Industry News: CAHPS Survey Time Period Extended
October 20th, 2011 8:47 AM

Home Health Care CAHPS (HHCAHPS) Survey protocols require that HHCAHPS Survey vendors initiate the survey—that is, begin data collection activities—within 21 days after the close of a sample month. The rationale for this protocol is that sample patients will be better able to recall and accurately report their experiences with home health care if the survey is administered as soon as possible after the care is received.

The Centers for Medicare & Medicaid Services (CMS) is issuing the following guidance to HHCAHPS Survey vendors and home health agencies (HHAs) regarding initiating the HHCAHPS Survey more than 21 days after the sample month ends.

Effective immediately, if the survey cannot be fielded within 21 days after the sample month ends, HHCAHPS Survey vendors will be permitted to field the survey by the 26th day after the sample month ends. Survey vendors, however, should still make a concerted effort to initiate the survey within 21 days after the sample month ends. HHAs and vendors do not need approval to initiate the HHCAHPS Survey between the 22nd and 26th day after the sample month ends; however, survey vendors must continue to submit a Discrepancy Notification Report (DNR) to document the fact that the survey was not initiated within 21 days after the sample month ended.

CMS recognizes that occasionally HHAs may experience a situation that may make it difficult to provide a monthly patient information file in time for the vendor to initiate the survey within 21 days after the sample month ends. If the survey cannot be initiated within 26 days after the sample month ends, the HHA’s approved vendor must request approval from CMS to field the survey for the specific sample month. To request this approval, the survey vendor should send an e-mail message to the HHCAHPS Coordination Team, copying its HHA client, indicating the reason(s) the survey cannot be initiated as scheduled, and the expected date by which the survey will be initiated. CMS will review each request; the Coordination Team will notify the HHA and its vendor as to whether the request is approved.

If CMS approves the request for the HHA to initiate the HHCAHPS Survey more than 26 days after the sample month ends, the vendor will not need to submit a DNR. The e-mail message that the vendor submitted requesting approval to field the survey will be retained as documentation of the late data collection start.

HHCAHPS Survey vendors and HHAs should contact the HHCAHPS Coordination Team at hhcahps@rti.org or by calling the HHCAHPS toll-free number at 1-866-354-0985 if they have any questions or need further information about this protocol.

Posted by Bryan Fryar in Home Health CAHPS Survey from CMS   |  0 Comment(s)

Industry News: CMS Updates Provider Enrollment Rules (PECOS)
September 9th, 2011 11:03 AM

PECOS Enrollment

Section 6401 (a) of the Affordable Care Act required all enrolled Medicare providers to revalidate their enrollment information through the PECOS system.  This has been delayed but recently, CMS provided information that all providers that were enrolled prior to March 25, 2011 will be asked through their MAC to re-enroll.  Notices from the MAC will begin now and end on March 23, 2013.  Providers need to know the following:

**Providers will not be asked to revalidate until they have received notification from their respective MAC.

**Once notification is received, the easiest way to revalidate is through the PECOS system and can be found at https://pecos.cms.hhs.gov         on the CMS website.  This will allow the provider to update and submit revalidation via the Internet.  Once submitted, the provider must print, sign, date and mail the certification statement to their MAC.

**Once submission is completed, a fee of $505 per provider must be submitted.  The easiest way to submit payment is via the site http://www.pay.gov and type CMS in the search box under Find Public Forms.  Click the GO button to submit the fee via the website.

**Failure to submit the enrollment forms may result in the provider losing Medicare billing privileges.

More information about the enrollment process and fees can be found at the following website:

http://www.cms.gov/MLNMattersArticles/downloads/MM7350.pdf

Posted by Bryan Fryar in PECOS Enrollment for Home Health Providers   |  0 Comment(s)

Industry News: CMS FACE TO FACE REQUIREMENTS DELAYED
December 23rd, 2010 1:17 PM

CMS REQUIREMENT DELAYED

The Centers for Medicare & Medicaid (CMS) notified NAHC that instructions have been sent to its contractors advising them that home health agencies and hospices are to be allowed to use the first quarter of 2011 to implement procedures to meet face to face encounters requirements. Basically, this results in a delay of the implementation of the regulation.

Please check back with HealthCare Strategies as more information is released.

Posted by Bryan Fryar in CMS Home Health Agency Regulations   |  0 Comment(s)

Industry News: Timely Filing Requirement from the Patient Protection and Affordable Care Act (PPACA)
December 21st, 2010 12:40 PM

Taken from the recent CMS announcement:

Effective immediately, the Centers for Medicare & Medicaid Services (CMS) would like to remind Medicare fee-for-service physicians, providers and suppliers, who are submitting claims to Medicare for payment, all claims for services furnished on or after January 1, 2010, must be filed with your Medicare contractor no later than one calendar year (12 months) from the date of service or Medicare will deny them. This is a result of the Patient Protection and Affordable Care Act (PPACA).

•If you have Medicare fee-for-service claims with service dates from October 1, 2009, through December 31, 2009, those claims must be filed by December 31, 2010, or Medicare will deny them

•Claims with service dates from January 1, 2009, to October 1, 2009, keep their original December 31, 2010, deadline for filing.

In general, the start date for determining the one-year timely filing period is the date of service or 'From' date on the claim. For institutional claims that include span dates of service (i.e., a 'From' and 'Through' date on the claim), the 'Through' date on the claim is used for determining the date of service for claims filing timeliness. For claims submitted by physicians and other suppliers that include span dates of service, the line item 'From' date is used for determining the date of service for claims filing timeliness.

For additional information about the new maximum period for claims submission filing dates, contact your Medicare contractor or review the MLN Matters articles listed below related to this subject:

•MM6960 (PDF, 70 KB) – 'Systems Changes Necessary to Implement the Patient Protection and Affordable Care Act (PPACA) Section 6404 - Maximum Period for Submission of Medicare Claims Reduced to Not More Than 12 Months'

•MM7080 (PDF, 73 KB) – 'Timely Claims Filing: Additional Instructions 

Posted by Bryan Fryar in CMS Announcements for Home Health   |  0 Comment(s)

Industry News: Medicare and Medicaid Extenders Act of 2010 (MMEA)
December 21st, 2010 12:36 PM

Taken from the recent CMS Announcement:

On Wednesday, December 15, 2010, President Obama signed into law the Medicare and Medicaid Extenders Act of 2010 (MMEA). This new law prevents a scheduled payment cut for physicians who treat Medicare patients from taking effect. The Centers for Medicare & Medicaid Services (CMS) is pleased that this law has addressed key issues for beneficiaries and providers, and we are actively engaged in implementing these changes. 

CMS is also working to implement several important new provisions for Medicare beneficiaries made possible by the Affordable Care Act – the health reform law. In 2011:

•Beneficiaries who reach the prescription drug coverage gap, known as the donut hole, will receive a 50 percent discount when buying Part D-covered brand-name prescription drugs

•Virtually all Medicare beneficiaries are eligible to receive many free preventive care services and a free annual wellness visit

These provisions will improve care for Medicare beneficiaries, and we encourage you to share this information with your patients. More information on these Affordable Care Act provisions can be found at www.Medicare.gov and at www.healthcare.gov. Healthcare.gov also contains a timeline and other key information about the new law and a highly praised insurance finder for coverage options in public and private insurance programs, which family members and friends of Medicare beneficiaries may find useful.

Below please find technical summaries of key provisions of the MMEA along with some information about how these changes may affect providers and provider billing. 

Physician Payment Update

Section 101 of the MMEA prevents a payment cut for physicians that would have taken effect on January 1, 2011. While the physician fee schedule update will be zero percent, other changes to the relative value units (RVUs) used to calculate the fee schedule rates must be budget neutral. To make those changes budget neutral, the conversion factor must be adjusted for 2011. CMS is currently developing the 2011 Medicare Physician Fee Schedule (MPFS) to implement the zero percent update, and we expect all 2011 claims to be processed timely, in compliance with the new legislation.

Extension of Medicare Physician Work Geographic Adjustment Floor

Current law requires payment rates under the MPFS to be adjusted geographically for three factors to reflect differences in the cost of provider resources needed to furnish MPFS services: physician work, practice expense and malpractice expense. Section 103 of the MMEA extends the existing 1.0 floor on the 'physician work' geographic practice cost index, through December 31, 2011. As with the physician payment update, this change will be accomplished through a revised 2011 MPFS.

Extension of Physician Fee Schedule Mental Health Add-On Payments

For calendar year 2010, certain mental health services' payment rates continued to be increased by five percent. Section 107 of the MMEA extends the five percent increase in payments for these mental health services, through December 31, 2011. Similar to the zero percent update and the physician work geographic adjustment floor extension, the five percent increase will be reflected in the revised 2011 MPFS.

Extension of Medicare Modernization Act Section 508 Reclassifications

Section 102 of the MMEA extends Section 508 and special exception hospital reclassifications from October 1, 2010, through September 30, 2011. Effective April 1, 2011, Section 102 also requires removing Section 508 and special exception wage data from the calculation of the reclassified wage index if doing so raises the reclassified wage index. All hospitals affected by Section 102 of the MMEA shall be assigned an individual special wage index effective April 1, 2011. If the Section 508 or special exception hospital’s wage index applicable for the period beginning on October 1, 2010, and ending on March 31, 2011, is lower than the period beginning on April 1, 2011, and ending on September 30, 2011, the hospital shall be paid an additional amount that reflects the difference between the wage indices. The provision applies to both inpatient and outpatient hospital payments. For hospital outpatient payments, a special exception hospital’s reclassified wage index will be applicable from January 1, 2011, through December 31, 2011.

Extension of Exceptions Process for Medicare Therapy Caps

Section 104 of the MMEA extends the exceptions process for outpatient therapy caps. Outpatient therapy service providers may continue to submit claims with the KX HCPCS modifier, when an exception is appropriate, for services furnished on or after January 1, 2011, through December 31, 2011.  

The therapy caps are determined on a calendar year basis, so all patients begin a new cap year on January 1, 2011. For physical therapy and speech language pathology services combined, the limit on incurred expenses is $1,870. For occupational therapy services, the limit is $1,870. Deductible and coinsurance amounts applied to therapy services count toward the amount accrued before a cap is reached.    

Extension of Moratorium on Independent Laboratory Billing for the Technical Component (TC) of Physician Pathology Services Furnished to Hospital Patients

In the final physician fee schedule regulation published in the Federal Register on November 2, 1999, CMS stated that it would implement a policy to pay only the hospital for the TC of physician pathology services furnished to hospital patients. At the request of the industry, to allow independent laboratories and hospitals sufficient time to negotiate arrangements, the implementation of this rule was administratively delayed. Subsequent legislation formalized a moratorium on the implementation of the rule. 

Although the previous extension of the moratorium expired at the end of 2010, the MMEA restores the moratorium through 2011. Therefore, independent laboratories may continue to submit claims to Medicare for the TC of physician pathology services furnished to patients of a hospital, regardless of the beneficiary's hospitalization status (inpatient or outpatient) on the date that the service was performed.  This policy is effective for claims with dates of service on or after January 1, 2011, through December 31, 2011.

Extension of Ambulance Add-On Payments

The provisions that were extended by Section 106 of the MMEA are:

1.The three percent increase in the ambulance fee schedule amounts for covered ground ambulance transports that originate in rural areas and the two percent increase for covered ground ambulance transports that originate in urban areas

2.The provision relating to air ambulance services that considers any area that was designated as a rural area as of December 31, 2006, shall continue to be treated as a rural area for purposes of making payments under the ambulance fee schedule for such air ambulance services

3.The provision relating to payment for ground ambulance services where the base rate is increased when the ambulance transport originates in an area that is included in those areas comprising the lowest 25th percentile of all rural populations arrayed by population density.

All of these payment provisions are extended through December 31, 2011.

Extension of Outpatient Hold Harmless Provision

Section 108 of the MMEA extends the Outpatient Hold Harmless provision, effective for dates of service on and after January 1, 2011, through December 31, 2011, to rural hospitals with 100 or fewer beds and to all sole community hospitals and essential access community hospitals regardless of bed size. 

Extension of Medicare Reasonable Cost Payment for Clinical Lab Tests Furnished to Hospital Patients in Certain Rural Areas

Section 109 of the MMEA extends the reasonable cost payment for clinical lab tests furnished by hospitals with fewer than 50 beds in qualified rural areas as part of their outpatient services for cost reporting periods beginning on or after July 1, 2011, through June 30, 2012. This could affect services furnished as late as June 30, 2013. 

If your hospital qualifies under Section 109, you do not need to take any action. Your hospital will receive reasonable cost reimbursement for an entire year, starting with the facility cost reporting period beginning on or after July 1, 2011.

Repeal of the Delay of RUG-IV

Section 202 of the MMEA repeals the delay of the skilled nursing facility (SNF) PPS RUG-IV classification system. Therefore, RUG- IV will continue to remain in effect from October 1, 2010, as previously implemented by the final SNF payment regulation for FY 2011. All claims processing activities shall proceed in accordance with the existing instructions.

Please be on the alert for more information pertaining to the Medicare and Medicaid Extenders Act of 2010. Finally, as a reminder, beginning on January 3, 2011, eligible professionals, eligible hospitals, and critical access hospitals can register for the Medicare and Medicaid Electronic Health Records Incentive Programs. For more information, please visit the CMS Web site.

Posted by Bryan Fryar in CMS Announcements for Home Health   |  0 Comment(s)

Industry News: CMS Expands Claim Editing for Home Health Agencies
October 6th, 2010 2:42 PM

The Centers for Medicare & Medicaid Services (CMS) is expanding claim editing to meet the Social Security Act requirements for the attending physician when a plan of treatment is needed and submitted from an HHA. In this document the word ‘claim’ means both electronic and paper claims. The following are the only providers who can order/refer HHA beneficiary services: 

• Doctor of medicine or osteopathy; and
• Doctor of podiatric medicine. 

CMS claim editing is being expanded to verify that the attending physician on an HHA claim is eligible and is enrolled in Medicare’s PECOS. The editing expansion will be done in two phases: 

• Phase 1 (October 1, 2010 –December 31, 2010) - When a claim is received, CMS will determine if the attending physician is required for the billed service.  If the attending physician’s NPI is on the claim, Medicare will verify that the attending physician is on the national PECOS file. If the attending physician NPI is not on the national PECOS file during Phase 1, the claim will continue to process but a message will be included on the remittance advice notifying the billing provider that claims may not be paid in the future if the attending physician is not enrolled in Medicare or if the attending physician is not of the specialty eligible to be an attending physician for HHA services. 
• Phase 2 (On or after January 1, 2011) – As stated above, Medicare will determine if the attending physician’s NPI is required for the billed service. If the billed service requires an attending physician and the attending physician’s NPI is not on the claim, the claim will not be paid. If the attending physician’s NPI is on the claim, Medicare will also verify that the attending physician is on the national PECOS file. If the attending physician is on the PECOS file, but not as a specialty eligible to be an attending physician, the claim, during Phase 2, will not be paid. 

In both phases, FISS will use this process to determine if the attending physician on the claim matches the providers in the national PECOS file. If a match is found, the FISS will then compare the NPI, first letter of the first name and the first 4 letters of the last name of the matched record.  The claim is considered verified, if the NPI or names match for the attending physician. 

All providers should be verifying their enrollment on the CMS on-line enrollment systems known as Internet-based PECOS. 
 
Notes:  
- When CR6856 is implemented, the requirement (Transmittal 270, CR6093, Reporting NPIs for Secondary Providers, dated October 15, 2008) to use the billing provider’s NPI as the NPI of the attending physician, and the name of the attending physician, if the NPI of the attending physician cannot be determined by the billing provider is no longer valid. 
- A doctor of podiatric medicine may perform only plan of treatment functions that are consistent with the functions he or she is authorized to perform under State law. 

Additional Information
The official instruction (CR6856) issued to your Medicare FI, RHHI or A/B MAC is available at http://www.cms.gov/Transmittals/downloads/R778OTN.pdf on the CMS website.

Posted by Bryan Fryar in CMS Home Health   |  0 Comment(s)

Industry News: CMS Home Health CAHPS Update
October 6th, 2010 2:38 PM

Medicare-certified home health agencies are reminded that unless they qualify for an exemption from participating in the Home Health Care Consumer Assessment of Healthcare Providers and Systems

(HHCAHPS) Survey for the 2012 annual payment update (APU), they must conduct a dry run of the HHCAHPS Survey for at least one month in the third quarter of 2010 and implement the HHCAHPS Survey on an ongoing basis starting with the October 2010 sample month.

Home health agencies that do not meet the HHCAHPS reporting requirements for CY 2012 will have their 2012 annual payment update rates at 2% lower than they would otherwise be.

HHAs Have until October 21, 2010 to Initiate the Survey for the September Dry Run Month

There is still time for Medicare-certified agencies that have not yet taken any action on HHCAHPS to meet the participation requirements for the 2012 APU by conducting a dry run of the survey for the September 2010 sample month and begin the survey on an ongoing basis for the October 2010 sample month. The HHCAHPS Survey protocol is such that patients served by an agency one month are sampled the following month, and the survey is initiated with that sample within 21 days after the close of the sample month. Therefore, data collection for the September 2010 dry run data collection must begin by October 21, 2010.

To view the entire CMS report, go to

https://www.homehealthcahps.org/Announcement to HHAs about HHCAHPS Participation.pdf

Posted by Bryan Fryar in Home Health CAHPS   |  0 Comment(s)

Industry News: Medicare Timeliness Rules
September 21st, 2010 10:29 AM

Medicare Timeliness Rules

The recently passed Federal health care legislation included a provision to tighten the time frame for Medicare processing of claims.  This ruling was applicable to all Medicare providers, not just home health.  Below is a comparison of timeliness deadlines currently in effect vs. the new deadlines in effect after 01/01/2011.  All deadlines shown below are applied using the end or “through” date of the episodic claim, not the start date.

Old Timeliness Deadlines:

Claim Ends                                         Medicare Will Process & Pay If Submitted Before

10/01/2006 – or later                                  12/31/2008

10/01/2007 – or later                                  12/31/2009

10/01/2008 – or later                                  12/31/2010

Therefore, a claim with dates of service from 08/05/2008 thru 10/05/2008 could be submitted even as late as Dec 2010 and be paid if it had no errors.  This was an effective maximum range of 27 months to get your claims successfully processed.

New Timeliness Deadlines:

Claim Ends                                         Medicare Will Process & Pay If Submitted Before

01/01/2010                                                      01/01/2011

01/02/2010                                                      01/02/2011

01/03/2010                                                      01/03/2011

Therefore, starting next year, Medicare will shave 15 months off their timeliness deadlines!  And the new deadline changes to a constantly moving “window” of twelve months, not a static time period kept in place for a whole year as was the case previously.

Posted by Bryan Fryar in PPS Reimbursement Changes   |  0 Comment(s)

Industry News: CMS Home Health PPS Changes for 2011
August 3rd, 2010 8:35 AM

CMS issued a proposed rule to update the Medicare Home Health Prospective Payment (HH PPS) rates for calendar year (CY) 2011. Specifically, this rule proposes to update the rates by the home health market basket update minus 1 percentage point, per the Affordable Care Act (ACA) of 2010 (for a 1.4% increase), and update the case-mix reduction percentage for CY 2011 to 3.79% to account for the additional increases in case-mix not due to the underlying condition of the home health patient. The rule also proposes implementation approaches for ACA provisions which affect home health outlier payments and certification requirements for the Medicare home health and hospice benefits. In addition, this rule proposes changes to the HH capitalization requirements, proposes to add clarifying language to home health the therapy coverage regulations, and provides clarification regarding the quality reporting requirements for the CY 2012 HH PPS rate update as it relates to HHCAHPS.

Click on the link for the proposed changes from CMS:

http://edocket.access.gpo.gov/2010/2010-17753.htm

Posted by Bryan Fryar in PPS Reimbursement   |  0 Comment(s)

Industry News: CMS Changes Capitalization Requirements for New Home Health Providers
July 30th, 2010 9:34 AM

Recent Article about new Home Health Providers and IROF Letters from Palmetto GBA

Palmetto GBA released an article relating to the capitalization requirements for new Home Health providers.  It seems that CMS has directed Palmetto GBA to revisit their calculations. This means that many new providers are being asked to re submit confirmation of capitalization funds using the new capitalization calculation at a much higher rate.  CMS may have given Palmetto GBA direction that is not in line with the regulations that govern the capitalization requirements at 42 CFR 489.28.  Here are some concerns regarding the new requirements.

1.       The intermediary is asking for confirmation of the capitalization requirements after the provider agreement has been approved and entered into by CMS (i.e. the provider number has been issued).

2.       The CFR is clear that CMS must not enter into a provider agreement with a home health agency until the capitalization requirements have been validated, therefore the validation of the initial capitalization requirements must be done prior to the issuance of the provider number.

3.       Re-validating the capitalization requirements after the provider number has been issued is not in line with the CFR.

4.       CMS is free to re-verify the initial reserve prior to the issuance of the provider number; however using a different formula is not appropriate.  Palmetto GBA has not updated their capitalization calculator on its website to reflect the new higher capitalization requirements.

5.       Currently the Intermediary is taking up to 180 days to re-confirm a three month initial capitalization requirement before they issue the tie in notice that will allow the provider to bill.

6.       Palmetto is recalculating the capitalization requirements at rates that are sometimes 2-4 times greater than the initial requirement that was approved by Palmetto GBA.

The requirements from Palmetto GBA are listed on the Palmetto GBA website  www.palmettogba.com.  >From the home page, you will click on the link for "Regional Home Health & Hospice Intermediary (RHHI) on the left hand side of the screen.  You will then need to click on "Articles" on the left hand side of the screen.  From there you will need to click on "Home Health".  Scroll down and find the article entitled "Capitalization Requirement for Home Health Agencies (HHAs).  This should detail everything out for you.

Many new providers with pending 855A applications are receiving letters from Palmetto GBA requesting that they re-submit updated Initial Reserve Operating Funds (IROF) in the amount that Palmetto has calculated using the new calculations.  Based upon the projected visits submitted on the 855A, PGBA recalculates the amounts required to be in the bank prior to approving the 855A.  PGBA is using 3 comparable home health agencies in your area in the first year of service to calculate the capitalization amount. The comparable agencies are chosen considering such factors as geographic location and urban/rural status, number of visits, provider based vs. freestanding and proprietary vs. non-proprietary status.

Posted by Bryan Fryar in IROF LETTERS   |  0 Comment(s)