Home Health & Hospice

CMS issues four home health policy change requests

Homecare Insider, August 11, 2014

CMS, hoping to promote compliance and cut down on program vulnerability, recently issued four change requests that address home health policy and claims processing issues. 

Change Request 8699, inspired by a recommendation written in a 2012 report by the Office of Inspector General, prevents duplicate payments when overlapping inpatient and home health claims are out of sequence. The request revises previous edits in Medicare claims systems to better prevent inappropriate payments when dates in home health claims overlap inpatient stays, especially swing bed stints (which are overlooked in standing policy measures) in hospitals, or in skilled nursing facilities. The change will take effect January 1, 2015, with an implementation date of January 5.
 
With Change Request 8710, which follows the same timeline, CMS seeks to prevent payments on Requests for Anticipated Payment (RAP) when home health beneficiaries are enrolled in Medicare Advantage (MA) plans.
 
Original Medicare claims for home health services are not payable when the home health episode dates fall entirely within an MA enrollment period, but RAPs are currently being paid for such episodes. With the change request, CMS states that these RAPs will be processed but paid at 0% if their service dates fall within MA enrollment periods.
 
The third change request, number 8813, enables Medicare Administrative Contractors to reject HH claims that list a manifestation code as a primary diagnosis.
 
Home health agencies are required by ICD-9-CM guidelines to report diagnosis codes on their claims. But an analysis of OASIS records and 2011 claims revealed that some agencies weren’t complying with these guidelines, especially ones specifying that certain codes require the underlying condition to be sequenced before the manifestation. Thus, with this change request, CMS hopes to facilitate greater compliance with codling guidelines for primary diagnoses. Like the first two change requests, this one will take effect January 1, 2015, with an implementation date of January 5.
 
Finally, Change Request 8818 clarifies the definition of “confined to the home” to more accurately reflect the corresponding definition delineated by the Social Security Act and to improve clarity and specificity surrounding its requirements. It will take effect September  2, 2014, with implementation beginning that day.
 
“This will prevent confusion, promote a clearer enforcement of the statute, and provide more definitive guidance to HHAs in order to foster compliance,” the document states.