Home Health & Hospice Week

OASIS:

MONITOR M0175--OR RISK LOSSES FOR A NEW REASON

There's more at stake for HHAs than just case mix scores.

The feds may be about to stop tracking for payment purposes whether your patients were hospitalized just before heading to home care--but now is no time to get lax about how you're answering M0175.

A new report from the HHS Office of Inspector General signals the government's continued interest in home health agencies' accuracy in coding OASIS item M0175 (From which of the following inpatient facilities was the patient discharged during the past 14 days), experts say. Like other audits in recent years, the July 26 report notes that an agency's mistakes in coding M0175 led to Medicare overpayments.

But the latest OIG audit's timing is significant.

First, it comes on the heels of the Centers for Medicare & Medicaid Services' prospective payment system update proposal, which includes dropping M0175 from the list of items used to calculate patients' case mix.

Second, the report shows that CMS is likely to recover little by continuing to try to recoup M0175 overpayments. The audit found that Medicare had overpaid VNA Care Network of Worcester, MA, about $6,200 in 2004 and 2005--out of total claims paid in those years of about $437,000.

The VNA initially submitted more claims upcoded for M0175, but CMS' automatic prepayment edit for the item caught and corrected most of them.

"The $6,178 probably did not cover the cost of the audit," says Bob Wardwell of the Visiting Nurse Associations of America in Silver Spring, MD.

New cause for concern: Still, the report shows that the feds will continue to monitor agencies' accuracy on M0175--and they're not likely to look the other way even when the item drops from the case mix lineup.

"It's still a key risk-adjustment factor for a number of outcomes measures," notes consultant Judy Adams with Charlotte, NC-based LarsonAllen. And that makes it important to the future of Medicare revenues. Because M0175 influences outcomes, it will affect payment once Medicare starts paying HHAs based on their performance.

"Plus, there's still the rest of this year," says Adams, referring to M0175's continuing role in determining case mix scores for 2007.

Furthermore, CMS has no plans to stop overpayment recoveries from past years, an agency official tells Eli.

Note: The OIG report (A-01-06-00514) is at http://oig.hhs.gov/oas/reports/region1/10600514.htm.
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