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Home Health & Hospice Week

Prospective Payment System:

PPS ADJUSTMENTS FINALLY UNDERWAY

Published on Tue Jan 27, 2009

You must take action to get the thousand dollars per error coming to you.

The wait has been long, but HHAs should soon have their 2008 PPS errors squared away.

Background: In an Oct. 31, 2008 transmittal, the Centers for Medicare & Medicaid Services directed the regional home health intermediaries to process adjustments for nine separate prospective payment system errors that occurred in 2008 (see Eli's HCW, Vol. XVII, No. 39, p. 308). For two of the nine errors listed, home health agencies must bring incorrectly paid claims to the RHHIs' attention to have them corrected.

At the time, CMS and the RHHIs expressed hope that the adjustments would be complete not just by the Feb. 2, 2009 deadline, but before the year's end. However, that didn't happen.

Intermediary Cahaba GBA began processing the adjustments on Jan. 23 and will complete them by Feb. 1, a Cahaba representative tells Eli. And RHHI National Government Services is also on track to complete the adjustments by the deadline, CMS has told the National Association for Home Care & Hospice, according to NAHC.

Intermediary Palmetto GBA will start making adjustments on Feb. 2, a rep tells Eli. "We do not have a timeline for the completion of the adjustments," the source adds.

Don't feel bad if you're confused by the adjustments. Beyond CMS's original transmittal and MLN Matters 6article from last fall, the RHHIs didn't give agencies advance notice that the recoupments and repayments would take place.

"I've not seen any info from Cahaba through its listserv, Web site or Newsline publication," points out consultant M. Aaron Little with BKD in Springfield, Mo.

Coming: "We will publish additional information this week to inform providers about the status of the adjustments," the Cahaba source pledges.

Don't forget: You'll probably find it worth your while to take action on error #2 from the transmittal, experts agree. That error occurred only when claims were projected to have less than 20 therapy visits but actually had exactly 20 therapy visits.

This is one of two errors that agencies must bring to RHHIs' attention manually for correction, and an adjustment will net you more than $1,000.

The other errors being corrected range from the widespread problem of failing to count 2007 episodes toward early/late designations to incorrectly paying low utilization payment adjustment (LUPA) amounts.

In general: If you had a lot of later episodes designated as early ones due to error #6 in the transmittal, you'll likely be looking at some extra money. If you had a lot of LUPA episodes near the five-visit limit, you're more apt to have to repay money due to error #5 in the transmittal.

Note: The transmittal describing in detail the nine errors being corrected is at www.cms.hhs.gov/transmittals/downloads/R397OTN.pdf. The MLN Matters article about the topic is at www.cms.hhs.gov/MLNMattersArticles/downloads/MM6250.pdf.

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