Regulations:
M0175 Takebacks Finally To Hit In November
Published on Mon Aug 01, 2005
CMS forum also reveals details on expedited review, outcomes and hospital referrals. In just a few short months, you may have to pay the piper if you've made mistakes recording patients' prior inpatient stays.
For the first three years under the prospective payment system, the claims processing system didn't catch the mistake if a home health agency failed to mark a hospital, skilled nursing facility or rehab stay in OASIS item M0175.
Why it matters: That's a big deal because failing to mark a hospital stay along with a SNF or rehab stay nets the HHA an extra $200 for a non-therapy patient's episode and $600 for a therapy patient's episode. Conversely, if an HHA fails to mark the SNF or rehab stay, it shorts itself of $200 or $600 per episode.
A series of HHS Office of Inspector General reports projects millions in M0175 overpayments due to un-marked hospital stays, and the Centers for Medicare & Medicaid Services said last summer that it would start M0175 recoupments from the first years of PPS this year (see Eli's HCW, Vol. XIII, No. 28, p. 218).
After a series of delays, recoupment time is now almost nigh, CMS said in the Aug. 25 Open Door Forum for home care providers. CMS has sent the overpayment files to the regional home health intermediaries, CMS official Wil Gehne said in the forum. And the files include underpayments too - a hard-fought concession won by the industry.
The RHHIs first will test the M0175 files, Gehne explained. "We want to make sure that these files are right before we take any actions with them." Then starting Oct. 24, the intermediaries will post the over- and underpayments on the system so that agencies have five weeks to review them for accuracy.
How to correct: When an agency finds an erroneous adjustment, it should tell its RHHI. The intermediary will then remove the adjustment before it is processed if it agrees with the error, Gehne said.
Happy holidays: After the review period, the RHHIs will begin making the M0175 adjustments - both recoupments and refunds - the week of Nov. 28, CMS expects. After the adjustments are processed, HHAs must pursue correction through the traditional claims appeal process. CMS: Underpayments Offset Overpayments "The impact of these adjustments on home health agency cash flow isn't expected to be significant," Gehne said in the forum. That's partly due to the over- and underpayments offsetting each other. "If people have findings to the contrary of that, then we certainly want to know about them," he said.
The files will include adjustments based on patient stays in long-term care hospitals, Gehne confirmed. That's despite industry protests that LTCHs function more like SNFs than acute hospitals.
Other topics addressed [...]
