CGS Initiates a Widespread Home Health Probe on Face-To-Face Encounter Documentation

As a result of numerous errors identified by both CGS and the Comprehensive Error Rate Testing (CERT) contractor related to home health face-to-face (FTF) encounter documentation, CGS will be initiating a widespread edit for all home health providers.  The topic code for this review will be 52xxT (‘xx’ denotes various numbers) and the edit will select start of care home health claims equally across the provider community.  Once selected, the claims will be reviewed for valid FTF encounter documentation, medical necessity compliance with all CMS coverage guidelines, correct billing and coding.

In addition, beginning July 8, 2013, CGS will begin requesting the initial certification face-to-face (FTF) encounter documentation is submitted with all home health claims selected for Medical Review. The Centers for Medicare & Medicaid Services (CMS) clarified the “face-to-face encounter requirement is necessary for the initial certification, which is a condition of payment. Without a complete initial certification, there cannot be subsequent episodes.” (CMS FAQ # 44)

The previous was from CGS website: http://bit.ly/18czZ7g. Site goes into additional details of examples of what should be included and what would be considered insufficient within FTF documentation. The site also recommends actions for agencies to prepare for this edit which will come in the form of an Additional Documentation Request (ADR) letter. They recommend:

1. Checking for claims in the Additional Development Request status/location in the Fiscal Intermediary Standard System (FISS) at least weekly.
2. Prior to submitting your documentation to CGS, ensure that it undergoes a review by a clinician at your agency.
3. Mailing your documentation for claims selected to CGS by day 30.

CMS Issues ICD-9 to ICD-10 Transition Claims Instructions

CMS published a special MedLearn Matters article addressing ICD-9 to ICD-10 transition claims instructions. The article SE1325, addresses institutional provider which includes home health and hospice providers. Providers will be required to split claims so that all ICD-9 codes remain on one claim with Dates of Service (DOS) through September 30, 2014 and all ICD-10 codes placed on the other claim with DOS beginning October 1, 2014 and later. While the processing requirements for hospice should be clean because they bill on a monthly basis, home health has several challenges and issues to clarify.

Since home health does episodic billing, will all Medicare and Medicaid patients be required to be discharged and readmitted at their first billable visit on or after October 1, 2014? Under important details in the article, Note 1 states that “creating multiple/interim claims on a single encounter is not a new concept and that these instructions will apply to relatively few claims that span this single implementation date (October 1, 2014) will be impacted.” This could impact 1/6th of all claims for 2014 impacting over 1 million Medicare episodes alone, so this would not affect a “relatively few claims”.

There is a potential that CMS would fall back to the logic stated in Note 2 and treat the episode as a single service; however not likely because of the problems this causes. If an episode starts before October 1, 2014 and the resumption of care is completed after, which code set would you use? ICD-10 should be used, then the diagnosis data will not be consistent across the episode. If ICD-9 is used, then agencies will be required to code certain claims under each of the ICD data sets during an extended period. This would result in increased confusion amongst coders and potential errors.

CMS also needs to clarify which OASIS data set (M item), is tied to the DOS; M0030 (Start of Care (SOC) Date) or M0090 (Date Assessment Completed). CMS has implemented different program changes based on each item depending on the circumstance. M0030 makes sense except in the case of recertification, since that is not used. M0090 can be beneficial, as it allows a few days of wiggle room around the October 1st implementation date. In the case of SOC, this would allow for SOC to be completed as early as September 27th, considering that October 1st will occur mid-week. This could be helpful especially if all Medicare and Medicaid patients will need to be discharged and readmitted.

Either scenario would not be pleasant. Ideally, there should be a 60 day window on either side of October 1, 2014 to allow for entering ICD-9 or ICD-10 codes. This would put the burden on the government. The agencies would have the ability to do what is best for their staff and the patients. The government would need to handle processing both types of claims during this time.  This would decrease the burden on the agencies.  There has not been any talk of this and it does appear the burden will fall onto the agencies.



 

Four cooperating parties approved statements clarifying the use of external cause and unspecified codes in ICD-10-CM

The four cooperating parties responsible for the ICD-10-CM/PCS and ICD-9-CM Coding Guidelines, which includes AHIMA, along with the American Hospital Association, the Centers for Medicare & Medicaid Services, and the National Center for Health Statistics, have approved two statements clarifying the use of external cause and unspecified codes in ICD-10-CM. Read the statements.

From AHIMA E-Alert 5/16/2013

New Home Health Claims Data Requirements

CMS announced plans to require home health agencies to report new claims data. See Transmittal 2680.

For episodes beginning on or after July 1, 2013, HHAs must report where home health services were provided. The following codes are used for this reporting:

Q5001: Hospice or home health care provided in patient’s home/residence

Q5002: Hospice or home health care provided in assisted living facility

Q5009: Hospice or home health care provided in place not otherwise specified (NO)

The location where services were provided must always be reported along with the first billable visit in an HH PPS episode. In addition to reporting a visit line using the G codes as described above, HHAs must report an additional line item with the same revenue code and date of service, reporting one of the three Q codes (Q5001, Q5002, and Q5009), one unit and a nominal covered charge (e.g., a penny). If the location where services were provided changes during the episode, the new location should be reported with an additional line corresponding to the first visit provided in the new location.

Nurse Recognition Program Seeking 2013 Nominations

HHNA is currently accepting nominations to honor and recognize home care and hospice nurses from across the country. Agencies may nominate any registered nurse to represent their state for 2013. Nominations will be reviewed by the Nurse Recognition Program Selection Committee and one nurse will be recognized from each state.

 

To see examples of stories from previous issues of CARING, you can click here. To fill out the online nomination form click here. The deadline for submission has been extended to April 8, 2013.

Take Our 2nd Annual ICD-10 Preparedness Survey

For the second year in a row, Daymarck is conducting a research study on  ICD-10 implementation preparedness. By participating, you’ll be registered in a drawing for a $100 gift card to Shutterfly, in honor of the National Association for Home Care (NAHC) Annual Meeting & Exposition: Making Memories and Magic in Orlando, Florida, October 21-25, 2012. And, more importantly, your feedback will help the industry gain important insights as we transition to ICD-10 in 2014.

We will share this year's survey results on our blog and website. In the meantime, read the findings from last year's survey - and we hope to see you at NAHC National.

NAHC Annual Meeting: Making Memories in Orlando

NAHC's Annual Meeting & Exposition: Making Memories & Magic in Orlando
October 21 - 25, 2012

In the midst of an election year, it is vital that we talk about homecare and the importance it provides to millions of Americans. And what better time to do this than at NAHC's Annual Meeting & Exposition in Orlando, Florida? Both President Obama and former Governor Romney are scheduled to speak and are expected to share their thoughts on the future of homecare. The list of keynote speakers this year includes other influential healthcare leaders like Donna Shalala, Professor of Political Science and President of the University of Miami and Former U.S. Secretary of Health and Human Services and Senator Susan M. Collins (R-ME).

Daymarck is pleased to be exhibiting again this year at NAHC Annual, sharing our message of how homecare is an important part of the solution to the healthcare crisis. Back in July at NAHC's Financial Executives' Conference, we met with hundreds of financial executives to talk about compliance, coding, and of course, ICD-10. It was exciting to meet with small and large agencies to show them how Daymarck provides peace of mind and cost savings so that they can do what they do best - provide excellent patient care. We look forward to meeting new faces and seeing old friends in October and continuing those conversations.

Please come visit us at booth #316 where we’ll be administering our 2^nd annual ICD-10 preparedness survey and giving out disposable cameras to participants. We’ll also be raffling off a $100 gift card to Shutterfly so that you can share your memories with friends and family.

If you can’t make this year’s convention, you can always attend virtually by keeping up with us here and on Facebook and Twitter. Let's make memories together!