources.
The new date isn't really a delay, given that the transmittal requiring the recoupments specifies implementation only "no earlier than January 2005," a Centers for Medicare & Medicaid Services official tells Eli.
The timeline: RHHIs expect to receive the programming for the takebacks in mid-February and test it in the following weeks. If the file is OK, intermediaries will post the pending M0175 adjustments for FY 2001 in early March. Providers will then have a month to look over the coming adjustments.
If all goes as planned, the recoupments will start in early to mid-April, RHHI officials predict.
It won't only be downcodes that are recouped, however. Providers won a hard-fought battle when CMS agreed to identify M0175 mistakes in agencies' favor for FYs 2001, 2002 and 2003 and refund any underpayments (see Eli's HCW, Vol. XIII, No. 28, p. 218). Agencies will gain $200 to $600 per episode when they identified a hospital stay within 14 days of admission, but failed to identify a SNF or rehab stay as well.
Experts are split on whether overpayments will significantly outstrip underpayments or whether they will even out.
CMS has previously said it plans to have intermediaries recoup FY 2001 funds first, then recoup 2003 and 2004 monies within a year or two.
HHAs have operated under ongoing, pre-payment edits for M0175 since last April (see related story, p. 29). And intermediaries soon will start conducting an annual post-payment, retroactive recoupment of M0175 payments, to catch those hospital stays that don't show up in the Medicare claims file before HHAs bill their final claims.
CMS has thus far refused to identify M0175 underpayments for HHAs from FY 2004 onward, although they will continue to recoup overpayments for those years.
Editor's Note: To find out more about how to answer and bill M0175 accurately and obtain your rightful reimbursement, you can sign up for a March 10 Eli Research and Coding Institute teleconference, "OASIS Accuracy (Part 1): An In-Depth Look at the Service Domain Items," at
http://codinginstitute.com/conference/conference.cgi?detail=245 or by calling 1-800-508-2582.
