DHHS Office of Civil Rights Random HIPAA Audits (OCR)

The Department of Health and Human Services Office of Civil Rights will begin collecting a Pre-Audit Survey from 1200 HIPPA Covered Business Entities and Business Associates.   The survey will gather information about respondents to enable the OCR to assess the size, complexity, and fitness of respondent for an audit.  Information collected includes, data about the number of patient visits or insured lives, use of electronic information, revenue, and business locations.

For more information please use the following link.

http://www.gpo.gov/fdsys/pkg/FR-2014-02-24/pdf/2014-03830.pdf

CMS Allows Contractors to Deny Claims Not Under Review

CMS issued Change Request 8245 on February 5, 2014.  This will allow Medicare Administrative Contractors (MACs), Zone Program Integrity Contractors (ZPICs) and Recovery Audit Contractors (RACs) to deny even more claims.  This new rule allows the Medicare Contractors to deny claims which are related to the claims they are reviewing.

The rule states the contractors have discretion to deny other related claims submitted before or after the initial claim in question. If documentation associated with one claim can be used to validate another claim then those claims can be considered related.  The contractors are not required to request additional documentation for the related claims before issuing a denial for the related claims. 

For more information please use the following link.

http://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/Downloads/R505PI.pdf

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You must REGISTER to receive login and replay of the webinar.

Event link: http://events.constantcontact.com/register/event?llr=zbpwlrdab&oeidk=a07e90ku8n2bdfde246

Palmetto GBA Post Results of Hospice Probe Edits

Palmetto GBA performed a service-specific prepay probe review on Hospice claims with non-cancer diagnoses, billed with place of service Skilled Nursing Facility (HCPCS Q5004). The results for claims processed November 1, 2013 – January 31, 2014 are of 121 claims reviewed, 74 were either completely or partially denied, resulting in a claim denial rate of 61.1%. A total of $484,667.62 charges was reviewed with $171,363.21 denied, resulting in a charge denial rate of 35.3 percent. The top five reasons for denials are listed below.

1.     Plan of Care submitted does not cover the dates billed on a claim

2.     Documentation submitted does not support medical prognosis of six months or less

3.     The Face-to-Face Encounter documentation submitted was not valid

4.     The Plan of Care submitted was not valid

5.     Documentation submitted did not contain the physician narrative statement.

For more information please use the following link.

http://www.palmettogba.com/palmetto/providers.nsf/DocsCat/Providers~Jurisdiction%2011%20Home%20Health%20and%20Hospice~Medical%20Review~Results~9G3PA23121?open&navmenu=Medical^Review||||

CMS Expands Home Health Moratoriums

CMS has issued a six month moratorium on new Medicare Home Health Agencies located in the following areas:

City                                        Counties

Fort Lauderdale, FL           Broward

Detroit, MI                           Macomb, Monroe, Oakland, Washtenaw & Wayne

Dallas, TX                              Collin, Dallas, Denton, Ellis, Kaufman, Rockwall & Tarrant

Houston, TX                         Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery & Waller

CMS has extended the moratorium for another six months for Medicare Home Health Agencies located in the following areas:

City                                        Counties

Chicago, IL                            Cook, DuPage, Kane, Lake, McHenry & Will

Miami, FL                              Miami-Dade & Monroe

For more information please utilize the following link:

http://www.gpo.gov/fdsys/pkg/FR-2014-02-04/pdf/2014-02166.pdf

CMS Reverses Hospice Patient Vaccine Restrictions

CMS issued Transmittal 1339 on February 6, 2014 to reverse its previous rule that restricted payment for hospice beneficiary vaccines.  In the previous rule only the hospice would be eligible to receive payment for vaccines for hospice patients.  They have determined that this enforcement is too restrictive.  This removes the previous rule Change Request 8098.  Any provider will now be allowed to furnish and receive payment for vaccines to hospice beneficiaries.

For more information please utilize the following link:

http://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/Downloads/R1339OTN.pdf

Affordable Care Act Delayed Again

The Obama administration announced Monday afternoon that it is delaying the employer mandate for businesses with between 50 and 99 employees until January 2016.  It also made a change to businesses that have 100 or more employees.  They will still be required to cover their employees beginning on January 2015, but the percentage of employees covered by employer health insurance has dropped to 70%.

We will publish a link when the final rule is published