Effective Date: October 1, 2010

CMS is updating edit criteria related to the consolidated billing provision of the Home Health Prospective Payment System (HH PPS).

Non-routine supplies provided during a HH episode of care are included in Medicare’s payment to the home health agency (HHA) and subject to consolidated billing edits as described in the Medicare Claims Processing Manual, chapter 10, section 20.2.1. If the date of service falls within the dates of HH episode, the line item was previously rejected by Medicare systems.

Effective October 1st, 2010, CMS is implementing new requirements to modify this edit in order to restore the original intent to pay for supplies delivered before the HH episode began. Such supplies may have been ordered before the need for HH care had been identified, and are appropriate for payment if all other payment conditions are met. The edit will be changed to only reject services if the ‘from’ date on the supply line item falls within a HH episode.

Good Morning MFS Bloggers, CMS recently revised the its OASIS-C Guidance Manual for Calendar Year 2011. The revisions and updated errata list are now available on the CMS site, https://www.cms.gov/HomeHealthQualityInits/14_HHQIOASISUserManual.asp, and are available for download:

OASIS-C Guidance Manual Errata (December 2011)
and OASIS-C Guidance Manual (December 2011)

Have a great day!

Good Morning MFS Bloggers, In a December 8, 2011 CMS Listserv Update, CMS clarified its policy on its face-to-face documentation requirements. CMS stated as follows: “In the case of patients admitted to home health following an acute or post-acute stay, the BPM language allows for one physician to sign the certification and face-to-face documentation, while a different physician can sign the plan of care. If the face-to-face encounter documentation and the CMS-485 form collectively satisfy all of the certification and plan of care content requirements as defined in Chapter 7 Section 30 of the BPM, Medicare contractors shall accept a CMS-485 form signed by the community physician who assumes oversight of the patient’s home healthcare with an addendum containing the face-to-face encounter documentation requirements signed by a physician who cared for the patient in an acute or post-acute setting, to satisfy the certification, face-to-face encounter, and plan of care requirements. In this scenario, the certifying physician is the acute or post-acute physician, has initiated content on the CMS-485, and has completed and signed the face-to-face encounter documentation. The physician who signs the CMS-485 assumes care for the patient’s home healthcare.
Additionally, it has come to our attention that some contractors are denying claims for failure of the acute or post-acute physician to identify the community physician who will assume care for the patient. CMS has not mandated the acute or post-acute physician to follow a specific documentation protocol to hand-off a patient to the community physician.
For claims that have been previously denied for not having met face-to-face requirements in the scenarios described above, upon receiving a request from the home health agency for reopening of the claim, CMS contractors have been instructed to reopen and determine if face-to-face requirements have been met, due to their meeting the criteria described in the instruction described above. However, a determination that face-to-face requirements have been met would not result in an automatic pay of the claim. Contractors must subsequently perform a complete and full review to determine if payment should be made.
In summary, assuming all content requirements of the certification and the face-to-face documentation are otherwise met, in the case of patients admitted to home health following an acute or post-acute stay, Medicare contractors have been instructed to accept a CMS-485 form signed by the community physician who assumes oversight of the patient’s home healthcare with an addendum containing the face-to-face encounter documentation requirements signed by a physician who cared for the patient in an acute or post-acute setting, to satisfy the requirement of the certification, (which now includes the face-to-face encounter).”

Wishing you all a happy and healthy 2012.
Christopher A. Parrella, JD, CHC, CPC, CPCO

Good Afternoon MFS Bloggers!

The Affordable Care Act (the “ACA”) amended the requirements for physician certification of home health services to require that, as a condition of payment, prior to certifying a patient’s eligibility for the home health benefit, the certifying physician must document that the physician himself or herself, or an allowed nonphysician practitioner (NPP) working with the physician, has had a face-to-face encounter with the patient. HHAs have been required to comply with the face-to-face encounter requirements since April 1, 2011.

Importantly, CMS addressed what is called an “unintentional gap” in ACA by not explicitly including language that allows the acute or post-acute attending physician to inform the certifying physician regarding his or her face-to-face encounters with the patient to satisfy the requirement. CMS stated that ACA does not preclude a patient’s acute or post-acute physician from informing the certifying physician regarding his or her experience with the patient for the purpose of the face-to-face encounter requirement, much like a NPP currently can.

The final rule revises applicable regulations to incorporate CMS’ position: effective with starts of care beginning January 1, 2012, and later, for patients admitted to home health immediately after an acute or post-acute stay, the physician who cared for the patient in the acute or post-acute facility may perform the face-to-face encounter and communicate the clinical findings of that encounter to the certifying physician. CMS commented that the HHA may facilitate communications between the physicians, including sending the discharge plan to the certifying physician. The patient’s discharge summary or discharge plan can serve as the face-to-face documentation if it includes the signature of the certifying physician and the required content.

Good Morning MFS Bloggers,

The new Medicare provider enrollment revalidation effort does not change other aspects of the enrollment process. Providers should continue to submit routine changes (address updates, reassignments, additions to practices, changes in authorized officials, information updates, etc) – as they always have. If you also receive a request for revalidation, respond separately to that request.
All providers and suppliers who enrolled in the Medicare program prior to 03/25/2011 will have their enrollment revalidated under new risk screening criteria. DO NOT send in revalidated enrollment forms until you are notified by Medicare. You will receive a notice to revalidate between now and March, 2013.

ALL MEDICARE PAYMENTS TO BE MADE BY EFT
Medicare requires at the time of enrollment, enrollment change request or revalidation, providers that expect to receive payment from Medicare for services provided must also agree to receive Medicare payments through electronic funds transfer (EFT). As part of the revalidation efforts, all providers who are not currently receiving EFT payments will be identified, and required to submit the CMS-588EFT form with the provider revalidation application.

Good Afternoon MFS Bloggers, Please find below recent CMS postings regarding muliple modaliuty billing.

During a home health visit, nurses and therapists many times provide more than one service. Do we report multiple G-codes for all the services that were provided during the visit?
Answer:
In the course of a visit, a nurse or qualified therapist could likely provide more than one of the nursing or therapy services reflected in the new and revised codes. Home health agencies (HHAs) must not report more than one G-code for the nursing visit regardless of the variety of nursing services provided during the visit. Similarly, the HHA must not report more than one G-code for the therapy visit, regardless of the variety of therapy services provided during the visit. In cases where more than one nursing or therapy service is provided in a visit, the HHA should report the G-code which reflects the service for which most of the time was spent during that visit.

Note: Documentation should include details of all the services provided during the visit.

Is it true that if a home health agency (HHA) provides a therapy service and a nursing service on the same day for the same patient that the HHA can only bill one G-code for that day?Answer:

No. Change Request 7182 does not change the reporting requirements for HHAs. Claims must report all home health services provided to the beneficiary within the episode. Each service must be reported in line item detail. A separate G-code for therapy and a separate G-code for nursing for the same patient on the same day is acceptable.

Have a great afternoon, CP