Comparative Billing Report on Home Health Services

The Comparative Billing Report is provided as a collaborative effort between the Medicare provider community and the Centers for Medicare & Medicaid Services to support best billing practices and effective management of Medicare Program Resources.  The report has several pitfalls.  The first is the report is not wage index adjusted; therefore home health agencies with higher wage indexes can be inappropriately targeted.  The second is the report is not risk based adjusted for patient ages, comorbidities, agency size or referral sources.

The report is based on paid claims with service dates from 1/1/2011 to 12/31/2011.  The report compares the home health agency averages to the state and the national averages for following items:

1.     The average number of home health visits per beneficiary

2.     The average number of PT visits per beneficiary

3.     The average number of OT visits per beneficiary

4.     The average number of SP visits per beneficiary

5.     The average Medicare payments per beneficiary

According to several national home health associations only about half of the home health agencies actually received the reports.   We would encourage every home health agency that has received a report to carefully review the data to determine their standings compared to their state and national averages.  We can be certain that reviewers and surveyors will utilize this data.

For more information please utilize the following link.

http://www.safeguard-servicesllc.com/cbr/documents/CBR022%20Home%20Health%20Services%20Sample.pdf

Med Pac Report Recommends 0% Rate Increase for Hospice in 2014

The report recommends that Congress should eliminate the update to the hospice payment rates for fiscal year 2014.  They continued a previous year recommendation to increase the per day payment rate at the beginning of the hospice episode and relatively lower payment per day as the length of the episode increases.  To include a relatively higher payment for the costs associated with patient death at the end of the episode. 

For more information please utilize the following link.

http://www.medpac.gov/documents/Mar13_EntireReport.pdf

Med Pac Report Recommends Copay for Home Health

The report recommends a $150 copayment for episodes that do not follow a hospital stay.  The copayment will not apply to LUPA episodes.  The number of Medicare Certified home health agencies increased form 11,654 in 2010 to 12,199 in 2011.  Total Medicare home health payments declined by 5 percent or $1 Billion from 2010 to 2011 based on decline in payments based on the base rate.  They recommend a revision in home health case-mix system to rely on patient characteristics to set payment for therapy and non-therapy services without the use of number of therapy visits.

For more information please utilize the following link.

http://www.medpac.gov/documents/Mar13_EntireReport.pdf

CGS Issues Instructions on Outpatient Therapy Cap

The Therapy Cap does not apply to Traditional PPS Home Health Part A and Part B Episodes.  The Therapy Cap applies to Home Health Therapy Episodes that are not part of the home health plan.  These are the Physical Therapy, Occupational Therapy and Speech Pathology visits that are billed as Outpatient Part B and are paid based on the fee schedule.  They also have a 20 percent copayment.

For the dates of services January 1, 2013 through December 31, 2013, all outpatient therapy claims submitted above the $3,700 threshold will be subject to prepayment medical review.  CGS will request the following documentation:

1.     Justification

2.     Evaluation or reevaluation(s) for Plan(s) of Care

3.     Certification of the Plan of Care

4.     Objective and measurable goals and any other documentation requirements of the Local Coverage Determination

5.     Progress reports

6.     Treatment notes

7.     Certification or Recertification for therapy services

8.     Any orders, if applicable, for additional therapy services

9.     Any additional information requested by CGS

For more information please utilize the following link.

http://www.cgsmedicare.com/hhh/pubs/news/2013/0313/cope21556.html

New England MAC Home Health Prepay Edit Results

The NHIC, CORP is the home health MAC for the New England Region of the United States.  They published the results of their three home health prepay edits for the period of July 1, 2012 to December 31, 2012.  The edits are listed below:

5AC01- billing of the home health resources groups (HHRGs) 3AFK*

5AC02- Billing the HHRG 1AFK*

5AC03-billing 5-7 visits for full episode payments

They issued 4,785 Additional Documentation Request (ADR) for the three edits.  Nine percent of the claims were denied because the home health agencies did not provide the medical records within the required time frame.  Approximately 48% of the reviewed claims were paid in full and 52% received denials.  The denial breakdown is listed below:

56% – Skilled observation was not reasonable and necessary

15% – no physician certification

14% – no support for the homebound status

5% – physician orders were not signed timely

5% – OASIS not documented

5% - Therapy services were determined not to require a therapist

For more information please utilize the following link.

http://www.medicarenhic.com/providers/articles/HHPrepayResults022013.pdf

CMS Explains Dates on Face-to-Face Encounter

CMS published Revised Questions & Answers to Home Health Face-to-Face Encounters on February 28, 2013. The answers to Question 16 and Question 17 states that home health agencies are allowed to title and date the face-to-face encounter documentation when the signed documentation is not titled and dated by the certifying physician. The home health agency can utilize the day they receive the documentation as the date.  It is not clear in the answers if the home health agency can utilize an earlier date such as the date that the physician actually signed the document.

For more information please utilize the following link.

http://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/HomeHealthPPS/Downloads/Home-Health-Questions-Answers.pdf

CMS PECOS Edits By May 1st

CMS MLN Matters article stated that CMS will instruct contractors to turn on Phase 2 of the denial edits on the following claims to check for a valid individual National Provider Identifier (NPI) and to deny the claim when this information is missing.  The MLN Matter states this will be effective May 1^st 2013. 

These denials apply to Medicare Part B claims including Durable Medical Equipment, Orthotics, and Supplies (DMEPOS) that have an ordering or referring physician/non-physician provider.  The also apply to Medicare Part A Home Health Agency claims that require an attending physician provider.

For more information please utilize the following link.

http://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/MedicareProviderSupEnroll/MedicareOrderingandReferring.html

CMS Updates Home Health Therapy Q&As

On February 28^th CMS updated the Therapy Questions and Answers.  This clarifies several issues regarding counting visits and assessment times.

1.  The classifications of Medicare covered and Medicare non-covered visits refer to how the visits would be reported on the claim.
2.  Home health agencies and therapist should not change the number of therapy visits a patient receives based on whether prior visits were covered or non-covered.
3. Patients should only receive the number of therapy visits called for in the patient’s plan of care.

For more information please utilize the following link.

http://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/HomeHealthPPS/Downloads/Therapy_Questions_and_Answers.pdf

VA Procedures to Enter Into Provider Agreements

On February 13, 2013 the Department of Veterans Affairs issued a proposed rule to allow the VA to utilize Medicare or State Medicaid procedures to enter into provider agreement to obtain extended care services from non-VA providers.  The proposed rules include home health care, palliative care, and non-institutional hospice care services as extended care services. 

The terms and rates of the provider’s separate Medicare provider agreement with CMS or agreement under State Medicaid plan, or, if a provider has agreements with both Medicare and under a State Medicaid Plan, the terms and rates would be the same as the agreement with the highest rates. 

For more information please utilize the following link.

http://www.gpo.gov/fdsys/pkg/FR-2013-02-13/pdf/2013-02993.pdf