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<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong><strong>Medicare</strong> A <strong>Newsline</strong>Important Information from Cahaba Government Benefit Administrators ® , LLC (Cahaba)<strong>April</strong> 1, <strong>2010</strong> Vol. 17, No. 7This bulletin should be shared with all health care practitioners and managerialmembers of the provider/supplier staff. Bulletins are available at no cost from ourWeb site at: www.cahabagba.comThe Inside StoryNews from CMSNews Flash Messages from CMS ........................ 1Additional ICD-9 Codes Analysis andProcessing Direction (InstitutionalClaims Only) ....................................................... 4July <strong>2010</strong> Quarterly Average SalesPrice (ASP) <strong>Medicare</strong> Part B Drug PricingFiles and Revisions to Prior QuarterlyPricing Files ......................................................... 5Correction to Processing of Non-CoveredRevenue Codes—Revised ................................... 6Point of Origin for Admission or VisitCodes Update to the UB-04 (CMS-1450)Manual Code List—Revised ................................ 8Quarterly Provider Update ................................. 10Coding Patient Transfers under the<strong>Home</strong> <strong>Health</strong> Prospective PaymentSystem (HH PPS) .............................................. 11<strong>April</strong> <strong>2010</strong> Update of the Hospital OutpatientProspective Payment System (OPPS)................ 13<strong>April</strong> <strong>2010</strong> Integrated Outpatient CodeEditor (I/OCE) Specifications Version 11.0 ...... 20Implementation of <strong>Home</strong> <strong>Health</strong> AgencyProgram Safeguard Provisions—Revised .......... 22Questions and Answers on ReportingPhysician Consultation Services ........................ 23News from CahabaSuspended Claims—What YouNeed to Know ...................................................... 31Submitting <strong>Medicare</strong> SecondaryPayer (MSP) Claims Where a DeductibleOr Coinsurance Payment is Due to thePrimary Insurer .................................................... 33Clarification on Submitting <strong>Medicare</strong>Secondary Payer (MSP) Claims andAdjustments and Reason Code 31265 ................. 35Clinical Frequently Asked Questions (FAQs)for <strong>Home</strong> <strong>Health</strong> and <strong>Hospice</strong> ............................. 36Compliance and Enforcement <strong>Medicare</strong>Drug Integrity Contractor (C&E MEDIC)and Benefit Integrity <strong>Medicare</strong> DrugIntegrity Contractor (BI MEDIC) ........................ 38Availability of the Provider ContactCenter (PCC) ....................................................... 39<strong>Medicare</strong> Credit Balance QuarterlyReminder ............................................................. 40The Inside Story Continues on the Next PageStay Informed! Subscribe to the Cahaba E-mailNotification Service to receive the most current homehealth and hospice <strong>Medicare</strong> information. This service isfree. When you subscribe, we’ll send you periodic e-mailstelling you about new or updated <strong>Medicare</strong> information.Key for Icons: <strong>Home</strong> <strong>Health</strong> Providers <strong>Hospice</strong> ProvidersThe <strong>Medicare</strong> A <strong>Newsline</strong> provides information for those providers who submit claims to Cahaba Government BenefitAdministrators ® , LLC as their Fiscal Intermediary or Regional <strong>Home</strong> <strong>Health</strong> Intermediary. The CPT codes, descriptors andother data only are copyright © <strong>2010</strong> American Medical Association. All rights reserved. Applicable FARS/DFARS apply.


News from Cahaba (continued)New Fiscal Intermediary StandardSystem (FISS) Inquiry Menu Screen for<strong>Home</strong> <strong>Health</strong> Providers ........................................ 40Resolving Reason Code U538F ........................... 44<strong>Medicare</strong> Forum ................................................... 45New Summary of <strong>Hospice</strong> Changes QuickReference Tool .................................................... 46Clarification on Reporting of SocialWorker Phone Calls by <strong>Hospice</strong>s ........................ 46Length of Stay Proves to Be a TopVulnerability in <strong>Hospice</strong> Medical Review ........... 47Cahaba Learning Corner .................................................... 49DisclaimerThis educational material was prepared as a tool to assist <strong>Medicare</strong> providers and other interested parties and is not intended togrant rights or impose obligations. Although every reasonable effort has been made to assure the accuracy of the informationwithin this module, the ultimate responsibility for the correct submission of claims lies with the provider of services. Cahabaemployees, agents, and staff make no representation, warranty, or guarantee that this compilation of <strong>Medicare</strong> information iserror-free and will bear no responsibility or liability for the results or consequences of the use of these materials. Thispublication is a general summary that explains certain aspects of the <strong>Medicare</strong> Program, but is not a legal document. Theofficial <strong>Medicare</strong> Program provisions are contained in the relevant laws, regulations, and rulings.We encourage users to review the specific statues, regulations and other interpretive materials for a full and accurate statementof their contents. Although this material is not copyrighted, CMS prohibits reproduction for profit making purposes.American Medical Association Notice and DisclaimerCPT codes, descriptors and other data only are copyright <strong>2010</strong> American Medical Association. All rights reserved.ICD-9 NoticeThe ICD-9-CM codes and descriptors used in this material are copyright <strong>2010</strong> under uniform copyright convention. All rightsreserved.News Flash Messages from CMS for <strong>Home</strong> <strong>Health</strong> and <strong>Hospice</strong> ProvidersJoin CMS Provider ListservsFor the latest information on joining the <strong>Medicare</strong> Fee-For-Service (FFS) provider listservs, the MLNMatters Articles ® or MLN Educational Products listservs, and other listservs available through the Centersfor <strong>Medicare</strong> & Medicaid Services (CMS), please click onhttp://www.cms.hhs.gov/prospmedicarefeesvcpmtgen/downloads/Provider_Listservs.pdf on the CMS Website.<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 1<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


H1N1 Influenza Immunizations<strong>Medicare</strong> will cover immunizations for H1N1 influenza also called the “swine flu.” There will be nocoinsurance or copayment applied to this benefit, and beneficiaries will not have to meet their deductible.For more information, go to http://www.cms.hhs.gov/H1N1 on the CMS Web site.<strong>Medicare</strong> Contractor Provider Satisfaction Survey (MCPSS)The fifth annual national administration of the <strong>Medicare</strong> Contractor Provider Satisfaction Survey (MCPSS)is now underway. If you received a letter indicating that you were randomly selected to participate in the<strong>2010</strong> MCPSS, CMS urges you to take a few minutes to go online and complete this important survey via asecure Internet website. Responding online is a convenient, easy, and quick way to provide CMS with yourfeedback on the performance of the FFS contractor that processes and pays your <strong>Medicare</strong> claims. Surveyquestionnaires can also be submitted by mail, secure fax, and over the telephone. To learn more about theMCPSS, please visit the CMS MCPSS Web site http://www.cms.hhs.gov/mcpss or read the CMS SpecialEdition MLN Matters article, SE1005, located athttp://www.cms.hhs.gov/MLNMattersArticles/downloads/SE1005.pdf on the CMS Web site.<strong>Medicare</strong> Crossover ProcessThe Centers for <strong>Medicare</strong> & Medicaid Services (CMS) reminds all providers, physicians, and suppliers toallow sufficient time for the <strong>Medicare</strong> crossover process to work—approximately 15 work days after<strong>Medicare</strong>’s reimbursement is made, as stated in MLN Matters Article SE0909(http://www.cms.hhs.gov/MLNMattersArticles/downloads/SE0909.pdf) — before attempting to balance billtheir patients’ supplemental insurers. That is, do not balance bill until you have received writtenconfirmation from <strong>Medicare</strong> that your patients’ claims will not be crossed over, or you have received aspecial notification letter explaining why specified claims cannot be crossed over. Remittance AdviceRemark Codes MA18 or N89 on your <strong>Medicare</strong> Remittance Advice (MRA) represent <strong>Medicare</strong>’s intentionto cross your patients’ claims over.<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 2<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


<strong>Medicare</strong> Preventive Services Quick Reference Information ChartsThe <strong>Medicare</strong> Preventive Services Quick Reference Information Charts have been updated and are nowavailable in downloadable format. This includes the following charts:• Quick Reference Information: <strong>Medicare</strong> Preventive Services: This two-sided reference chart provideshealth care providers with coverage, coding, and payment information on the many preventive servicescovered by <strong>Medicare</strong>.• Quick Reference Information: <strong>Medicare</strong> Immunization Billing: This two-sided reference chart providescoverage, coding and payment information on seasonal influenza, pneumococcal, and Hepatitis Bvaccinations covered by <strong>Medicare</strong>.• Quick Reference Information: The ABCs of Providing the Initial Preventive Physical Examination(IPPE): This two-sided reference chart provides a checklist of the elements of an IPPE, as well ascoding information and frequently asked questions.To view the revised charts, please visit the “Preventive Services Educational Products” page at:http://www.cms.hhs.gov/MLNProducts/35_PreventiveServices.asp and select the “Educational Products”link in the “Downloads” section.Hard copies of all three charts will be available at a later date.Revised <strong>Home</strong> <strong>Health</strong> Prospective Payment System Fact SheetThe revised <strong>Home</strong> <strong>Health</strong> Prospective Payment System Fact Sheet (January <strong>2010</strong>), which providesinformation about coverage of home health services and elements of the <strong>Home</strong> <strong>Health</strong> Prospective PaymentSystem, is now available in downloadable format from the Centers for <strong>Medicare</strong> & Medicaid Services<strong>Medicare</strong> Learning Network at http://www.cms.hhs.gov/MLNproducts/downloads/<strong>Home</strong>HlthProsPaymt.pdfon the CMS Web site.Revised Hospital Outpatient Prospective Payment System Fact SheetThe revised Hospital Outpatient Prospective Payment System Fact Sheet (January <strong>2010</strong>), which providesgeneral information about the Hospital Outpatient Prospective Payment System, ambulatory paymentclassifications, and how payment rates are set, is now available in downloadable format from the Centers for<strong>Medicare</strong> & Medicaid Services (CMS) <strong>Medicare</strong> Learning Network athttp://www.cms.hhs.gov/MLNProducts/downloads/HospitalOutpaysysfctsht.pdf on the CMS Web site.<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 3<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


Revised <strong>Medicare</strong> Physician Fee Schedule Fact SheetThe <strong>Medicare</strong> Physician Fee Schedule Fact Sheet (March <strong>2010</strong>)has been revised to include informationabout the two month zero percent (0%) update to the <strong>2010</strong> <strong>Medicare</strong> Physician Fee Schedule (MPFS)effective for dates of service January 1, <strong>2010</strong>, through March 31, <strong>2010</strong>. This fact sheet, which also providesinformation about MPFS payment rates and the MPFS payment rates formula, is available in downloadableformat from the Centers for <strong>Medicare</strong> & Medicaid Services <strong>Medicare</strong> Learning Network at:http://www.cms.hhs.gov/MLNProducts/downloads/MedcrePhysFeeSchedfctsht.pdfNews from CMS for <strong>Home</strong> <strong>Health</strong> and <strong>Hospice</strong> ProvidersAdditional ICD-9 Codes Analysis and Processing Direction (Institutional Claims Only)The Centers for <strong>Medicare</strong> & Medicaid Services (CMS) has provided the following <strong>Medicare</strong> LearningNetwork (MLN) Matters article. This MLN Matters article and other CMS articles can be found on theCMS Web site at: http://www.cms.hhs.gov/MLNMattersArticlesMLN Matters ® Number: MM6851 Related Change Request (CR) #: 6851Related CR Release Date: March 5, <strong>2010</strong> Effective Date: January 1, 2011Related CR Transmittal #: R648OTN Implementation Date: January 3, 2011Provider Types AffectedThis article is for hospitals, home health agencies, skilled nursing facilities, and other providers who billfiscal intermediaries, (FIs), regional home health intermediaries (RHHIs), or <strong>Medicare</strong> administrativecontractors (A/B MACs) for providing institutional services to <strong>Medicare</strong> beneficiaries.What You Need to KnowCR 6851, from which this article is taken, announces that (effective January 1, 2011) CMS is expanding thenumber of ICD-9 diagnosis and procedure codes processed on institutional claims. Please see the“Background” section, below for details.BackgroundIn CR 6797 (Institutional Online Screens Changes for Version 005010 Related to ICD-10, InstitutionalOnline Screens Changes for Additional Medical Codes, and Changes Needed to Process Additional MedicalCodes - Analysis Only), released on January 8, <strong>2010</strong>, CMS announced the need to perform an analysis ofthe institutional online Fiscal Intermediary Standard System (FISS) and the National Claims History (NCH)System to determine what changes are required to allow for additional, and larger, ICD-9 diagnosis andprocedure codes. You can find CR 6797 at http://www.cms.hhs.gov/transmittals/downloads/R618OTN.pdfon the CMS Web site.<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 4<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


CR 6851 continues and completes this process by announcing that, effective January 1, 2011, CMS isexpanding the number of ICD-9 diagnosis and procedure codes it will accept and process on institutionalclaims.This expansion is being done to allow for: 1) Adding additional ICD-9 other (secondary) diagnosis codes(from 8 codes to 24 codes) as well as additional associated present on admission (POA) codes; and 2)Adding additional ICD-9 other (secondary) procedure codes (from 5 codes to 24 codes).Note: CMS will be able to accept and process additional ICD-9/POA codes effective January 1, 2011.Additional InformationYou can find the official instruction, CR 6851, issued to your FI, RHHI, or A/B MAC by visitinghttp://www.cms.hhs.gov/Transmittals/downloads/R648OTN.pdf on the CMS Web site.If you have questions regarding this issue, refer to the “Contact Us” page of our Web site and select “PhoneUs” to call the Provider Contact Center.DisclaimerThis article was prepared as a service to the public and is not intended to grant rights or impose obligations. This article maycontain references or links to statutes, regulations, or other policy materials. The information provided is only intended to be ageneral summary. It is not intended to take the place of either the written law or regulations. We encourage readers to review thespecific statutes, regulations and other interpretive materials for a full and accurate statement of their contents.July <strong>2010</strong> Quarterly Average Sales Price (ASP) <strong>Medicare</strong> Part B Drug Pricing Filesand Revisions to Prior Quarterly Pricing FilesThe Centers for <strong>Medicare</strong> & Medicaid Services (CMS) has provided the following <strong>Medicare</strong> LearningNetwork (MLN) Matters article. This MLN Matters article and other CMS articles can be found on theCMS Web site at: http://www.cms.hhs.gov/MLNMattersArticlesMLN Matters ® Number: MM6805 Related Change Request (CR) #: 6805Related CR Release Date: February 19, <strong>2010</strong> Effective Date: July 1, <strong>2010</strong>Related CR Transmittal #: R1922CP Implementation Date: July 6, <strong>2010</strong>Provider Types AffectedAll physicians, providers and suppliers who submit claims to <strong>Medicare</strong> contractors (<strong>Medicare</strong> administrativecontractors (MACs), fiscal intermediaries (FIs), carriers, durable medical equipment <strong>Medicare</strong>administrative contractors (DME MACs) or regional home health intermediaries (RHHIs)) are affected bythis issue.What You Need to KnowThis article is based on CR 6805 which instructs <strong>Medicare</strong> contractors to download and implement the July<strong>2010</strong> ASP drug pricing file for <strong>Medicare</strong> Part B drugs; and if released by CMS, also the revised <strong>April</strong> <strong>2010</strong>,January <strong>2010</strong>, October 2009, and July 2009 files. <strong>Medicare</strong> will use the July <strong>2010</strong> ASP and not otherwise<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 5<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


classified (NOC) drug pricing files to determine the payment limit for claims for separately payable<strong>Medicare</strong> Part B drugs processed or reprocessed on or after July 6, <strong>2010</strong>, with dates of service July 1, <strong>2010</strong>,through September 30, <strong>2010</strong>.BackgroundThe ASP methodology is based on quarterly data submitted to CMS by manufacturers. CMS will supplycontractors with the ASP and NOC drug pricing files for <strong>Medicare</strong> Part B drugs on a quarterly basis.Payment allowance limits under the OPPS are incorporated into the Outpatient Code Editor (OCE) throughseparate instructions.The following table shows how the quarterly payment files will be applied:FilesEffective Dates of ServiceJuly <strong>2010</strong> ASP and NOC files July 1, <strong>2010</strong>, through September 30, <strong>2010</strong><strong>April</strong> <strong>2010</strong> ASP and NOC files <strong>April</strong> 1, <strong>2010</strong>, through June 30, <strong>2010</strong>January <strong>2010</strong> ASP and NOC files January 1, <strong>2010</strong>, through March 31, <strong>2010</strong>October 2009 ASP and NOC files October 1, 2009, through December 31, 2009July 2009 ASP and NOC files July 1, 2009, through September 30, 2009Additional InformationIf you have questions regarding this issue, refer to the “Contact Us” page of our Web site and select “PhoneUs” to call the Provider Contact Center. The official instruction (CR 6805) issued to your <strong>Medicare</strong> MAC,carrier, and/or FI may be found at http://www.cms.hhs.gov/Transmittals/downloads/R1922CP.pdf on theCMS Web site.DisclaimerThis article was prepared as a service to the public and is not intended to grant rights or impose obligations. This article maycontain references or links to statutes, regulations, or other policy materials. The information provided is only intended to be ageneral summary. It is not intended to take the place of either the written law or regulations. We encourage readers to review thespecific statutes, regulations and other interpretive materials for a full and accurate statement of their contents.Correction to Processing of Non-Covered Revenue Codes—RevisedThe Centers for <strong>Medicare</strong> & Medicaid Services (CMS) has issued a revision to the <strong>Medicare</strong> LearningNetwork (MLN) Matters article, “Correction to Processing of Non-Covered Revenue Codes,” which waspublished in the March 1, <strong>2010</strong>, <strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>Medicare</strong> A <strong>Newsline</strong>. This MLN Matters articleand other CMS articles can be found on the CMS Web site at:http://www.cms.hhs.gov/MLNMattersArticlesMLN Matters ® Number: MM6774 Revised Related Change Request (CR) #: 6774Related CR Release Date: March 5, <strong>2010</strong> Effective Date: July 1, <strong>2010</strong>Related CR Transmittal #: R1928CP Implementation Date: July 6, <strong>2010</strong><strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 6<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


Note: This article was revised on March 5, <strong>2010</strong>, to reflect the release of a revised Change Request. Thetransmittal number, CR release date and the link to the transmittal were changed. All other information isthe same.Provider Types AffectedAll providers and suppliers submitting claims to <strong>Medicare</strong> contractors (fiscal intermediaries (FI), regionalhome health intermediaries (RHHI), and A/B <strong>Medicare</strong> administrative contractors (MAC)) for <strong>Medicare</strong>beneficiaries are affected.Provider Action NeededThis article, based on CR 6774, explains that claims containing an institutional service line submitted with arevenue code that is not valid for <strong>Medicare</strong> billing will only be returned to the provider if the line issubmitted with covered charges or the claim indicates that beneficiary liability may apply. Affectedproviders should ensure that their billing staffs are aware of these changes that are effective for claimsprocessed on or after July 6, <strong>2010</strong>.BackgroundIn October 2004, CMS issued Transmittal 332, CR 3416, entitled “New Policy and Refinements on BillingNon-covered Charges to Fiscal Intermediaries (FIs).” This transmittal completed a series of instructionsthat established requirements for processing non-covered charges on institutional claims and for correctlyassigning financial liability for non-covered charges. One underlying premise of those instructions was thatany institutional provider should be able to submit a claim line with non-covered charges for any servicethat the provider delivered and that <strong>Medicare</strong> systems should process that non-covered line to completionwithout payment. This premise is consistent with the goals of administrative simplification and increasingautomated coordination of benefits across various payers.Those instructions contained one significant omission in that they did not take into account the fact that<strong>Medicare</strong> systems currently determine whether a particular revenue code is valid for <strong>Medicare</strong> billingwithout regard to whether the revenue code line is submitted as non-covered. Each <strong>Medicare</strong> contractor thatprocesses institutional claims maintains a revenue code file which lists the revenue codes that are valid foreach type of bill. If a provider submits a claim with a revenue code that is not listed on the revenue code fileas valid for the submitted type of bill, the claim is returned to the provider. This should happen when therevenue code line is submitted with covered charges, but the claim should not be returned if it is submittedentirely with non-covered charges.<strong>Medicare</strong> systems will be changed so that a revenue code line submitted with entirely non-covered chargesand no indication that beneficiary liability may apply will not be returned to the provider. Such claimsshould be processed to completion without payment, assigning liability to the provider. CR 6774 revises<strong>Medicare</strong> systems to ensure this outcome. CR 6774 also contains miscellaneous clarifications to Chapter 1,General Billing Requirements, in the <strong>Medicare</strong> Claims Processing Manual and those clarifications, whichdo not change any <strong>Medicare</strong> policies, are attached to CR 6774.Additional InformationIf you have questions regarding this issue, refer to the “Contact Us” page of our Web site and select “PhoneUs” to call the Provider Contact Center.The official instruction, CR 6774, issued to your <strong>Medicare</strong> contractor regarding this change may be viewedat http://www.cms.hhs.gov/Transmittals/downloads/R1928CP.pdf on the CMS Web site.<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 7<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


DisclaimerThis article was prepared as a service to the public and is not intended to grant rights or impose obligations. This article maycontain references or links to statutes, regulations, or other policy materials. The information provided is only intended to be ageneral summary. It is not intended to take the place of either the written law or regulations. We encourage readers to review thespecific statutes, regulations and other interpretive materials for a full and accurate statement of their contents.Point of Origin for Admission or Visit Codes Update to the UB-04 (CMS-1450) ManualCode List—RevisedThe Centers for <strong>Medicare</strong> & Medicaid Services (CMS) has issued a revision to the <strong>Medicare</strong> LearningNetwork (MLN) Matters article, “Point of Origin for Admission or Visit Codes Update to the UB-04 (CMS-1450) Manual Code List,” which was published in the March 1, <strong>2010</strong>, <strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>Medicare</strong> A<strong>Newsline</strong>. This MLN Matters article and other CMS articles can be found on the CMS Web site at:http://www.cms.hhs.gov/MLNMattersArticlesMLN Matters ® Number: MM6801 Revised Related Change Request (CR) #: 6801Related CR Release Date: March 9, <strong>2010</strong> Effective Date: July 1, <strong>2010</strong>Related CR Transmittal #: R1929CP Implementation Date: July 6, <strong>2010</strong>Note: This article was revised on March 12, <strong>2010</strong>, to reflect the revised CR 6801 issued on March 9,<strong>2010</strong>. Reference to article MM6757 was added to the table on pages 2-4. Also, the CR transmittalnumber, release date, and the Web address for accessing CR 6801 were changed. All otherinformation remains the same.Provider Types AffectedThis article impacts providers submitting claims to <strong>Medicare</strong> contractors (fiscal intermediaries (FIs), A/B<strong>Medicare</strong> administrative contractors (A/B MACs), and/or regional home health intermediaries (RHHIs)) forservices provided to <strong>Medicare</strong> beneficiaries.Provider Action NeededSTOP – Impact to YouThis article is based on CR 6801 which updates the Point-of-Origin for Admission or Visit Codes to the UB-04 (CMS-1450) Manual Code List.CAUTION – What You Need to KnowThe following Point of Origin for Admission or Visit (formerly Source of Admission) codes (discontinuedby the National Uniform Billing Committee (NUBC)) will be discontinued for use by <strong>Medicare</strong> Systems:‘7’ - Discontinued Effective July 1, <strong>2010</strong>; ‘B’ - Discontinued Effective July 1, <strong>2010</strong>; and ‘C’ - DiscontinuedEffective July 1, <strong>2010</strong>. In addition, Point of Origin for Admission or Visit code ‘1’ example and definitionlanguage has been updated, though the processing of code ‘1’ is not being changed. Also, Point of Originfor Admission or Visit code ‘2’ definition language has been updated, though the processing of code ‘2’ isnot being changed.<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 8<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


GO – What You Need to DoBe sure billing staff are aware of these changes.BackgroundCMS <strong>Health</strong> Insurance Claim Form (UB-04) and its electronic equivalence have a required field (FormLocator (FL) 15) on all institutional inpatient claims and outpatient registrations for diagnostic testingservices. FL 15 indicates the point of patient origin for the admission or visit of the claim being billed.The Point of Origin for Admission or Visit (formerly Source of Admission) codes ‘7’, ‘B’, and ‘C’(discontinued by the National Uniform Billing Committee (NUBC)) will be discontinued for use by theFiscal Intermediary Standard System (FISS) effective July, 1, <strong>2010</strong>. In addition, Point of Origin forAdmission or Visit code ‘1’ example and definition language has been updated (the processing of code ‘1’is not being changed), and Point of Origin for Admission or Visit code ‘2’ definition language has beenupdated (the processing of code ‘2’ is not being changed). These revisions are shown in the following table:Form Locator (FL) 15 – Point of Origin for Admission or VisitRequired: The provider enters the code indicating the source of the referral for this admission or visit.Code Structure:1 Non-<strong>Health</strong> Care FacilityPoint of Origin (PhysicianReferral) Effective July 1,<strong>2010</strong>: Non-<strong>Health</strong> CareFacility Point of OriginUsage note: Includes patientscoming from home, aphysician’s office, orworkplace. Effective July 1,<strong>2010</strong>: Examples: Includespatients coming from home orworkplace.Inpatient: The patient was admitted to this facility upon an order ofa physician.Effective July 1, <strong>2010</strong>: Inpatient: The patient was admitted to thisfacility.Outpatient: The patient presents to this facility with an order froma physician for services or seeks scheduled services for which anorder is not required (e.g., mammography). Includes non-emergentself referrals.Effective July 1, <strong>2010</strong>: Outpatient: The patient presented to thisfacility for outpatient services.2 Clinic or Physician’s Office Inpatient: The patient was admitted to this facility as a transferfrom a freestanding or non-freestanding clinic. Effective July 1,<strong>2010</strong>: Inpatient: The patient was admitted to this facility.Outpatient: The patient was referred to this facility for outpatient orreferenced diagnostic services.Effective July 1, <strong>2010</strong>: Outpatient: The patient presented to thisfacility for outpatient services.7 Emergency Room (ER) Inpatient: The patient was admitted to this facility after receivingservices in this facility’s emergency room department.Discontinued July 1, <strong>2010</strong><strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 9<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


BCTransfer From Another<strong>Home</strong> <strong>Health</strong> AgencyReadmission to Same<strong>Home</strong> <strong>Health</strong> AgencyThe patient was admitted to this home health agency as a transfer fromanother home health agency Discontinued July 1, <strong>2010</strong>. See conditioncode 47 as discussed in the article athttp://www.cms.hhs.gov/MLNMattersArticles/downloads/MM6757.pdfThe patient was readmitted to this home health agency within the samehome health episode period. Discontinued July 1, <strong>2010</strong>. See conditioncode 47 as discussed in the article athttp://www.cms.hhs.gov/MLNMattersArticles/downloads/MM6757.pdfon the CMS Web site.Note From Cahaba: <strong>Home</strong> health provides should also refer to the <strong>Medicare</strong> Learning Network (MLN)Matters article MM6757, entitled, “Coding Patient Transfers under the <strong>Home</strong> <strong>Health</strong> Prospective PaymentSystem (HH PPS)”, which is found later in this newsletter. This article is based on Change Request 6757and provides additional changes to Point of Origin for Admission or Visit (formerly Source of Admission)codes.Additional InformationThe official instruction, CR 6801, issued to your FI, A/B MAC, and RHHI regarding this change may beviewed at http://www.cms.hhs.gov/Transmittals/downloads/R1929CP.pdf on the CMS Web site. If youhave questions regarding this issue, refer to the “Contact Us” page of our Web site and select “Phone Us” tocall the Provider Contact Center.Quarterly Provider UpdateThe Quarterly Provider Update is a comprehensive resource published by the Centers for <strong>Medicare</strong> &Medicaid Services (CMS) on the first business day of each quarter. It is a listing of all nonregulatorychanges to <strong>Medicare</strong> including transmittals, manual changes, and any other instructions that could affectproviders. Regulations and instructions published in the previous quarter are also included in the update.The purpose of the Quarterly Provider Update is to:• Inform providers about new developments in the <strong>Medicare</strong> program;• Assist providers in understanding CMS programs and complying with <strong>Medicare</strong> regulations andinstructions;• Ensure that providers have time to react and prepare for new requirements;• Announce new or changing <strong>Medicare</strong> requirements on a predictable schedule; and• Communicate the specific days that CMS business will be published in the Federal Register.To receive notification when regulations and program instructions are added throughout the quarter, sign upfor the Quarterly Provider Update listserv (electronic mailing list).<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 10<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


We encourage you to bookmark the Quarterly Provider Update Web site and visit it often for this valuableinformation.If you have questions regarding this issue, refer to the “Contact Us” page of our Web site and select “PhoneUs” to call the Provider Contact Center.DisclaimerThis article was prepared as a service to the public and is not intended to grant rights or impose obligations. This article maycontain references or links to statutes, regulations, or other policy materials. The information provided is only intended to be ageneral summary. It is not intended to take the place of either the written law or regulations. We encourage readers to review thespecific statutes, regulations and other interpretive materials for a full and accurate statement of their contents.News from CMS for <strong>Home</strong> <strong>Health</strong> ProvidersCoding Patient Transfers under the <strong>Home</strong> <strong>Health</strong> Prospective Payment System (HHPPS)The Centers for <strong>Medicare</strong> & Medicaid Services (CMS) has provided the following <strong>Medicare</strong> LearningNetwork (MLN) Matters article. This MLN Matters article and other CMS articles can be found on theCMS Web site at: http://www.cms.hhs.gov/MLNMattersArticlesMLN Matters ® Number: MM6757 Related Change Request (CR) #: 6757Related CR Release Date: February 5, <strong>2010</strong> Effective Date: July 1, <strong>2010</strong>Related CR Transmittal #: R1904CP Implementation Date: July 6, <strong>2010</strong>Provider Types Affected<strong>Home</strong> health agencies (HHAs) submitting claims to <strong>Medicare</strong> regional home health intermediaries (RHHIs)for services provided to <strong>Medicare</strong> beneficiaries are impacted by this issue.Provider Action NeededSTOP – Impact to YouThis article is based on CR 6757 which revises <strong>Medicare</strong> processing of <strong>Home</strong> <strong>Health</strong> Prospective PaymentSystem (HH PPS) claims to account for recent changes to the UB-04 code set by the National UniformBilling Committee (NUBC).CAUTION – What You Need to KnowCR 6757 implements changes to <strong>Medicare</strong> systems in response to NUBC code changes. Point of origincodes B and C are deleted, effective with claims for dates of service on or after July 1, <strong>2010</strong>, and a newcondition code 47 is created. <strong>Medicare</strong> system editing of HH episodes is also revised to accommodate thesechanges.GO – What You Need to DoSee the “Background” and “Additional Information” sections of this article for further details regardingthese changes.<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 11<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


BackgroundWhen the National Uniform Billing Committee (NUBC) replaced the UB-92 institutional claim form withthe UB-04, they made several changes to the names and definitions of claim fields. These changesincluded:• Redefining the ‘Source of Admission’ field as ‘Point of Origin for Admission or Visit’; and• Specifying that codes in this field must represent a place rather than a referral source.The NUBC has continued to review the code values that are valid for this field to ensure they are consistentwith the current definition, and it has found the following are not consistent with the definition:• Point of origin code B (defined as ‘transfer from another home health agency’); and• Point of origin code C (defined as ‘readmission to the same home health agency’).Therefore, NUBC will retire these two codes effective for dates of service on or after July 1, <strong>2010</strong>.These two codes are significant in <strong>Medicare</strong> claims processing of home health (HH) claims under the HHPPS, because both codes are used as indicators to alert <strong>Medicare</strong> systems that a partial episode payment(PEP) adjustment will apply to a HH episode. When these codes are present, the <strong>Medicare</strong> system isprogrammed to allow a request for anticipated payment (RAP) which overlaps a previously establishedepisode. The previously established episode is shortened and a new episode is created, allowing theoverlapping RAP to be paid.The NUBC is replacing point of origin code B with new condition code 47. The title of condition code47 is “Transfer from another <strong>Home</strong> <strong>Health</strong> Agency,” and the definition is “The patient was admitted to thishome health agency as a transfer from another home health agency.” The NUBC will not replace point oforigin code C.CR 6757 ensures <strong>Medicare</strong> systems can continue to implement existing policies appropriately despitechanges in coding. Specifically, <strong>Medicare</strong> will take the following steps for claims with dates of service onor after July 1, <strong>2010</strong>:• <strong>Medicare</strong> will allow an HH RAP on institutional claims (type of bill (TOB) 322 or 332) or a no-RAPLow Utilization Payment Adjustment (LUPA) claim to overlap an existing HH episode if condition code47 is present on the RAP.• <strong>Medicare</strong> will allow an HH RAP (TOB 322 or 332) or a no-RAP LUPA claim to overlap an existing HHepisode record if the Claim Control Number (CCN) on the RAP and the episode match.• <strong>Medicare</strong> will calculate an add-on payment to LUPAs on institutional HH claims when the followingconditions are met:o The dates in the claim “From” date and admission dates match;o The first position of the <strong>Health</strong> Insurance Prospective Payment System (HIPPS) code is 1 or 2;o Condition code 47 is not present; ando The recoding indicator of 2 is not set.Note from Cahaba: Please note that these changes impact the dates of service submitted on the RAP/claim,not the date the RAP or claim was received by <strong>Medicare</strong>. Any RAP/claim with a “FROM” date on or afterJuly 1, <strong>2010</strong>, is subject to the NUBC UB-04 code set changes.<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 12<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


Additional InformationThe official instruction, CR 6757, issued to your RHHI regarding this change may be viewed athttp://www.cms.hhs.gov/Transmittals/downloads/R1904CP.pdf on the CMS Web site.If you have questions regarding this issue, refer to the “Contact Us” page of our Web site and select “PhoneUs” to call the Provider Contact Center.DisclaimerThis article was prepared as a service to the public and is not intended to grant rights or impose obligations. This article maycontain references or links to statutes, regulations, or other policy materials. The information provided is only intended to be ageneral summary. It is not intended to take the place of either the written law or regulations. We encourage readers to review thespecific statutes, regulations and other interpretive materials for a full and accurate statement of their contents.<strong>April</strong> <strong>2010</strong> Update of the Hospital Outpatient Prospective Payment System (OPPS)The Centers for <strong>Medicare</strong> & Medicaid Services (CMS) has provided the following <strong>Medicare</strong> LearningNetwork (MLN) Matters article. This MLN Matters article and other CMS articles can be found on theCMS Web site at: http://www.cms.hhs.gov/MLNMattersArticlesMLN Matters Number: MM6857 Related Change Request (CR) #: 6857Related CR Release Date: February 26, <strong>2010</strong> Effective Date: <strong>April</strong> 1, <strong>2010</strong>Related CR Transmittal #: R1924CP Implementation Date: <strong>April</strong> 5, <strong>2010</strong>Provider Types AffectedProviders submitting claims to <strong>Medicare</strong> contractors (fiscal intermediaries (FIs), <strong>Medicare</strong> administrativecontractors (MACs), and/or regional home health intermediaries (RHHIs)) for outpatient services providedto <strong>Medicare</strong> beneficiaries and paid under the OPPS.Provider Action NeededThis article is based on CR 6857, which describes changes to the OPPS to be implemented in the <strong>April</strong> <strong>2010</strong>OPPS update. Be sure billing staffs are aware of these changes.Background<strong>April</strong> <strong>2010</strong> OPPS UpdateCR 6857 describes changes to and billing instructions for various payment policies implemented in the<strong>April</strong> <strong>2010</strong> OPPS update. The <strong>April</strong> <strong>2010</strong> Integrated Outpatient Code Editor (I/OCE) and OPPS Pricer willreflect the HCPCS, Ambulatory Payment Classification (APC), HCPCS Modifier, and Revenue Codeadditions, changes, and deletions identified in this notification.<strong>April</strong> <strong>2010</strong> revisions to I/OCE data files, instructions, and specifications are provided in CR 6857, “<strong>April</strong><strong>2010</strong> Integrated Outpatient Code Editor (I/OCE) Specifications Version 11.1.”<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 13<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


Key OPPS Updates for <strong>April</strong> <strong>2010</strong>1. Procedure and Device Edits for <strong>April</strong> <strong>2010</strong>Procedure-to-device edits require that when a particular procedural HCPCS code is billed, the claim mustalso contain an appropriate device code. Failure to pass these edits will result in the claim being returned tothe provider. Device-to-procedure edits require that a claim that contains one of a specified set of devicecodes be returned to the provider if it fails to contain an appropriate procedure code. The updated lists ofboth types of edits can be found under “Device, Radiolabeled Product, and Procedure Edits” athttp://www.cms.hhs.gov/HospitalOutpatientPPS/ on the CMS Web site.2. Editing of Hospital Part B Inpatient ServicesBlood and blood products are not included in the list of services that may be covered when furnished topersons who are inpatients, but for whom no <strong>Medicare</strong> inpatient coverage is available. Therefore, no Part Bpayment may be made for them.The <strong>Medicare</strong> Claims Processing Manual, Chapter 4, §240.1 is revised to add revenue codes 038x (Bloodand Blood Components) and 039x (Administration, Processing and Storage for Blood and BloodComponents) to the table of revenue codes that are not allowed to be reported on a claim for payment ofservices furnished to hospital inpatients for whom there is no <strong>Medicare</strong> Part A coverage of their inpatienthospital care (12x type of bill (TOB)).The instruction is also revised to reflect that these edits are currently locally controlled by the <strong>Medicare</strong> A/BMAC or FI and are not imbedded in the FI Standard System.For more information, you may view the <strong>Medicare</strong> Benefits Policy Manual, Chapter 6, §2 for the servicesfor which payment may be made under the Part B <strong>Medicare</strong> hospital outpatient benefit for services tohospital inpatients and the <strong>Medicare</strong> Claims Processing Manual, Chapter 4, §240 for claims processinginstructions for these claims.3. Clarification to Coding Requirements for Pulmonary Rehabilitation Services Furnished On orAfter January 1, <strong>2010</strong>Section 140.4 .1 (Coding Requirements for Pulmonary Rehabilitation Services Furnished On or AfterJanuary 1, <strong>2010</strong>), Chapter 32 in the <strong>Medicare</strong> Claims Processing Manual, is being revised to reflectinstructions to hospitals and practitioners’ offices for reporting respiratory or pulmonary services furnishedto a patient when those services do not meet the diagnosis and coverage criteria for pulmonary rehabilitationservices.4. Warfarin TestingEffective August 3, 2009, <strong>Medicare</strong> covers pharmacogenomic testing to predict warfarin responsivenessonly in the context of an approved, clinical study, in addition to the coverage criteria outlined in the<strong>Medicare</strong> National Coverage Determinations (NCD) Manual, Chapter 1, §90.1, and in the <strong>Medicare</strong> ClaimsProcessing Manual, Chapter 32, §240. New Level II HCPCS code G9143 was developed to enableimplementation of this new coverage policy. Pharmacogenomic testing for warfarin response is a once-in-alifetimetest absent any reason to believe that the patient’s personal genetic characteristics would changeover time.Under the hospital OPPS, HCPCS code G9143 will be assigned status indicator “A” effective in the <strong>April</strong><strong>2010</strong> update, and payment for this lab test will be made under the clinical lab fee schedule (CLFS).<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 14<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


However, because of CLFS payment requirements and the timing of creation of the new code, HCPCS codeG9143 does not appear in the CY <strong>2010</strong> CLFS with an assigned rate. Therefore, its CY <strong>2010</strong> payment willbe determined by <strong>Medicare</strong> FIs and/or A/B MACs.<strong>Medicare</strong> FIs and/or A/B MACs will determine the hospital outpatient payment rate for HCPCS codeG9143 in the same manner that payment rates for unlisted laboratory CPT codes are currently determined.The reporting hospital’s FI or A/B MAC will contact the carrier or A/B MAC in the reporting hospital’sjurisdiction to obtain an appropriate payment amount for HCPCS code G9143. If that carrier or A/B MACcannot provide a payment amount for the service, then to establish a payment rate, the hospital’s FI or A/BMAC should contact the carrier or A/B MAC in the jurisdiction of the reference laboratory that performedthe test. If neither carrier nor A/B MAC has a payment amount for HCPCS code G9143 and the FI or A/BMAC for the reporting hospital determines that the service is covered, that FI or A/B MAC must determinethe payment amount.Further information on billing and coverage for warfarin testing can be found in CR 6715 issued December18, 2009, (under Transmittals 111 and 1880). These transmittals are available athttp://www.cms.hhs.gov/Transmittals/downloads/R111NCD.pdf andhttp://www.cms.hhs.gov/Transmittals/downloads/R1889CP.pdf on the CMS Web site.Table 1—Warfarin TestingHCPCS Long Descriptor APC SIG9143 Warfarin responsiveness testing by genetic technique using any method, any NA Anumber of specimen(s)5. Human Immunodeficiency Virus (HIV) Screening TestsCMS has determined that screening for HIV infection, which is recommended with a grade of A by the U.S.Preventive Services Task Force (USPSTF) for certain individuals, is reasonable and necessary for earlydetection of HIV and is appropriate for individuals entitled to benefits under Part A or enrolled under PartB. Therefore, effective December 8, 2009, <strong>Medicare</strong> covers HIV screening tests for beneficiaries that are atincreased risk for HIV infection per the USPSTF guidelines and beneficiaries that are pregnant whosediagnosis of pregnancy is known during the third trimester and at labor.Three new Level II HCPCS G-codes were created to implement this new coverage decision. The threeHCPCS G-codes (G0432, G0433, and G0435) describe both standard and Food and Drug Administration(FDA)-approved rapid HIV screening tests. Under the hospital OPPS, HCPCS G-codes G0432, G0433, andG0435 will be assigned status indicator “A” effective in the <strong>April</strong> <strong>2010</strong> update. Payment for these tests willbe made under the CLFS.However, because of CLFS payment requirements and the timing of creation of the new codes, HCPCScodes G0432, G0433, and G0435 do not appear in the CY <strong>2010</strong> CLFS with assigned rates. Therefore,payment for them must be determined by <strong>Medicare</strong> FIs and/or A/B MACs. <strong>Medicare</strong> FIs and/or A/B MACwill determine the hospital outpatient payment rates for HCPCS codes G0432, G0433, and G0435 in thesame manner that the payment rates for unlisted laboratory Current Procedural Terminology (CPT) codesare currently determined.The reporting hospital’s FI or A/B MAC will contact the carrier or A/B MAC in the reporting hospital’sjurisdiction to obtain an appropriate payment amount for HCPCS codes G0432, G0433, and G0435. If that<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 15<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


carrier or A/B MAC cannot provide a payment amount for the service, then to establish a payment rate, thehospital’s FI or A/B MAC should contact the carrier or A/B MAC in the jurisdiction of the referencelaboratory that performed the test. If neither carrier nor A/B MAC has a payment amount for the HCPCSG-code and the FI or A/B MAC for the reporting hospital determines that the service is covered, that FI orA/B MAC must determine the payment amount. Further information on coverage for HIV screening testsunder this new coverage decision can be found in a separate CR, which will be released shortly.Table 2—HIV TestingHCPCS Long Descriptor APC SIG0432G0433G0435Infectious agent antigen detection by enzyme immunoassay (EIA) technique,qualitative or semi-quantitative, multiple-step method, HIV-1 or HIV-2,screeningInfectious agent antigen detection by enzyme-linked immunosorbent assay(ELISA) technique, antibody, HIV-1 or HIV-2, screeningInfectious agent antigen detection by rapid antibody test of oral mucosatransudate, HIV-1 or HIV-2, screening6. Billing for Drugs, Biologicals, and RadiopharmaceuticalsHospitals are strongly encouraged to report charges for all drugs, biologicals, and radiopharmaceuticals,regardless of whether the items are paid separately or packaged, using the correct HCPCS codes for theitems used. It is also of great importance that hospitals billing for these products make certain that thereported units of service of the reported HCPCS codes are consistent with the quantity of a drug, biological,or radiopharmaceutical that was used in the care of the patient.Hospitals are reminded that under the OPPS, if two or more drugs or biologicals are mixed together tofacilitate administration, the correct HCPCS codes should be reported separately for each product used inthe care of the patient. The mixing together of two or more products does not constitute a “new” drug asregulated by the FDA under the New Drug Application (NDA) process. In these situations, hospitals arereminded that it is not appropriate to bill HCPCS code C9399. HCPCS code C9399 (Unclassified drug orbiological) is for new drugs and biologicals that are approved by the FDA on or after January 1, 2004, forwhich a HCPCS code has not been assigned.Unless otherwise specified in the long description, HCPCS descriptions refer to the non-compounded, FDAapprovedfinal product. If a product is compounded and a specific HCPCS code does not exist for thecompounded product, the hospital should report an appropriate unlisted code such as J9999 or J3490.a. Drugs and Biologicals with Payments Based on Average Sales Price (ASP) Effective <strong>April</strong> 1,<strong>2010</strong>For CY <strong>2010</strong>, payment for non-pass-through drugs, biologicals and therapeutic radiopharmaceuticalsis made at a single rate of ASP + 4 percent, which provides payment for both the acquisition andpharmacy overhead costs associated with the drug, biological or therapeutic radiopharmaceutical. InCY <strong>2010</strong>, a single payment of ASP + 6 percent for pass-through drugs, biologicals andradiopharmaceuticals is made to provide payment for both the acquisition and pharmacy overheadcosts of these pass-through items. For the second quarter of CY <strong>2010</strong>, payment for drugs andbiologicals with pass-through status is not made at the Part B Drug Competitive AcquisitionProgram (CAP) rate, as the CAP program was suspended beginning January 1, 2009. Should theNANANAAAA<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 16<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


Part B Drug CAP program be reinstituted sometime during CY <strong>2010</strong>, <strong>Medicare</strong> would again use thePart B drug CAP rate for pass-through drugs and biologicals if they are a part of the Part B drugCAP program, as required by the statute.In the CY <strong>2010</strong> OPPS/ASC final rule with comment period, it was stated that payments for drugsand biologicals based on ASPs will be updated on a quarterly basis as later quarter ASP submissionsbecome available. In cases where adjustments to payment rates are necessary based on the mostrecent ASP submissions, <strong>Medicare</strong> will incorporate changes to the payment rates in the <strong>April</strong> <strong>2010</strong>release of the OPPS Pricer. The updated payment rates, effective <strong>April</strong> 1, <strong>2010</strong>, will be included inthe <strong>April</strong> <strong>2010</strong> update of the OPPS Addendum A and Addendum B, which will be posted on theCMS Web site.b. Drugs and Biologicals with OPPS Pass-Through Status Effective <strong>April</strong> 1, <strong>2010</strong>Six drugs and biologicals have newly been granted OPPS pass-through status, effective <strong>April</strong> 1,<strong>2010</strong>. These items, along with their descriptors and APC assignments, are identified in Table 3below.Table 3—Drugs and Biologicals with New OPPS Pass-Through Status Effective <strong>April</strong> 1, <strong>2010</strong>HCPCSCodeLong Descriptor APC Status IndicatorEffective <strong>April</strong> 1, <strong>2010</strong>C9258 Injection, telavancin, 10 mg 9258 GC9259 Injection, pralatrexate, 1 mg 9259 GC9260 Injection, ofatumumab, 10 mg 9260 GC9261 Injection, ustekinumab, 1 mg 9261 GC9262 Fludarabine phosphate, oral, 1 mg 9262 GC9263 Injection, ecallantide, 1 mg 9263 Gc. Updated Payment Rate for HCPCS Code J9031 Effective January 1, 2009 through March 31,2009The payment rate for one HCPCS code was incorrect in the January 2009 OPPS Pricer. Thecorrected payment rate is listed in Table 4 below and has been installed in the <strong>April</strong> <strong>2010</strong> OPPSPricer, effective for services furnished on January 1, 2009, through implementation of the <strong>April</strong> 2009update.Table 4—Updated Payment Rate for HCPCS Code J9031 Effective January 1, 2009 through March31, 2009HCPCSCodeStatus Indicator APC Short DescriptorCorrectedPaymentRateCorrected MinimumUnadjustedCopaymentJ9031 K 0809 Bcg live intravesical vac $118.96 $23.79<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 17<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


Note: <strong>Medicare</strong> contractors may adjust as appropriate claims previously paid under the OPPS brought totheir attention that:1. Have dates of service that fall on or after January 1, 2009, but prior to <strong>April</strong> 1, 2009;2. Contain HCPCS code listed in Table 4 above; and3. Were originally processed prior to the installation of the <strong>April</strong> <strong>2010</strong> OPPS Pricer.d. Updated Payment Rates for Certain HCPCS Codes Effective October 1, 2009, throughDecember 31, 2009The payment rates for several HCPCS codes were incorrect in the October 2009 OPPS Pricer. Thecorrected payment rates are listed in Table 5 below and have been installed in the <strong>April</strong> <strong>2010</strong> OPPSPricer effective for services furnished on October 1, 2009, through implementation of the January<strong>2010</strong> update.Table 5—Updated Payment Rates for Certain HCPCS Codes Effective October 1, 2009, throughDecember 31, 2009HCPCSCodeStatusIndicatorAPCShort DescriptorCorrectedPayment RateCorrectedMinimumUnadjustedCopayment90371 K 1630 Hep b ig, im $113.78 $22.76J1458 K 9224 Galsulfase injection $333.49 $66.70J2278 K 1694 Ziconotide injection $6.38 $1.28J2323 K 9126 Natalizumab injection $7.97 $1.59Note: Providers should also note that <strong>Medicare</strong> contractors may adjust as appropriate claims previously paidunder the OPPS brought to their attention that:1. Have dates of service that fall on or after October 1, 2009, but prior to January 1, <strong>2010</strong>;2. Contain HCPCS code listed in Table 5 above; and3. Were originally processed prior to the installation of the <strong>April</strong> <strong>2010</strong> OPPS Pricer.e. Correct Reporting of Biologicals When Used As Implantable DevicesWhen billing for biologicals where the HCPCS code describes a product that is solely surgicallyimplanted or inserted, whether the HCPCS code is identified as having pass-through status or not,hospitals are to report the appropriate HCPCS code for the product. In circumstances where theimplanted biological has pass-through status, either as a biological or a device, a separate paymentfor the biological or device is made. In circumstances where the implanted biological does not havepass-through status, the OPPS payment for the biological is packaged into the payment for theassociated procedure.When billing for biologicals, where the HCPCS code describes a product that may either besurgically implanted or inserted or otherwise applied in the care of a patient, hospitals should notseparately report the biological HCPCS codes, with the exception of biologicals with pass-throughstatus, when using these items as implantable devices (including as a scaffold or an alternative tohuman or nonhuman connective tissue or mesh used in a graft) during surgical procedures.<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 18<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


Under the OPPS, hospitals are provided a packaged APC payment for surgical procedures thatincludes the cost of supportive items, including implantable devices without pass-through status.When using biologicals during surgical procedures as implantable devices, hospitals may include thecharges for these items in their charge for the procedure, report the charge on an uncoded revenuecenter line, or report the charge under a device HCPCS code (if one exists) so these costs wouldappropriately contribute to the future median setting for the associated surgical procedure.f. Correct Reporting of Units for DrugsHospitals and providers are reminded to ensure that units of drugs administered to patients areaccurately reported in terms of the dosage specified in the full HCPCS code descriptor. That is,units should be reported in multiples of the units included in the HCPCS descriptor.Examples:If the description for the drug code is 6 mg, and 6 mg of the drug was administered to the patient, theunits billed should be 1. As another example, if the description for the drug code is 50 mg, but 200mg of the drug was administered to the patient, the units billed should be 4.Providers and hospitals should not bill the units based on the way the drug is packaged, stored, orstocked. That is, if the HCPCS descriptor for the drug code specifies 1 mg and a 10 mg vial of thedrug was administered to the patient, hospitals should bill 10 units, even though only 1 vial wasadministered. The HCPCS short descriptors are limited to 28 characters, including spaces, so shortdescriptors do not always capture the complete description of the drug. Therefore, before submitting<strong>Medicare</strong> claims for drugs and biologicals, it is extremely important to review the complete longdescriptors for the applicable HCPCS codes.g. Reporting of Outpatient Diagnostic Nuclear Medicine ProceduresWith the specific exception of HCPCS code C9898 (Radiolabeled product provided during a hospitalinpatient stay) to be reported by hospitals on outpatient claims for nuclear medicine procedures toindicate that a radiolabeled product that provides the radioactivity necessary for the reporteddiagnostic nuclear medicine procedure was provided during a hospital inpatient stay, hospitalsshould only report HCPCS codes for products they provide in the hospital outpatient department andshould not report a HCPCS code and charge for a radiolabeled product on the nuclear medicineprocedure-to-radiolabeled product edit list solely for the purpose of bypassing those edits present inthe I/OCE.As was stated in the October 2009 OPPS update, in the rare instance when a diagnosticradiopharmaceutical may be administered to a beneficiary in a given calendar year prior to a hospitalfurnishing an associated nuclear medicine procedure in the subsequent calendar year, hospitals areinstructed to report the date the radiolabeled product is furnished to the beneficiary as the same datethat the nuclear medicine procedure is performed. This situation is extremely rare and it is expectedthat the majority of hospitals will not encounter this situation.7. Coverage DeterminationsThe fact that a drug, device, procedure, or service is assigned a HCPCS code and a payment rate under theOPPS does not imply coverage by the <strong>Medicare</strong> program, but indicates only how the product, procedure, orservice may be paid if covered by the program. FIs and/or MACs determine whether a drug, device,procedure, or other service meets all program requirements for coverage. For example, FIs/MACsdetermine that it is reasonable and necessary to treat the beneficiary’s condition and whether it is excludedfrom payment.<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 19<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


Additional InformationFor complete details regarding this CR please see the official instruction issued to your <strong>Medicare</strong> FI, RHHI,or A/B MAC, which may be viewed by going tohttp://www.cms.hhs.gov/Transmittals/downloads/R1924CP.pdf on the CMS Web site.If you have questions regarding this issue, refer to the “Contact Us” page of our Web site and select “PhoneUs” to call the Provider Contact Center.Detailed information about OPPS is available athttp://www.cms.hhs.gov/HospitalOutpatientPPS/05_OPPSGuidance.asp on the CMS Web site.A fact sheet entitled, Hospital Outpatient Prospective Payment System (OPPS), may be found in the<strong>Medicare</strong> Learning Network catalog. This fact sheet provides general information about the HospitalOutpatient Prospective Payment System, ambulatory payment classifications, and how payment rates areset. The document may be viewed athttp://www.cms.hhs.gov/MLNProducts/downloads/HospitalOutpaysysfctsht.pdf on the CMS Web site.DisclaimerThis article was prepared as a service to the public and is not intended to grant rights or impose obligations. This article maycontain references or links to statutes, regulations, or other policy materials. The information provided is only intended to be ageneral summary. It is not intended to take the place of either the written law or regulations. We encourage readers to review thespecific statutes, regulations and other interpretive materials for a full and accurate statement of their contents. CPT onlycopyright 2009 American Medical Association. All rights reserved.<strong>April</strong> <strong>2010</strong> Integrated Outpatient Code Editor (I/OCE) Specifications Version 11.0The Centers for <strong>Medicare</strong> & Medicaid Services (CMS) has provided the following <strong>Medicare</strong> LearningNetwork (MLN) Matters article. This MLN Matters article and other CMS articles can be found on theCMS Web site at: http://www.cms.hhs.gov/MLNMattersArticlesMLN Matters Number: MM6882 Related Change Request (CR) #: 6882Related CR Release Date: March 5, <strong>2010</strong> Effective Date: <strong>April</strong> 1, <strong>2010</strong>Related CR Transmittal #: R1927CP Implementation Date: <strong>April</strong> 5, <strong>2010</strong>Provider Types AffectedProviders submitting institutional outpatient claims to <strong>Medicare</strong> fiscal intermediaries (FIs), <strong>Medicare</strong>administrative contractors (MACs), and/or regional home health intermediaries (RHHIs)) for outpatientservices provided to <strong>Medicare</strong> beneficiaries are affected.Provider Action NeededThis article is based on CR 6882, which describes changes to the Integrated Outpatient Code Editor. Besure billing staffs are aware of these changes.<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 20<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


BackgroundCR 6882 describes changes to billing instructions for various payment policies implemented in the <strong>April</strong><strong>2010</strong> OPPS update. The <strong>April</strong> <strong>2010</strong> Integrated Outpatient Code Editor (I/OCE) changes are also discussedin CR 6882.Note: The full list of I/OCE specifications will no longer be included in these quarterly change requests.Those specifications can now be found at http://www.cms.hhs.gov/OutpatientCodeEdit/ on the CMS Website.A summary of the changes for <strong>April</strong> <strong>2010</strong> is within Appendix M of Attachment A in CR 6882 and thatsummary is captured in the following key points.Key Points of CR 6882 Based on Appendix M of the I/OCE Specifications• Effective December 8, 2009, <strong>Medicare</strong> added codes G0432, G0433 and G0435.• Effective January 1, <strong>2010</strong>, <strong>Medicare</strong> updates procedure/device edit requirements.• Effective <strong>April</strong> 1, <strong>2010</strong>, <strong>Medicare</strong> will:• Bypass sex conflict edits (#3 = diagnosis/sex; #8 = procedure/sex) if condition code 45 is present onthe claim;• Add new revenue codes 860 and 861 to the list of valid revenue codes;• Modify appendices E and F to change the TOB used by FQHCs, from 73X to 77X;• Make HCPCS/APC SI changes (data change files);• Implement version 16.0 of the NCCI (as modified for applicable institutional providers);• Add new modifier ‘GX’ to the valid modifier list; and• Create 508-compliant versions of the specifications and Summary of Data Changes documents forpublication on the CMS Web site.Additional InformationFor complete details regarding this CR, please see the official instruction (CR 6882) issued to your<strong>Medicare</strong> FI or carrier at http://www.cms.hhs.gov/Transmittals/downloads/R1927CP.pdf on the CMS Website.The I/OCE instructions are attached to CR 6882 and will also be posted athttp://www.cms.hhs.gov/OutpatientCodeEdit/ on the CMS Web site.If you have questions regarding this issue, refer to the “Contact Us” page of our Web site and select “PhoneUs” to call the Provider Contact Center.DisclaimerThis article was prepared as a service to the public and is not intended to grant rights or impose obligations. This article maycontain references or links to statutes, regulations, or other policy materials. The information provided is only intended to be ageneral summary. It is not intended to take the place of either the written law or regulations. We encourage readers to review thespecific statutes, regulations and other interpretive materials for a full and accurate statement of their contents.<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 21<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


Implementation of <strong>Home</strong> <strong>Health</strong> Agency Program Safeguard Provisions—RevisedThe Centers for <strong>Medicare</strong> & Medicaid Services (CMS) has issued a revision to the <strong>Medicare</strong> LearningNetwork (MLN) Matters article, “Implementation of <strong>Home</strong> <strong>Health</strong> Agency Program Safeguard Provisions,”which was published in the February 1, <strong>2010</strong>, <strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>Medicare</strong> A <strong>Newsline</strong>. This MLNMatters article and other CMS articles can be found on the CMS Web site at:http://www.cms.hhs.gov/MLNMattersArticlesMLN Matters ® Number: MM6750 Revised Related Change Request (CR) #: 6750Related CR Release Date: December 18, 2009 Effective Date: January 1, <strong>2010</strong>Related CR Transmittal #: R318PI Implementation Date: January 1, <strong>2010</strong>Note: This article was revised on February 18, <strong>2010</strong>, to include this note that clarifies that the newrequirements are effective for CMS-855A applications received on or after January 1, <strong>2010</strong>.Applications received prior to January 1, <strong>2010</strong>, will be handled in accordance with the policies inplace prior to January 1, <strong>2010</strong>.Provider Types Affected<strong>Home</strong> health agencies (HHAs) submitting claims to <strong>Medicare</strong> contractors (fiscal intermediaries (FIs), A/B<strong>Medicare</strong> administrative contractors (A/B MACs), and/or regional home health intermediaries (RHHIs)) forservices provided to <strong>Medicare</strong> beneficiaries.Provider Action NeededThis article is based on CR 6750, which implements two provisions from the HHA Prospective PaymentSystem Final Rule (CMS-1560-F). The first provision requires an HHA whose <strong>Medicare</strong> billing privilegeshave been deactivated to undergo a State survey or obtain accreditation from a CMS-approved accreditingorganization prior to having its billing privileges reactivated. The second provision holds that an HHA maynot undergo a change of ownership or transfer of ownership if the effective date of the change or transferoccurs within 36 months of: (1) the effective date of the provider’s enrollment in <strong>Medicare</strong>, or (2) theeffective date of the last ownership change or transfer for the HHA. The provider must instead enroll as anew HHA, undergo a State survey or obtain accreditation from a CMS-approved accrediting organization,and sign a new provider agreement.BackgroundAn “ownership change” includes any of the following:• Change of ownership (CHOW);• Acquisition/merger;• Consolidation;• Change request reporting a 5 percent or greater ownership change (including, stock transfer or assetsale); or• Change request reporting a change in partners, regardless of the percentage of ownership involved.If a <strong>Medicare</strong> contractor receives an application for an ownership change from an HHA, it willdetermine whether the effective date of the transfer is within 36 months of either the effective date ofthe provider’s initial enrollment in <strong>Medicare</strong> or last ownership change. The <strong>Medicare</strong> contractor willverify the effective date of the ownership transfer by requesting a copy of the transfer agreement, salesagreement, bill of sale, etc., rather than relying upon the projected date of the sale listed on the application.<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 22<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


If the transfer date falls within the 36-month period after the effective date of the provider’senrollment in <strong>Medicare</strong> or last ownership change, the <strong>Medicare</strong> contractor will return the application andnotify the provider that, per 42 CFR 424.550(b), the HHA must:• Enroll as an initial applicant;• Obtain a new State survey or accreditation from a CMS-approved accrediting organization after it hassubmitted its initial enrollment application and the <strong>Medicare</strong> contractor has made a recommendation forapproval to the State; and• Sign a new provider agreement as part of the initial enrollment;As the new owner must enroll as a new provider, the <strong>Medicare</strong> contractor will also deactivate the HHA’sbilling privileges if the sale has already occurred. If the sale has not occurred, the contractor will alert theHHA that it must submit a CMS-855A voluntary termination application (seehttp://www.cms.hhs.gov/cmsforms/downloads/cms855a.pdf on the CMS Web site).If the transfer date is more than 36 months after the effective date of the provider’s enrollment in<strong>Medicare</strong> or most recent ownership change, the application can be processed normally, without the needfor a new State survey or an approval from an approved accreditation organization.Additional InformationThe official instruction, CR 6750, issued to your FI, A/B MAC, and RHHI regarding this change may beviewed at http://www.cms.hhs.gov/Transmittals/downloads/R318PI.pdf on the CMS Web site.If you have questions regarding this issue, refer to the “Contact Us” page of our Web site and select “PhoneUs” to call the Provider Contact Center.DisclaimerThis article was prepared as a service to the public and is not intended to grant rights or impose obligations. This article maycontain references or links to statutes, regulations, or other policy materials. The information provided is only intended to be ageneral summary. It is not intended to take the place of either the written law or regulations. We encourage readers to review thespecific statutes, regulations and other interpretive materials for a full and accurate statement of their contents.News from CMS for <strong>Hospice</strong> ProvidersQuestions and Answers on Reporting Physician Consultation ServicesThe Centers for <strong>Medicare</strong> & Medicaid Services (CMS) has provided the following <strong>Medicare</strong> LearningNetwork (MLN) Matters article. This MLN Matters article and other CMS articles can be found on theCMS Web site at: http://www.cms.hhs.gov/MLNMattersArticlesMLN Matters ® Number: SE1010 Related Change Request (CR) #: 6740Related CR Release Date: N/A Effective Date: January 1, <strong>2010</strong>Related CR Transmittal #: N/A Implementation Date: January 4, <strong>2010</strong><strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 23<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


Provider Types AffectedThis article is for physicians and non-physician practitioners (NPPs) who perform initial evaluation andmanagement (E/M) services previously reported by Current Procedural Terminology (CPT) consultationcodes for <strong>Medicare</strong> beneficiaries and submit claims to <strong>Medicare</strong> carriers and/or <strong>Medicare</strong> administrativecontractors (MACs) for those services. It is also intended for Method II critical access hospitals, which billfor the services of those physicians and NPPs who have reassigned their billing rights, and hospices wherethe hospice bills Part A for the services of physicians on staff or working under arrangement with thehospice. This article only applies to the services of physicians and NPPs paid under the <strong>Medicare</strong> Fee-For-Service (FFS) program. It does not revise existing policies or rules governing <strong>Medicare</strong>Advantage or non-<strong>Medicare</strong> insurers. Physicians, NPPs, Method II critical access hospitals, andhospices to which the revised policy applies are subsequently referred to as providers throughout thispublication.Provider Action NeededThis article pertains to CR 6740, which alerts providers that effective January 1, <strong>2010</strong>, the CPT consultationcodes (ranges 99241-99245 and 99251-99255) are no longer recognized for <strong>Medicare</strong> Part B payment.Effective for services furnished on or after January 1, <strong>2010</strong>, providers should report each E/M service,including visits that could be described by CPT consultation codes, with an E/M code payable under the<strong>Medicare</strong> Physician Fee Schedule (MPFS) that represents WHERE the visit occurs and that identifies theCOMPLEXITY of the visit performed.BackgroundIn the calendar year (CY) <strong>2010</strong> MPFS final rule with comment period (CMS-1413-FC), CMS eliminated thepayment of all CPT consultation codes (inpatient and office/outpatient codes) for various places of serviceexcept for telehealth consultation HCPCS G-codes. The change does not increase or decrease <strong>Medicare</strong>payments. In the case of CPT codes for E/M services that may be reported in CY <strong>2010</strong> for E/M servicespreviously paid by the CPT consultation codes, CMS increased the work relative value units (RVUs) fornew and established office visits, increased the work RVUs for initial hospital and initial nursing facilityvisits, and incorporated the increased use of these visits into the practice expense (PE) and malpracticecalculations. CMS also increased the incremental work RVUs for the E/M codes that are built into the 10-day and 90-day global surgical codes. All references (both text and code numbers) in Publication 100-04,Chapter 12, §30.6 of the <strong>Medicare</strong> Claims Processing Manual that pertain to the use of the AmericanMedical Association (AMA) CPT consultation codes (ranges 99241-99245 and 99251-99255) are removedby CR 6740. (The Web address for viewing CR 6740 is in the “Additional Information” section of thisarticle.)Questions (Qs) & Answers (As)The following Qs and As are offered to address some of the key questions you may have regarding thesechanges:Q. When will providers and <strong>Medicare</strong> contractors stop reporting and paying the CPT consultationcodes for consultative E/M services that could be described by the CPT consultation codes?A. <strong>Medicare</strong> ceased recognizing the CPT consultation codes for payment effective for services furnished onor after January 1, <strong>2010</strong>.Q. Does this policy apply to other <strong>Medicare</strong> products, such as <strong>Medicare</strong> Advantage?<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 24<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


A. This policy applies to providers billing the <strong>Medicare</strong> fee-for-service program. If a provider is furnishingan E/M service that could be described by a CPT consultation code to a <strong>Medicare</strong> Advantage patient, theprovider should contact the <strong>Medicare</strong> Advantage plan for its policy.Q. Is CMS going to crosswalk the CPT consultation codes that are no longer recognized to the E/Mcodes for each setting in which an E/M service that could be described by a CPT consultation codecan be furnished?A. No, providers must bill the E/M code (other than a CPT consultation code) that describes the servicethey provide in order to be paid for the E/M service furnished. The general guideline is that the providershould report the most appropriate available code to bill <strong>Medicare</strong> for services that were previouslybilled using the CPT consultation codes. For services that could be described by inpatient consultationCPT codes, CMS has stated that providers may bill the initial hospital care service CPT codes and theinitial nursing facility care CPT codes, where those codes appropriately describe the level of serviceprovided. When those codes do not apply, providers should bill the E/M code that most closelydescribes the service provided.Q. How should providers bill for services that could be described by CPT inpatient consultationcodes 99251 or 99252, the lowest two of five levels of the inpatient consultation CPT codes, whenthe minimum key component work and/or medical necessity requirements for the initial hospitalcare codes 99221 through 99223 are not met?A. There is not an exact match of the code descriptors of the low level inpatient consultation CPT codes tothose of the initial hospital care CPT codes. For example, one element of inpatient consultation CPTcodes 99251 and 99252, respectively, requires “a problem focused history” and “an expanded problemfocused history.” In contrast, initial hospital care CPT code 99221 requires “a detailed or comprehensivehistory.” Providers should consider the following two points in reporting these services. First, CMSreminds providers that CPT code 99221 may be reported for an E/M service if the requirements forbilling that code, which are greater than CPT consultation codes 99251 and 99252, are met by theservice furnished to the patient. Second, CMS notes that subsequent hospital care CPT codes 99231 and99232, respectively, require “a problem focused interval history” and “an expanded problem focusedinterval history” and could potentially meet the component work and medical necessity requirements tobe reported for an E/M service that could be described by CPT consultation code 99251 or 99252.Q. How will <strong>Medicare</strong> contractors handle claims for subsequent hospital care CPT codes that reportthe provider’s first E/M service furnished to a patient during the hospital stay?A. While CMS expects that the CPT code reported accurately reflects the service provided, CMS hasinstructed <strong>Medicare</strong> contractors to not find fault with providers who report a subsequent hospital careCPT code in cases where the medical record appropriately demonstrates that the work and medicalnecessity requirements are met for reporting a subsequent hospital care code (under the level selected),even though the reported code is for the provider's first E/M service to the inpatient during the hospitalstay.Q. How will more reporting of initial hospital care CPT codes instead of CPT consultation codesaffect the review of claims by <strong>Medicare</strong> contractors?<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 25<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


A. CMS has alerted MAC audit staff as well as <strong>Medicare</strong> Recovery Audit Contractors of its expectationthat physicians may bill more E/M codes for initial hospital care in place of billing inpatient CPTconsultation codes. CMS has also alerted contractors to expect a different proportion of various initialhospital care CPT codes under the new policy. CMS expects contractors to consider that these may beappropriate changes when making decisions about whether to pursue medical review and other types ofclaims review.Q. How should providers bill for E/M services that cannot be described by any CPT E/M code that ispayable by <strong>Medicare</strong>?A. These services should be reported with CPT code 99499 (Unlisted evaluation and management service).Reporting CPT code 99499 requires submission of medical records and contractor manual medicalreview of the service prior to payment, and CMS expects reporting of this E/M code to be unusual.Q. Because CPT consultation codes are no longer recognized by CMS for payment, is the definition oftransfer of care no longer relevant?A. Yes, CMS agrees that discontinuing recognition of the CPT consultation codes for payment renders theissues regarding the definition of what constitutes a transfer of care no longer relevant.Q. When is it appropriate for providers to report critical care services in the context of furnishing anE/M service that could be described by a CPT consultation code?A. Providers should continue to follow the existing CPT guidelines for reporting critical care codes.Q. What constitutes a new versus an established patient? Can a provider bill an office/outpatientnew patient visit code and/or an initial hospital care service code for a patient seen within the pastthree years but for a new problem?A. The rules with respect to new and established patient office visits are unchanged. Providers shouldfollow the guidance in Publication 100-04, Chapter 12, §30.6.7 of the <strong>Medicare</strong> Claims ProcessingManual:Interpret the phrase “new patient” to mean a patient who has not received any professional services,i.e., E/M service or other face-to face service (e.g., surgical procedure) from the physician orphysician group practice (same physician specialty) within the previous 3 years. For example, if aprofessional component of a previous procedure is billed in a 3 year time period, e.g., a labinterpretation is billed and no E/M service or other face-to-face service with the patient is performed,then this patient remains a new patient for the initial visit. An interpretation of a diagnostic test,reading an x-ray or EKG, etc., in the absence of an E/M service or other face-to-face service with thepatient does not affect the designation of a new patient.Q. Will <strong>Medicare</strong> contractors accept the CPT consultation codes when <strong>Medicare</strong> is the secondarypayer?A. <strong>Medicare</strong> will also no longer recognize the CPT consultation codes for purposes of determining<strong>Medicare</strong> secondary payments (MSP). In MSP cases, providers must bill an appropriate E/M code forthe E/M services previously reported and paid using the CPT consultation codes. If the primary payerfor the service continues to recognize CPT consultation codes for payment, providers billing for theseservices may either:<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 26<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


• Bill the primary payer an E/M code that is appropriate for the service, and then report the amountactually paid by the primary payer, along with the same E/M code, to <strong>Medicare</strong> for determination ofwhether a payment is due; or• Bill the primary payer using a CPT consultation code that is appropriate for the service, and thenreport the amount actually paid by the primary payer, along with an E/M code that is appropriate forthe service, to <strong>Medicare</strong> for determination of whether a payment is due.Q. Can a provider provide an advance beneficiary notice (ABN) to the beneficiary and then bill his orher charge for the consultation after the consultation is billed and denied by <strong>Medicare</strong>?A. No, when a CPT consultation code is reported to <strong>Medicare</strong>, the claim is not denied. Instead, the claim isreturned to the provider for a different CPT code because <strong>Medicare</strong> recognizes another code for paymentof E/M services that may be described by CPT consultation codes. Once the claim is resubmitted toreport an appropriate, payable E/M code (other than a CPT consultation code) for a medically reasonableand necessary E/M service, the beneficiary can only be billed any applicable <strong>Medicare</strong> deductible andcoinsurance amounts that apply to the covered E/M service.Q. Can a provider who furnished an E/M service that could be described by a CPT consultation codeto a <strong>Medicare</strong> beneficiary bill the beneficiary for his or her charge for the service after providingan ABN?A. No, an ABN cannot be employed in these circumstances, because ABNs are applicable only wheredenial of payment is anticipated on grounds of the medical necessity requirement under section1862(a)(1)(A) of the Social Security Act. E/M services previously reported using CPT consultationcodes may be medically reasonable and necessary. CPT consultation codes 99241-99245 and 99251-99255 are now assigned status indicator “I,” which means that these codes are not valid for <strong>Medicare</strong>purposes, and explicitly provides that “<strong>Medicare</strong> uses another code for the reporting of, and payment forthese services.”Q. Can providers count floor/unit time toward the time threshold that must be met to bill aprolonged service with direct (face-to-face) patient contact in the inpatient setting?A. The existing rules for counting time for purposes of meeting the prolonged care threshold times continueto apply. In particular, the <strong>Medicare</strong> Claims Processing Manual, Chapter 12, §30.6.15.1.C, providesthat providers may count only the duration of direct face-to-face contact between the provider and thepatient for these purposes and may not include time spent reviewing charts or discussion of a patientwith house medical staff and not with direct face-to-face contact with the patient.Q. Can a new patient office visit CPT code be billed to report an E/M service that could be describedby a CPT consultation code when a patient is seen for a pre-operative consultation at the requestof a surgeon, even if the consulting provider has provided a professional service to the beneficiarywithin the past three years?A. Publication 100-04, Chapter 12, §30.6.7 of the <strong>Medicare</strong> Claims Processing Manual states:“Interpret the phrase “new patient” to mean a patient who has not received any professional services,i.e., E/M service or other face-to face service (e.g., surgical procedure) from the physician orphysician group practice (same physician specialty) within the previous 3 years. For example, if aprofessional component of a previous procedure is billed in a 3 year time period, e.g., a lab<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 27<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


interpretation is billed and no E/M service or other face-to-face service with the patient is performed,then this patient remains a new patient for the initial visit. An interpretation of a diagnostic test,reading an x-ray or EKG etc., in the absence of an E/M service or other face-to-face service with thepatient does not affect the designation of a new patient.”CMS has not adopted any revisions to the previous policies, regarding the billing of E/M codes as aresult of the new policy on CPT consultation codes (other than allowing providers who wouldpreviously have billed the inpatient CPT consultation codes to bill the initial hospital and nursing homevisit CPT codes where those codes appropriately describe the services furnished). Therefore, therequirements of Publication 100-04, Chapter 12, §30.6.7.A of the <strong>Medicare</strong> Claims Processing Manualremain in effect. In the situation where a patient is seen for a pre-operative consultation when theconsulting provider has furnished a professional service to the beneficiary in the past three years, thatprovision precludes the provider from billing a new patient office visit CPT code.Q. When may initial nursing facility (NF) care codes be reported for E/M services that could bedescribed by CPT consultation codes?A. Physicians may bill an initial NF care CPT code for their first visit during a patient’s admission to a NFin lieu of the CPT consultation codes these physicians may have previously reported, when theconditions for billing the initial NF care CPT code are satisfied. The initial visit in a skilled nursingfacility (SNF) and nursing facility must be furnished by a physician except as otherwise permitted asspecified in CFR Section 483.40(c)(4). The initial NF care CPT codes 99304 through 99306 are used toreport the initial E/M visit in a SNF or NF that fulfills federally-mandated requirements under Section483.40(c).Q. What E/M code should physicians report for an initial E/M service that could be described by aCPT consultation code but that does not meet the requirements for reporting an initial NF careCPT code?A. In these cases, physicians and other practitioners may bill a subsequent NF care CPT code in lieu of theCPT consultation codes they may have previously reported. Otherwise, the subsequent NF care CPTcodes 99307 through 99310 are used to report either a federally-mandated periodic visit under Section483.40(c), or any E/M service prior to and after the initial physician visit that is reasonable andmedically necessary to meet the medical needs of the individual resident.Q. When may NPPs furnish an initial NF E/M service?A. In the NF setting, an NPP, who is enrolled in the <strong>Medicare</strong> program and is not employed by the facility,may perform the initial visit when the state law permits this (See this exception in Publication 100–04,Chapter 12, §30.6.13.A of the <strong>Medicare</strong> Claims Processing Manual). A NPP who is enrolled in the<strong>Medicare</strong> program is permitted to report the initial hospital care visit or new patient office visit, asappropriate, under current <strong>Medicare</strong> policy. As discussed in the CY <strong>2010</strong> MPFS proposed rule (74 FR33543), the long-term care regulations at Section 483.40 require that residents of SNFs receive initialand periodic personal visits. These regulations insure that at least a minimal degree of personal contactbetween a physician or a qualified NPP and a resident is maintained, both at the point of admission tothe facility and periodically during the course of the resident's stay.<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 28<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


Q. How should E/M services previously reported by CPT consultation codes and provided in asplit/shared manner be billed?A. The split/shared rules applying to E/M services remain in effect, including those cases where serviceswould previously have been reported by CPT consultation codes.Q. Does the policy of no longer recognizing CPT consultation codes for the purposes of <strong>Medicare</strong>billing apply to billing for physicians’ services in hospices, where the hospice bills Part A for theservices of physicians on staff or working under arrangement with the hospice?A. Yes, when hospices bill Part A for the services of physicians, they must use CPT codes that are paidunder the MPFS. Since the CPT consultation codes are no longer recognized for payment under theMPFS, hospices must follow the same guidelines for reporting E/M services as physicians billing Part B.<strong>Hospice</strong>s should use the most appropriate E/M codes to bill for E/M services furnished by physiciansthat could be described by CPT consultation codes.Q. Will appending modifier “-A1”(Dressing for one wound) instead of the appropriate modifier “-AI”(Principal physician of record) to the CPT code for an initial hospital or nursing home E/Mservice furnished by the principal physician of record affect payment to the provider for thatservice?A. Because modifier “-AI” (not modifier “-A1”) is the appropriate modifier to identify an initial hospital ornursing home E/M service by the patient’s principal physician of record, payment to the provider for theE/M service could be affected. Some <strong>Medicare</strong> contractors may reject an E/M code reported withmodifier “-A1” as an invalid procedure code/modifier combination and, therefore, payment for the E/Mservice would not be made. In that case, the provider should submit a corrected claim reporting modifier“-AI” appended to the E/M code. If an E/M code with modifier “-A1” appended has already beensubmitted and paid, the provider does not need to submit a corrected claim but should report theappropriate modifier “-AI” on future claims for initial hospital or nursing home E/M services when theE/M service is furnished by the principal physician of record. Providers should contact their <strong>Medicare</strong>contractor for further assistance if necessary.Q. Do admitting physicians still get paid if they do not report the modifier “-AI?”A. Yes, the use of the modifier is for informational purposes only.Q. The transmittal, “Revisions to Consultation Services Payment Policy” (Transmittal # R1875CP,also referred to as CR 6740), indicates that the CPT consultation codes are ‘not valid for<strong>Medicare</strong>.’ It also states <strong>Medicare</strong> uses a different code to report the service. However, the MLNMatters ® article directed to providers states the consult codes are ‘non-covered.’ When it comesto reporting services, there is a definite difference in these two terms. Please clarify.A. The question refers to the following passage in the original MLN Matters ® article:Physicians who bill a consultation after January 1, <strong>2010</strong>, will have the claim returned with a messageindicating that <strong>Medicare</strong> uses another code for the service. The physician must bill another code forthe service and may not bill the patient for a non-covered service.The MLN Matters ® article is being reissued to clarify this passage, consistent with the answer to thequestion that follows.<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 29<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


The provider may not bill the patient in lieu of billing <strong>Medicare</strong> and may not have the patient sign anABN to hold the patient personally responsible for the payment. CMS did not intend for this passage tosuggest that E/M services that could be described by CPT consultation codes are “noncovered.” Rather,CMS intended to indicate that providers may not bill the patient for the E/M service that could bedescribed by a CPT consultation code as though the E/M service was non-covered, as is now clarified inthe reissued article. However, some people have interpreted the passage to suggest that providers cannotbill for an E/M service that could be described by a CPT consultation code because it is a non-coveredservice. The following language may clarify what CMS was trying to say in the cited passage:Providers who bill an E/M service after January 1, <strong>2010</strong>, using one of the CPT consultation codes(ranges 99241-99245, and 99251-99255) will have the claim returned with a message indicating that<strong>Medicare</strong> uses another code for reporting and payment of the service. To receive payment for theE/M service, the claim should be resubmitted using the appropriate E/M code as described in thisarticle. Although CMS has eliminated the use of the CPT consultation codes for payment of E/Mservices furnished to <strong>Medicare</strong> fee-for-service patients, those E/M services themselves continue tobe covered services if they are medically reasonable and necessary and, therefore, an ABN is notapplicable. Furthermore, the patient may not be billed for the E/M service instead of <strong>Medicare</strong>.Q. Does the new policy violate HIPPA rules by requiring providers to bill for E/M services that couldbe described by CPT consultation codes using codes other than the ones designated by CPT, whichis the adopted code set under the law?A. The HIPAA regulations place certain requirements on health plans. One of those requirements is that “ahealth plan may not delay or reject a transaction, or attempt to adversely affect the other entity or thetransaction, because the transaction is a standard transaction.” In addition, a health plan must “[a]cceptand promptly process any standard transaction that contains code sets that are valid" and CPT-4 hasbeen accepted as the standard medical data code set for, among other things, physician services.However, the regulations also state that “all parties [must] accept these codes within their electronictransactions . . . [but does not require] payment for all of these services.”As of January 1, <strong>2010</strong>, <strong>Medicare</strong> will no longer recognize for payment CPT consultation codes. Instead,CMS is instructing providers to use the most appropriate office or inpatient E/M code to report E/Mservices that could be described by CPT consultation codes. This policy change was adopted after goingthrough notice and comment rulemaking and the payment rates for certain E/M services were increasedto maintain budget neutrality and to ensure all providers were being paid equivalently for equivalentwork. Further, CMS is not changing the definition of any of the existing E/M codes as a result of thispolicy.Claims with the CPT consultation codes are not rejected. Instead, <strong>Medicare</strong> accepts a claim that reportsa CPT consultation code, processes it, and returns the claim to the provider to report an E/M code for theservice that is recognized by <strong>Medicare</strong> for payment because CMS does not pay for the CPT consultationcodes. In other words, accepting claims with CPT codes (including consultation codes) from theadopted code set, and then processing (paying, denying, or returning the claim to the provider to report acode that is recognized by <strong>Medicare</strong> for payment) those claims in accordance with the MPFS ensuresthat <strong>Medicare</strong> is fulfilling its obligation to “accept” and “process” standard transactions that containvalid code sets.It is not intention of CMS to cause confusion or make the <strong>Medicare</strong> program more administrativelycomplex.<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 30<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


Additional InformationIf you have questions regarding this issue, refer to the “Contact Us” page of our Web site and select “PhoneUs” to call the Provider Contact Center.The official instruction, CR 6740, issued to <strong>Medicare</strong> MACs and carriers regarding this change may beviewed at http://www.cms.hhs.gov/Transmittals/downloads/R1875CP.pdf on the CMS Web site. Therelated MLN Matters article may be found athttp://www.cms.hhs.gov/MLNMattersArticles/downloads/MM6740.pdf on the CMS Web site.<strong>Medicare</strong> manuals are available at http://www.cms.hhs.gov/Manuals/IOM/list.asp on the CMS Web site.MLN Matters® Number: SE1010 Related Change Request Number: 6740The E/M documentation guidelines are available athttp://www.cms.hhs.gov/MLNEdWebGuide/25_EMDOC.asp on the CMS Web site.DisclaimerThis article was prepared as a service to the public and is not intended to grant rights or impose obligations. This article maycontain references or links to statutes, regulations, or other policy materials. The information provided is only intended to be ageneral summary. It is not intended to take the place of either the written law or regulations. We encourage readers to review thespecific statutes, regulations and other interpretive materials for a full and accurate statement of their contents. CPT onlycopyright 2009 American Medical Association.News from Cahaba for <strong>Home</strong> <strong>Health</strong> and <strong>Hospice</strong> ProvidersSuspended Claims—What You Need to KnowData analysis shows that providers often call the Provider Contact Centers (PCCs) with questions aboutclaims that are in a suspended status/location (S/LOC). These claims can be identified in the FiscalIntermediary Standard System (FISS) by the status code “S” (e.g., S B0100, S M50MR).All claims will temporarily suspend in different S/LOCs as they process through FISS, and generally,providers do not need to take action for claims in a suspended S/LOC. Suspended claims may require<strong>Medicare</strong> staff intervention and could remain in a suspended S/LOC for about 30 days. In some casesclaims may require additional processing time. For example:• Claims with <strong>Medicare</strong> Secondary Payer (MSP) involvement may be suspended for more than 60 daysto complete investigation and processing.• Claims selected for prepayment review require action by the provider, and therefore; may take up to 60days to complete processing. Claims in prepayment review generate an Additional DevelopmentRequest (ADR) (FISS S/LOC “S B6001”) to which the provider must submit the requested medicalrecord documentation. For more information about claims in the ADR S/LOC “S B6001”, refer to the“Additional Development Request (ADR) Process” Web page located on Cahaba’s Web site.<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 31<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


Claims in the “S MXXXX” status/location indicate that intervention by the <strong>Medicare</strong> intermediary(Cahaba) is required in order for the claim to continue processing. Providers may call the ProviderContact Center if their claims have been in the same “S MXXXX” status/location for longer than 30days, or 60 days if your claim contains MSP information, or was selected for prepayment review.Below are some common suspended S/LOC codes and what they mean:S/LOC Definition Provider Action Needed?S B0100 System processing NoS B6001S B90XXS M0XXXS MRADJS M50MRClaim needs additional information fromprovider (ADR).(XX=variety of location codes) System iscomparing claim data to beneficiary eligibilityinformation posted at the Common WorkingFile (CWF).(XXX=variety of location codes) Suspendedclaims/adjustment requiring manualintervention by <strong>Medicare</strong> staff.A <strong>Medicare</strong> Secondary Payer (MSP)adjustment has been received; claimsuspended while awaiting completion.Medical Review (moves claims to thislocation once medical documentation has beenreceived.) Please note: the review processmay take up to 60 days to complete.Yes, providers should return the medicaldocumentation within 30 days. Claimwill deny on 46 th day if documentationnot received.NoNo. Suspended claims/adjustments thatrequire Cahaba staff intervention may besuspended for about 30 days. Claimswith MSP information may be suspendedfor more than 60 days.In addition, claims are sent to the return to provider (RTP) (S/LOC “T B9997”) file because ofincomplete, incorrect or missing information. Because this is not a suspended S/LOC, claims in RTP arenot monitored by <strong>Medicare</strong> staff. It is your responsibility to take action to correct your claims in RTP. Foradditional information, go to the “Return to Provider” Web page located on Cahaba’s Web site. Claims thatprocess (S/LOC “P B9997”), reject (S/LOC “R B9997”) or are fully denied (S/LOC D B9997”) are also notmonitored by <strong>Medicare</strong> staff. Providers should, therefore, ensure that they monitor the status/locations toensure that they take appropriate action when necessary (examples: adjust or resubmit processed or rejectedclaims or appeal partially or fully denied claims).For more information about FISS claims processing topics, please review the following sections of the FISSReference Guide:• FISS S/LOC Codes – “FISS Overview” section• Viewing Billing Transactions in FISS – “Inquiry Menu” section• Submitting Corrections, Adjustments and Cancels Using FISS – “Claims Correction” sectionNoNo<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 32<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


Submitting <strong>Medicare</strong> Secondary Payer (MSP) Claims Where a Deductible orCoinsurance Payment is Due to the Primary InsurerCahaba has received some questions from home health and hospice providers about how to submit MSPclaims when the primary insurer applied the charges to the deductible or the beneficiary is responsible for acoinsurance. In particular, the providers inquired about the use of a specific code to report the primaryinsurer’s deductible or coinsurance amount on their <strong>Medicare</strong> claims. While there is no specific coding toreflect the amount applied to the deductible or the coinsurance amount, it is important that this informationis captured through the usual MSP coding. Below is an example of how this information is captured on anMSP claim.Example: A beneficiary has a working aged insurance (value code 12) where their deductible amount is$1,000.00; however, none of the deductible has been met. The beneficiary received 12 skilled nursing visitsat $100.00 per visit for total charges by the provider of $1,200.00. These charges are subject to thedeductible amount. The working aged insurance will only allow $75.00 per visit, and the provider agrees toaccept this as payment in full (value code 44). Since none of the deductible was met, the primary insurerapplied the $900.00 (12 visits @ $75.00 per visit) to the deductible.When submitting the claim to <strong>Medicare</strong>, the provider will report the following information, in addition tothe other data as required by their type of bill (TOB):UB-04 Form Locator Code Entered Dollar AmountOccurrence Code/Date (FL31-3424Date on the explanation ofbenefits (EOB) received fromthe primary insurer. (Note:Occurrence code 24 is onlyused when $0000.00 isreceived from the primaryinsurer.)Value Code (FL 39-41) 12 $0000.00Value Code (FL 39-41) 44 $900.00Note: Value code 44 is defined as the amount a provider agreed to accept from a primary insurer aspayment in full. Value code 44 should be submitted on a claim to <strong>Medicare</strong> when the amount agreed to is:• less than the charges; and• higher than the payment received from the primary insurer.In our example, the $900.00 that the provider agreed to accept as payment in full is less than the provider’stotal charges of $1,200.00, and is higher than the payment of $0000.00 received from the primary insurer.Value code 44 should not be used when:• the provider did not agree to accept a lesser amount than their charges from the primary payer aspayment in full; or• charges are equal to the amount the provider agreed to accept; or• payment from primary insurance is more than the amount they agreed to accept.<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 33<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


In addition, the provider will also enter the following data elements on their <strong>Medicare</strong> claim:UB-04 Form LocatorData EnteredPayer (FL 50) Line A: Primary insurer’s name (as it appears on ELGA pg. 9+)Line B: <strong>Medicare</strong>Provider Number (FL 51) Line A: Provider number for the primary payerInsured’s Name (FL 58) Line A: Name of the individual who carries the primaryinsuranceLine B: Beneficiary’s namePatient’s Relationship (FL 59) Line A: Enter code for the patient’s relationship to theindividual who carries the insurance (See listingavailable on the “<strong>Medicare</strong> Secondary Payer (MSP)Billing” quick reference tool.)Insured’s Unique ID (FL 60) Line A: Primary payer’s policy number (if available on ELGA)Line B: Beneficiary’s <strong>Medicare</strong> numberInsurance Group Name (FL 61) Line A: Group name or plan through which primary insurance isprovidedInsurance Group Number (FL 62) Line A: Insurance group number of the primary insuranceRemarks (FL 80)Any information to assist in the processing of the claim, such asthe:• employer’s name and address;• claim number/date on EOB received from the primaryinsurer;• explanation why primary insurer didn’t make a payment;• beneficiary’s deductible or coinsurance amount due to theprimary payerFor more information about how to submit MSP claims to <strong>Medicare</strong>, see the “Clarification on Submitting<strong>Medicare</strong> Secondary Payer (MSP) Claims/Adjustments” article available in the February 1, <strong>2010</strong>, <strong>Home</strong><strong>Health</strong> & <strong>Hospice</strong> <strong>Medicare</strong> A <strong>Newsline</strong>. In particular, review the table in the article that discusses themethod (electronically using the American National Standard Institute (ANSI) ASC X12N 837 4010-A1format, direct data entry (DDE) in FISS, or paper claim or adjustment) by which claims containing MSPdata elements must be submitted due to the changes implemented with Change Request 6426. Thisinformation is also available in the following article, “Clarification on Submitting <strong>Medicare</strong> SecondaryPayer (MSP) Claims and Adjustments and Reason Code 31265”.Additional information is available in the <strong>Medicare</strong> Secondary Payer Manual published by the Centers for<strong>Medicare</strong> & Medicaid Services (CMS) or on the Cahaba <strong>Medicare</strong> Secondary Payer (MSP) Web page. Formore information about using ELGA, see the “Checking Beneficiary Eligibility” section of the FISSReference Guide.<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 34<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


Clarification on Submitting <strong>Medicare</strong> Secondary Payer (MSP) Claims andAdjustments and Reason Code 31265Beginning October 1, 2009, <strong>Medicare</strong> regulations changed the way providers submit MSP claims andadjustments to <strong>Medicare</strong> in certain MSP situations. Based on questions we have received, it appears thatthere is still some confusion about when and how to submit MSP claims and adjustments.To think of this in simple terms, if the primary insurer made a payment or there is a possibility that theprimary insurer will make a payment, the claim cannot be submitted direct data entry (DDE) via the FiscalIntermediary Standard System (FISS). If the primary insurer will never make a payment (services areunrelated or primary insurer denied payment), the claim can be submitted DDE via FISS. Below is a tableto assist you with determining how an MSP claim can be submitted based on the MSP situation.MSP SituationServices are unrelated to No-fault (value code 14),Liability (value code 47) or Workers’Compensation (value code 15) recordPrimary insurance denied paymentPrimary insurance made payment. Billing<strong>Medicare</strong> secondaryPrimary insurance liable, but not paid promptly(within 120 days of when claim submitted toprimary insurer)Primary insurance liable. All charges applied todeductibleDDE viaFISSYesYesElectronically(837 format)NoNoPaper (UB-04)YesSee “Note”YesSee “Note”No Yes YesNoNoNoNoYesSee “Note”YesSee “Note”Primary insurance is Federal Black Lung Program No No YesNote: If your facility does not have a waiver to allow the submission of paper claims, you must submitthe claim DDE via FISS showing <strong>Medicare</strong> as the primary payer. The claim will reject. When theclaim appears in R B9997 (this may take up to 75 days), a hardcopy adjustment can then be submittedwith the appropriate MSP information.It is important to understand if the claim is required to be submitted electronically or on paper due to theMSP situation and the claim is returned to the provider (RTP) (status/location T B9997), the claim cannotbe corrected out of RTP – a new claim must be submitted using these same regulations. In addition,when submitting the new claim, take extra care to ensure that all necessary corrections have been madebefore submitting it.If an MSP claim or adjustment, that should have been submitted electronically (837 format), is submitted orcorrected (RTP) via FISS DDE, the claim will RTP with reason code 31265. This reason code narrativestates “MSP claims and adjustment cannot be entered via direct data entry (DDE) using FISS, or correctedout of your RTP file. If you need to correct a claim that is in RTP (status/location T B9997), you mustsubmit a new claim/adjustment electronically (using the 837 format) or on paper.” In addition the narrativereminds providers that “all errors, including those for which the claim RTP’d are corrected beforesubmitting the new claim.”<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 35<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


For more detailed information about how to submit MSP claims, we have updated the ‘Submitting MSPClaims and Adjustments’ Web page, athttps://www.cahabagba.com/rhhi/claims/msp/claims_adjustments.htm and the MSP quick reference tool, athttps://www.cahabagba.com/rhhi/education/materials/quick_msp.pdf on our Web site. Please utilize theseresources to assist you in deciphering submission of your MSP claims.Clinical Frequently Asked Questions (FAQs) for <strong>Home</strong> <strong>Health</strong> and <strong>Hospice</strong>Cahaba receives questions in a variety of ways. We hear from providers through the Provider ContactCenter (PCC), educational events and our Advisory Groups. Through tracking and data analysis Cahabalooks at trends and provides additional guidance and education on those “hot topics”. One way Cahabaresponds to these frequent inquiries is by providing more detailed guidance on our “Frequently AskedQuestions” (FAQ) Web page. Please consult these FAQs for clarification on commonly received homehealth and hospice coverage topics.On the FAQ Web page, links to clinical frequently asked questions for home health and hospice can befound under the ‘HH+H’ header. The following topics are examples of FAQs available. Please refer to the“Frequently Asked Questions” Web page for the full listing.<strong>Hospice</strong>:We understand the physician certifying a patient’s terminal prognosis must now write a statementregarding why they feel the patient meets the criteria of a six-month prognosis. Does this statementhave to be completed within the two days after start of care?As of October 1, 2009, hospice certifications/recertifications are now required to include a brief narrativeexplaining the clinical findings that support a patient’s life expectancy of 6 months or less. The Centers for<strong>Medicare</strong> & Medicaid Services (CMS) FAQ # 9969, released in January <strong>2010</strong> states: “The oralcertification/recertification should state that the patient is terminally ill with a life expectancy of 6 months orless, if the illness runs its normal course. Currently, we do not require the narrative to be provided orally atthe same time as the oral certification/recertification. However, we would remind certifying/recertifyingphysicians and hospices, that while the narrative (verbal or otherwise) is not required as part of the oralcertification/recertification, the essence of what the written narrative will ultimately entail in its explanationof the clinical findings that support a life expectancy of 6 months or less, is expected to be the basis for theoral certification/recertification. While a verbal narrative is not required as part of the oralcertification/recertification, the written narrative is required prior to filing a claim.” This narrative can bepart of the certification/recertification form or as an addendum to the form. If the narrative is part of theform, it must be located immediately before the physician’s signature. If the narrative is an addendum, thephysician must also sign the addendum immediately following the narrative.The form must also include a statement under the physician signature that attests to the fact that by signingthe form, the physician confirms that he/she composed the narrative and it is based on his/her review of thepatient’s medical record or his/her examination of the patient.<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 36<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


In addition, the narrative must reflect the patient’s individual clinical circumstances, and cannot containcheck boxes or standard language used for all patients. The narrative must be composed by the physicianperforming the certification/recertification, and cannot be composed by other hospice personnel.Cahaba has updated its Sample <strong>Hospice</strong> Certification Form to reflect these new requirements. To view thefinal rule mandating this change, go to the August 6, 2009, Federal Register.(Oct. – Dec. 2009 FAQ)I attended a Cahaba GBA training event where the <strong>Hospice</strong> Local Coverage Determination (LCD)was covered. Part III of the LCD lists co-morbidities that may support the terminal prognosis of ourpatients. If we list these co-morbidities, aren’t we responsible for the care of these conditions?Listing non-related diagnoses on the claim does not mean the hospice is required to provide care related tothose. The hospice is required to provide care only for the terminal diagnosis and related conditions.Listing diagnosis codes on the UB-04 form does not relate to what care a hospice provider is required toprovide. These co-morbidities can be vital in “painting the picture” of the patient’s true status, andsupporting the terminal prognosis.(Oct. – Dec. 2009 FAQ)<strong>Home</strong> <strong>Health</strong>:Some of our patients have a payment source other than <strong>Medicare</strong> when we begin providing home careservices to them and then they become eligible for <strong>Medicare</strong> while we are seeing them or their<strong>Medicare</strong> benefits may be subsequently activated. How do we bill <strong>Medicare</strong> when the patientbecomes entitled to <strong>Medicare</strong> in this situation?There are occasional instances when it is learned that a patient has become entitled to <strong>Medicare</strong> after thefact, and it is determined that the patient would have qualified for the <strong>Medicare</strong> home health benefit at thetime of entitlement (under a plan of care by a physician, qualifying skilled need/services provided and thepatient was homebound). When this occurs, a new start of care Outcome and Assessment Information Set(OASIS) assessment must be completed that reflects the date of the beneficiary’s change to this paymentsource. The OASIS items must be completed based on the beneficiary’s condition(s) and needs at the timethe patient was eligible for the <strong>Home</strong> <strong>Health</strong> benefit. A new start of care is required any time the paymentsource changes to <strong>Medicare</strong> Fee-for-Service (FFS). The OASIS is completed in order to obtain a <strong>Health</strong>Insurance Prospective Payment System (HIPPS) code and Claims-OASIS Matching Key code, which areneeded to bill <strong>Medicare</strong>. The OASIS must be submitted to the state for <strong>Medicare</strong> payment to be made.With that assessment, a Request for Anticipated Payment (RAP) may be sent to <strong>Medicare</strong> to open an HHPPS episode.For more information about coverage of <strong>Medicare</strong> home health services, please see the <strong>Medicare</strong> BenefitPolicy Manual (Pub. 100-2, Ch 7) or the Cahaba <strong>Home</strong> <strong>Health</strong> Coverage Guidelines Web page.Instructions for billing home health services to <strong>Medicare</strong> can be accessed from the <strong>Medicare</strong> ClaimsProcessing Manual, Pub. 100-4, Ch. 10. You may also need to review the information found in Ch. 25 ofthis manual. Billing instructions are also available on the Cahaba <strong>Home</strong> <strong>Health</strong> Claims Filing Web page.(Jan. – Mar. <strong>2010</strong> FAQ)<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 37<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


Can Cahaba provide guidance to us regarding whether we can use specific diagnosis codes as primaryon our home health claims?The diagnosis, whether primary or secondary, must originate with the physician, and be based on thepatient's condition. The primary diagnosis must be the chief reason for skilled home health care. Secondarydiagnoses should be those diagnoses that are directly related to the home health plan of care, or those thatmay impact the home health plan of care. There are five allowances for secondary diagnoses in M1022 onthe OASIS. If there are more than five secondary diagnoses, these should be included on the plan of care.Any diagnoses and codes used as the primary (M1020) or secondary (M1022) must follow the ICD-9-CMcoding guidelines. Payment does not impact the ICD-9-CM coding process, and Cahaba cannot provide anyadditional guidance beyond what is found in the ICD-9-CM coding guidelines.(Jan. – March 2008 FAQ – Reviewed Jan. <strong>2010</strong>)Compliance and Enforcement <strong>Medicare</strong> Drug Integrity Contractor (C&E MEDIC)and Benefit Integrity <strong>Medicare</strong> Drug Integrity Contractor (BI MEDIC)As you may know, the Centers for <strong>Medicare</strong> & Medicaid Services (CMS) has partnered with <strong>Medicare</strong> DrugIntegrity Contractors (MEDICs) to fight fraud, waste, and abuse in the <strong>Medicare</strong> Advantage (Part C) andPrescription Drug (Part D) programs. Recently, the MEDICs began assisting CMS on Parts C and Dcompliance and enforcement work as well.The purpose of this article is to inform you that there has been a change in MEDIC operations – instead ofoperating within a specified region, the MEDICs will now be based on function. Effective November 14,2009, the MEDIC for fraud, waste, and abuse issues is <strong>Health</strong> Integrity (HI) and the MEDIC for complianceand enforcement activities is SafeGuard Services (SGS), LLC. Over the past two months, the MEDICshave worked seamlessly to transition work functions without interruption to current activities. For yourconvenience, we have attached contact information for both MEDICs.The MEDICs are committed to partnering with you and each other to detect and prevent inappropriateactivity in the Parts C and D programs. Below are some examples of what each MEDIC is responsible forin the Parts C and D programs (not all inclusive):The fraud, waste, and abuse MEDIC or BI MEDIC, <strong>Health</strong> Integrity, handles activities such as:• Criminal violations of law• Kickbacks, fraud schemes• Billing for services not rendered• Requests for data or information to support ongoing law enforcement investigationsThe C&E MEDIC, SafeGuard Services, assists CMS with activities such as:• Agent/broker marketing misrepresentation issues• Inappropriate enrollment or disenrollment• Program audits and other assessments<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 38<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


Additionally, since there is potential for crossover between compliance and enforcement and fraud, waste,and abuse work, the MEDICs will continue to work collaboratively and refer issues to one another asappropriate.This should be a seamless transition for the <strong>Medicare</strong> beneficiaries as well who will still be able to contactthe MEDIC toll free number from anywhere in the United States to report concerns pertaining to <strong>Medicare</strong>Parts C and D program fraud, waste, and abuse. Any <strong>Medicare</strong> beneficiary who suspects fraud should callthe Benefit Integrity (BI) MEDIC at 1-877-7SafeRx or 1-877-772-3379 or their local Senior <strong>Medicare</strong>Patrol (SMP). Those with concerns about plan sponsor compliance or agent/broker misconduct can call 1-800-<strong>Medicare</strong>, their local State <strong>Health</strong> Insurance Counseling and Assistance Program (SHIP) or theirDepartment of Insurance (DOI).Anyone with <strong>Medicare</strong> who finds that someone is inappropriately using their personal information shouldcontact: 1-877-7SafeRx (1-877-772-3379) and the Federal Trade Commission’s ID Theft hotline at 1-877-438-4338 to make a report (TTY users should call 1-866-653-4261). For more information about ID theftprotection, visit www.FTC.gov/idtheft.As always, beneficiaries who feel in danger for any reason should call their local police departmentimmediately.For further information about the MEDICs, please visit our Web sites:<strong>Health</strong> Integrity, Benefit Integrity (BI) MEDIC: www.healthintegrity.org/SafeGuard Services, LLC Compliance and Enforcement (C&E) MEDIC: www.edssafeguardservices.edsgov.com/Availability of the Provider Contact Center (PCC)<strong>Medicare</strong> is a continuously changing program, and it is important that we provide correct and accurateanswers to your questions. To better serve the provider community, the Centers for <strong>Medicare</strong> & MedicaidServices (CMS) allows the provider contact centers the opportunity to offer training to our customer servicerepresentatives (CSRs). Listed below are the date and time the home health and hospice PCC (1-877-299-4500 and 1-866-539-5592) will be closed for training. We will continue to notify you of future CSRtraining dates in the <strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>Medicare</strong> A <strong>Newsline</strong>.CSR Training Date<strong>April</strong> 13, <strong>2010</strong>May 11, <strong>2010</strong>June 8, <strong>2010</strong>July 13, <strong>2010</strong>Time8:20—10:40 a.m. Central Time8:20—10:40 a.m. Central Time8:20—10:40 a.m. Central Time8:20—10:40 a.m. Central Time<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 39<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


<strong>Medicare</strong> Credit Balance Quarterly ReminderThis is to remind you to submit the Quarterly <strong>Medicare</strong> Credit Balance Report. The next report is due in ouroffice postmarked by <strong>April</strong> 30, <strong>2010</strong>, for the quarter ending March 31, <strong>2010</strong>.The <strong>Medicare</strong> Credit Balance Report (CMS-838) and certification must be postmarked by the date indicatedabove. If the information is received with a postmark date later than the date indicated above, we arerequired to withhold 100 percent of all payments being sent to your facility. This withholding will remainin effect until the reporting requirements are met. If no credit balance exists for your facility during aquarter, a signed <strong>Medicare</strong> Credit Balance Report certification is still required. Please include your<strong>Medicare</strong> provider number on the certification form.To ensure timely receipt and processing, please send the report to the following address:Attention: Credit Balance, Sta. 210Provider Audit and ReimbursementCahaba GBAP.O. Box 14537Des Moines, IA 50306-3537If sending overnight:Attention: Credit Balance, Sta. 210Provider Audit and ReimbursementCahaba GBA400 E Court AveDes Moines, IA 50309-2019For additional information, refer to the “Credit Balance Report” Web page. If you have any questions, or ifyou need a paper copy of the CMS-838 form, please contact the <strong>Medicare</strong> Credit Balance telephone line at515-471-7444.News from Cahaba for <strong>Home</strong> <strong>Health</strong> ProvidersNew Fiscal Intermediary Standard System (FISS) Inquiry Menu Screen for <strong>Home</strong><strong>Health</strong> ProvidersThe Change Request 6759, “Limitation on <strong>Home</strong> <strong>Health</strong> Prospective Payment System (HH PPS) OutlierPayments”, explains that effective January 1, <strong>2010</strong>, outlier payments made to each home health agency aresubject to an annual limitation. As a result, the new FISS Inquiry Menu screen, <strong>Home</strong> <strong>Health</strong> Pymt Totals(Map 1B41), was developed to allow you to track your outlier and HH PPS payment totals to ensure thatoutlier payments comprise no more than 10 percent of the HHA’s total HH PPS payments for the year.Data for up to three years will be available, beginning with calendar year <strong>2010</strong> HH PPS payment totals andoutlier payments. When each HH PPS claim is processed, FISS will compare these two amounts anddetermine whether the 10 percent has currently been met.<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 40<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


Please review the following instructions to access the <strong>Home</strong> <strong>Health</strong> Pymt Totals screen (Map 1B41) andhow to obtain your facility’s payment information.1. From the FISS Main Menu (Map 1701), type 01 in the Enter Menu Selection field and press Enter.2. From the Inquiry Menu, type 67 in the Enter Menu Selection field and press Enter.MAP1702 CAHABA GBA - RHHI ACPFAT01 XX/XX/XXXXXXXX INQUIRY MENU C<strong>2010</strong>14S XX:XX:XXBENEFICIARY/CWF 10 ZIP CODE FILE 19DRG (PRICER/GROUPER) 11 CLAIM COUNT SUMMARY 56CLAIMS 12 HOME HEALTH PYMT TOTALS 67REVENUE CODES 13 ANSI REASON CODES 68HCPC CODES 14 CHECK HISTORY FIDX/PROC CODES 15ADJUSTMENT REASON CODES 16REASON CODES 17ENTER MENU SELECTION: 67PLEASE ENTER DATA - OR PRESS PF3 TO EXIT3. The <strong>Home</strong> <strong>Health</strong> Payment Totals Inquiry screen (Map 1B41) appears:MAP1B41 CAHABA GBA - RHHI ACPFAT01 XX/XX/XXXXXXXX SC HOME HEALTH PAYMENT TOTALS INQUIRY C<strong>2010</strong>14S XX:XX:XXPROVIDERNPISEL YEAR OUTLIER TOTAL PAYMENT TOTALPLEASE ENTER DATA - OR PRESS PF3 TO EXIT4. Type your facility’s Provider Transaction Access Number (PTAN) (also known as your OSCAR/Legacyprovider number) in the PROVIDER field.5. Tab to the NPI field and type your facility’s National Provider Identifier (NPI), and press Enter.The <strong>Home</strong> <strong>Health</strong> Payment Totals Inquiry (Map 1B42) screen displays the total home health paymentand outlier totals for up to three years beginning with calendar year <strong>2010</strong> HH PPS payments.<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 41<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


MAP1B41 CAHABA GBA - RHHI ACPFAT01 XX/XX/XXXXXXXX SC HOME HEALTH PAYMENT TOTALS INQUIRY C<strong>2010</strong>18E XX:XX:XXPROVIDER XXXXXX NPI XXXXXXXXXXSELYEAR OUTLIER TOTAL PAYME NT TOTAL<strong>2010</strong> 0.00 2,999.990000 0.00 0.000000 0.00 0.00PROCESS COMPLETED --- PLEASE CONTINUEPLEASE MAKE A SELECTION, ENTER NEW KEY DATA, OR PRESS PF3 TO EXITThe payment information is updated only after HH PPS claims are in FISS status/location (S/LOC) P B9997(paid). In addition, only HH PPS claims with “TO” dates on or after January 1, <strong>2010</strong>, are included in thedata currently available.6. To display a list of claims that comprise the outlier and payment totals for a specific year, type an S inthe SEL field next to that year. Press Enter.MAP1B41 CAHABA GBA - RHHI ACPFAT01 XX/XX/XXXXXXXX SC HOME HEALTH PAYMENT TOTALS INQUIRY C<strong>2010</strong>18E XX:XX:XXPROVIDER XXXXXX NPI XXXXXXXXXXSEL YEAR OUTLIER TOTAL PAYMENT TOTALS <strong>2010</strong> 0.00 2,999.990000 0.00 0.007. The <strong>Home</strong> <strong>Health</strong> Payment Totals Detail (MAP 1B42) screen appears with individual claim data andthe corresponding value code amounts that reflect outlier and total payment amounts.MAP1B42 CAHABA GBA - RHHI ACPFAT01 XX/XX/XXXXXXXX SC HOME HEALTH PAYMENT TOTALS DETAIL C<strong>2010</strong>18E XX:XX:XXPROVIDER XXXXXX NPI XXXXXXXXXX YEAR <strong>2010</strong>DATE HIC NUMBER DCN VALUE CD 17 VALUE CD 64 VALUE CD 650102 123456789A 12312312312312IDR 0.00 0.00 1,999.990103 987654321A 98798798798798IDR 0.00 0.00 1,000.00PROCESS COMPLETED ---PRESS PF3-EXIT ENTER-CONTINUENO MORE DATA THIS TYPEIn the above example, no outlier payments were made to the two individual claims shown. The amountdisplayed below the “Value CD 65” field indicates that the HH PPS payment for the two claims were fromthe <strong>Medicare</strong> Part B trust fund.<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 42<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


Field DescriptionsThe following provides field descriptions for the <strong>Home</strong> <strong>Health</strong> Payment Totals Inquiry (Map 1B41) andthe <strong>Home</strong> <strong>Health</strong> Payment Totals Detail (Map 1B42) screens.<strong>Home</strong> <strong>Health</strong> Payment Totals Inquiry (Map 1B41) Field DescriptionsPROVIDERNPISELYEAROUTLIERTOTALPAYMENTTOTALYour Provider Transaction Access Number (PTAN) (also known as yourOSCAR/Legacy provider number).Your facility’s National Provider Identifier (NPI) numberSelection. This field is used to view claim data for a particular year.The calendar year in which the outlier and payment totals are comprised.The total outlier payments made on HH PPS home health claims for a calendaryear. Note that Requests for Anticipated Payment (RAPs), (type of bills 322 or332), are excluded from this total. The “TO” date on the HH PPS claimdetermines the calendar year in which the outlier is applied.The total HH PPS payment made on home health claims for a calendar year. Notethat Requests for Anticipated Payment (RAPs), (type of bills 322 or 332), areexcluded from this total. The “TO” date on the HH PPS claim determines thecalendar year in which the outlier is applied.<strong>Home</strong> <strong>Health</strong> Payment Totals Detail (Map 1B42) Field DescriptionsPROVIDERNPIYEARDATEHIC NUMBERDCNVALUE CD 17VALUE CD 64VALUE CD 65Your Provider Transaction Access Number (PTAN) (also known as yourOSCAR/Legacy provider number).Your facility’s National Provider Identifier (NPI) numberThe calendar year that was selected to view the claim detail data.The month and day of the “through” date of the claim.The beneficiary’s <strong>Health</strong> Insurance Claim number on the claim.The document control number of the claim.The dollar amount associated with the outlier payment on the claim.The dollar amount associated with the HH PPS payment from the Part A trustfund. For more information regarding the <strong>Medicare</strong> Part A trust fund, see the<strong>Medicare</strong> Claims Processing Manual (Pub. 100-4, Ch. 10, § 10.1.10.4)The dollar amount associated with the HH PPS payment from the Part B trustfund. For more information regarding the <strong>Medicare</strong> Part B trust fund, see the<strong>Medicare</strong> Claims Processing Manual (Pub. 100-4, Ch. 10, § 10.1.10.4)<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 43<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


Resolving Reason Code U538FThe Cahaba Customer Service Representatives (CSRs) are reporting increased questions from home healthproviders regarding Requests for Anticipated Payment (RAPs) and final claims that are returned to provider(RTP) for correction for reason code U538F. This edit fires when a RAP or final claim overlaps an existingepisode with the same provider number and the “FROM” date equals the episode’s start date OR a visit dateon a final claim falls within another episode established by another home health agency (HHA) or thebilling HHA.HHAs receive this error most often when they submit a second RAP for an episode where the final claim forthe same episode was previously submitted and rejected (FISS status/location (S/LOC) R B9997).Example: An HHA submits a RAP and final claim for an episode from 08/30/09 to 10/28/09. The finalclaim rejects to S/LOC R B9997. The HHA submits a second RAP for 08/30/09 – 08/30/09, which is sentto RTP (T B9997) with reason code U538F.Billing errors for this reason code may also occur when a home health agency submits a final claim and itcontains a visit date (line item date of service – LIDOS) that overlaps another HHA’s episode or the billingprovider’s subsequent episode. Example: ABC <strong>Home</strong> Care submits a final claim for episode 02/01/09 –04/01/09, which contains a LIDOS for 02/24/09; however, XYZ <strong>Home</strong> Care has already established anepisode from 02/03/09 to 04/03/09, which is posted to Common Working File (CWF) for the beneficiary.How to prevent/resolve:• Submit only one RAP and final claim for each episode of care. If the final claim for the episode rejects,do not submit a second RAP. The final claim will need to be adjusted or resubmitted. See the“Resolving Rejected <strong>Home</strong> <strong>Health</strong> Claims Caused by Billing Errors” Web page for assistance indetermining whether to adjust or resubmit a rejected home health final claim.• Prior to admission or submitting RAPs/claims to <strong>Medicare</strong>, access ELGH page 3 or ELGA page 4 toreview established episodes for beneficiary, which may impact your dates of service. See the“Additional Resources” below for instructions on accessing the beneficiary eligibility screens ELGHand ELGA.• Tip: You may need to use the APP DATE field to research older episodes.• If another HHA’s episode overlaps your dates of service AND you are disputing their episode, you mustfollow the instructions for resolving a transfer dispute prior to contacting Cahaba for assistance. Alsoreview the information regarding beneficiary elected home health transfers.• If another HHA’s episode overlaps your dates of service AND there is NO dispute regarding the dates ofservice, remove the overlapping dates from your claim. Instructions for deleting revenue lines areaccessible for the “Claims Correction” section of the FISS Reference Guide.Additional Resources• Checking Beneficiary Eligibility section of the FISS Reference Guide• Inquiry Menu section of the FISS Reference Guide• Resolving Rejected <strong>Home</strong> <strong>Health</strong> Claims Caused by Billing Errors quick reference tool<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 44<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


<strong>Medicare</strong> ForumDo you have a <strong>Medicare</strong> question or topic that you would like addressed in the <strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong><strong>Medicare</strong> A <strong>Newsline</strong>? If so, fax it to the Provider Outreach and Education (POE) department at 515-471-7584, or e-mail it to ianewsline@cahabagba.com. Please include your facility’s name and provider number,your name and telephone number. Responses to the inquiries received in this e-mail box will be providedonly through the <strong>Medicare</strong> Forum article, if appropriate. If you need an immediate response to a question,please contact a Customer Service Representative (CSR) for assistance by accessing the “Contact Us” pageon our Web site and select “Phone Us”. We also welcome your comments or suggestions on thispublication and other Cahaba GBA, LLC customer service activities.Q1. Can a patient continue to receive homecare and go to a Partial Hospitalization PsychiatricProgram? The patient is going 5 days a week for 4 hours a day. Does this become a homeboundstatus issue and should the patient be discharged?The only regulation we can find is in the <strong>Medicare</strong> Benefits Policy Manual Chapter 7, §30.1.1which states: Any absence of an individual from the home attributable to the need to receivehealth care treatment, including regular absences for the purpose of participating in therapeutic,psychosocial, or medical treatment in an adult day-care program that is licensed or certified by astate, or accredited to furnish adult Day-care services in a State should not disqualify anindividual from being considered to be confined to his home.A1. A patient may leave the home for health care treatment, and still be considered homebound. Thesetreatments may include dialysis, physician visits, wound care clinics, adult day care, or even PartialHospitalization Programs (PHPs), as long as the patient still meets the other criteria of homebound, andthese are fully documented in the patient’s medical record. It becomes much more difficult to supportthat a patient has health characteristics and limitations that would regularly confine him/her to theirhome when the patient leaves home for a treatment like PHP. The absences are routine, and the levelof activity in PHPs are routinely more than most homebound patients would be able to tolerate orparticipate in. A PHP includes clinically recognized therapeutic interventions, including group andfamily psychotherapy sessions, occupational, activity, and psychoeducational groups pertinent to thepatient’s illness. The medical record would need clear, strong evidence of the taxing effort it takes toleave the home in objective terms, describing the pain, dyspnea, poor balance, or other limitations.Q2. Does this mean that the patient can leave the home on a regular basis for therapeutic,Psychosocial or medical treatment that is provided in an adult day-care center only? Is thetherapeutic and psychosocial treatment separate from the medical treatment in the adult daycarecenter or are all 3 services only allowed if they are provided in an adult day-care center?The way we are reading this is that the therapeutic, psychosocial and medical treatments can beprovided on regular basis if they are being provided in a certified day-care center only. Are weinterpreting this correctly?<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 45<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


A2. Yes, you are correct. The language cited above in the <strong>Medicare</strong> Benefit Policy Manual, §30.1.1 isspecifically referring to adult day care. Absences from the home for other health care treatment arealso allowable, as long as it is clear the taxing effort, and inability for the patient to leave home isdocumented in the medical record.News from Cahaba for <strong>Hospice</strong> ProvidersNew Summary of <strong>Hospice</strong> Changes Quick Reference ToolA new quick reference tool, “Summary of <strong>Hospice</strong> Changes” is now available on our Web site. Because ofthe variety of changes affecting hospice billing, this tool is a helpful resource for hospices to learn abouteach of the Change Requests (CRs) and their specific requirements. The four page tool will assist hospicesin determining the specific billing requirements and the effective dates for each CR. Please ensure that theappropriate staff is aware of this tool. This tool is listed under “<strong>Hospice</strong> General Tools” on the “<strong>Hospice</strong>Quick Reference Tools” Web page.Clarification on Reporting of Social Worker Phone Calls by <strong>Hospice</strong>sThe Centers for <strong>Medicare</strong> & Medicaid Services (CMS) issued a Question and Answer (Q&A) on their Website clarifying previous instructions provided in Change Request (CR) 6440 about reporting social workerphone calls. CR 6440 states that “social worker phone calls made to the patient or the patient’s familyshould be reported…” However, CMS issued Q&A #9970 which further expands the reporting of socialworker phone calls. In addition, the CMS Q&A also changes our previous education, which was providedin the March 1, <strong>2010</strong>, <strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>Medicare</strong> A <strong>Newsline</strong> article, “Common Questions and NewReason Codes for Change Request 6440” (page 33). The entire CMS Q&A is listed below for yourreference.Q: In CR6440 CMS wrote that: “Report only social worker phone calls related to providing and orcoordinating care to the patient and family, and documented as such in the clinical records.” Doesthis sentence mean that only calls to the patient and family are to be considered for reporting?A: Because of the nature of a social worker's job, social workers perform a portion of their work withoutface-to face contact with either the patient or their family, which is why CMS allowed social workers torecord their phone calls as visits. For instance, off hours counseling of the patient and/or counseling offamily members who live out of town, would be considered appropriate and necessary when providedvia a phone conversation. However, it would be inappropriate to record every phone call that a socialworker makes on behalf of a patient.<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 46<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


As stated in CR#6440, only social worker phone calls that are necessary for the palliation andmanagement of the terminal illness and related conditions as described in the patient's plan of care (suchas counseling or speaking with a patient's family or arranging for a placement) should be reported.Given the nature of a social worker's job responsibilities, we would expect that almost all social workerphone calls reported would be between the social worker and either the patient or the patient's family. Itis feasible, however, that care coordination phone calls by a social worker to other than family memberscould be reportable. For example, if a SW facilitates alternate care arrangements for the patient in ascenario where the patient's primary caregiver suddenly becomes unavailable to provide care, those callsshould be recorded. Clinical judgment should be applied to determine if a particular social worker phonecall is reportable. In essence, report only social worker phone calls related to providing care to and/orcoordinating care of the patient for the palliation and management of the terminal illness and relatedconditions, as well as for the counseling of a patient's family, and document those phone calls as such inthe clinical records.To access this or other CMS FAQs, go to https://questions.cms.hhs.gov/cgibin/cmshhs.cfg/php/enduser/std_alp.php?p_sid=dEzdjlWjLength of Stay Proves to Be a Top Vulnerability in <strong>Hospice</strong> Medical ReviewThere are two widespread edits that will continue to select claims based on longer length of stays, due to thecontinued high error rate last quarter (October 1, 2009, through December 31, 2009). Edit topic code“5037T” selects claims based on a length of stay for greater than 730 days, and had a denial rate of 53percent. Edit topic code “5048T” selects claims based on a length of stay of 999 days, and had a denial rateof 76 percent.The majority of the denials received by providers were related to the six-month [180 days] terminalprognosis not being supported in the documentation. The <strong>Medicare</strong> Benefit Policy Manual, (CMS Pub. 100-02), Ch. 9, states an individual is eligible for the <strong>Medicare</strong> hospice benefit when that individual has aterminal illness with a life expectancy of six months or less if the terminal illness runs its normal course.Documentation is essential in “painting the picture,” especially for patients that have remained on thehospice benefit for an extended length of time, or the patients that have chronic illnesses or general decline.These diagnoses alone may not support a six month or less life expectancy, and documentation is dependedupon showing why the patient is hospice appropriate. The local coverage determination (LCD) for <strong>Hospice</strong>,“Determining Terminal Status”, identifies clinical indicators for hospice coverage for patients for certaindisease processes, as well as a section on general decline, and provides specific information on clinicalfactors that should be documented. In addition, the hospice quick reference tool, “Suggestions for ImprovedDocumentation to Support <strong>Medicare</strong> <strong>Hospice</strong> Services” provides guidance for improving yourdocumentation. The patient’s appropriateness for the hospice benefit must be clearly supported in themedical record from admission and throughout the hospice care provided.A much smaller percent of the claims were denied for missing, incomplete or untimely certification. Avalid physician’s certification stating that the patient has a terminal illness with a life expectancy of sixmonths or less if the terminal illness runs its normal course is a criteria for hospice eligibility. For the first90-day period of hospice coverage, the hospice must obtain a certification of the terminal illness by the<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 47<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


medical director of the hospice or the physician member of the hospice interdisciplinary group and theindividual’s attending physician if the individual has an attending physician. For subsequent periods, thecertification statement must be obtained from the medical director of the hospice or the physician memberof the hospice’s interdisciplinary group. If the hospice cannot obtain the written certification within twocalendar days of the beginning of the certification period, the hospice must obtain verbal certification withinthe two days. There are no standardized forms for this certification; however, the written certification mustinclude:1. A statement that the individual’s medical prognosis is that their life expectancy is six months or less ifthe terminal illness runs its normal course;2. Specific clinical findings and other documentation supporting a life expectancy of six months or less;and3. Must be dated and signed by the physician(s) (e.g., Medical Director and/or the patient’s attendingphysician).Since October 1, 2009, the certification must also include a brief narrative explanation of the clinicalfindings that supports a life expectancy of 6 months or less. This narrative can be part of thecertification/recertification forms, or as an addendum to the forms.• If the narrative is part of the form, it must be located immediately before the physician’s signature.• If the narrative is an addendum, the physician must also sign the addendum immediately following thenarrative.• Do not include check boxes or standard language used for all patients. The narrative cannot becompleted by other hospice personnel; it must be completed by the certifying physician.The narrative must also include a statement, located under the physician signature, that attests to the factthat by signing the form, the physician confirms that he/she composed the narrative based on his/her reviewof the patient’s medical record or his/her examination of the patient.For a sample of a certification form, refer to the hospice quick reference tool “Sample <strong>Hospice</strong> CertificationForm” on our Web site.<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 48<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


Cahaba Learning Corner<strong>April</strong> <strong>2010</strong> Education EventsTo register for educational events, go to the “Calendar of Educational Events” page on our Web site.Select the event title for registration instructions.‣ “Utah Association for <strong>Home</strong> Care (UAHC) Annual Meeting”Date: <strong>April</strong> 20, <strong>2010</strong>Cahaba GBA Presenters: Annette Lee and Janna ArndtLocation: Miller Campus of the Salt Lake City Community College in Sandy, UTDescription: This in-person event is sponsored by UAHC and will include educational workshopsfor both clinical and billing staff.Register: For more information about this event or to register, please contact Dan Hull at UAHCby calling (801) 487-8242 or email at homecareconnection@msn.com‣ “Missouri Alliance for <strong>Home</strong> Care (MAHC) Annual Conference”Date: <strong>April</strong> 26-28, <strong>2010</strong>Cahaba GBA Presenters: Annette Lee and Janna ArndtLocation: Tan-Tar-A Resort in Osage Beach (Lake of the Ozarks), MODescription: This in-person event is sponsored by MAHC. Cahaba staff will present jointworkshops for home care clinical and billing staff.Register: For more information about this event or to register, please contact Lee Ann Ball bycalling (573) 634-7772 or send an email to leeann@homecaremissouri.org‣ “Maryland National Capital <strong>Home</strong>care Association (MNCHA) Spring Meeting”Date: <strong>April</strong> 28, <strong>2010</strong>Cahaba GBA Presenters: Annette Lee and Janna ArndtLocation: Loyola University, 8890 McGraw Road, Suite 130, Columbia, MDDescription: This in-person event is sponsored by MNCHA. Cahaba staff will presentinformation applicable to both home health clinical and billing staff.Register: For more information about this event or to register, please contact Bernard Lorenz bycalling (410) 456-9099 or email at bernielorenz@me.com<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 49<strong>Medicare</strong> A <strong>Newsline</strong> Vol. 17, No. 7


Cahaba GBA Learning Corner‣ “Clinicians: Help Yourself with Self Service Technology” WebinarDate: <strong>April</strong> 29, <strong>2010</strong>Time: 12:00 – 1:30 p.m. Central TimeRegistration Deadline: <strong>April</strong> 26, <strong>2010</strong>Intended Audience: <strong>Home</strong> health and hospice clinicians, administrators, and QI coordinators.Description: Learn the resources provided to guide clinicians in understanding the home healthand hospice benefits, eligibility, coverage and documentation. Services and tools from the Centersfor <strong>Medicare</strong> & Medicaid Services (CMS) and Cahaba will be demonstrated.‣ “Online Courses” are computer-based and can be launched from the convenience of your owndesk. All courses are free and open to anyone.Course TitleAdjusting and Canceling ClaimsUpdatedAdvanced <strong>Hospice</strong> BillingAppeals ProcessBasics of ICD-9-CM Coding for <strong>Home</strong><strong>Health</strong> CliniciansBeginner <strong>Hospice</strong> BillingBeginner <strong>Home</strong> <strong>Health</strong> BillingCERT (Comprehensive Error Rate Test)Checking Claims StatusComprehending <strong>Medicare</strong> ClaimsProcessing<strong>Medicare</strong> Coding (Insight into)<strong>Medicare</strong> Cost Report (Introduction to)Medical Review (Getting a view of)Overview of <strong>Medicare</strong>DescriptionLearn how to adjust or cancel claims.Learn about advanced hospice billing topics.Learn about the <strong>Medicare</strong> appeals process.Learn the basics ICD-9-CM coding.Learn the basics of hospice billing.Learn the basics of home health billing.Learn about the CERT Program.Learn how to use the Fiscal Intermediary StandardSystem (FISS) to check the status of your claims.UpdatedLearn about <strong>Medicare</strong> claims processing.Learn the basics about <strong>Medicare</strong> coding.Learn the basics about the <strong>Medicare</strong> Cost ReportLearn the basics of the Medical review process.Learn the basics about the <strong>Medicare</strong> program.<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 50<strong>Medicare</strong> A <strong>Newsline</strong>Vol. 17, No.7


Cahaba GBA Learning Corner‣ Online Courses” (continued)Course TitleProvider EnrollmentVerifying Beneficiary EligibilityUpdatedDescriptionLearn about provider enrollment and how to apply.Learn how to identify various eligibilityinformation by using ELGA and ELGH.Please note these courses were designed specifically for providers served by Cahaba. You can findadditional national courses under the <strong>Medicare</strong> Learning Network.‣ Didn’t find what you were looking for? Visit our Web site—it provides a variety of valuableinformation and is continuously updated.‣ Stay Informed! Subscribe to the Cahaba E-mail Notification Service to receive the most currenthome health and hospice <strong>Medicare</strong> information. This service is free. When you subscribe, we’llsend you periodic e-mails telling you about new or updated information that has been added to ourWeb site. Your e-mail address will not be shared with other subscribers or given to advertisers, andonce subscribed, you can unsubscribe from the list, or change your e-mail address at any time.<strong>Home</strong> <strong>Health</strong> & <strong>Hospice</strong> <strong>April</strong> 1, <strong>2010</strong> 51<strong>Medicare</strong> A <strong>Newsline</strong>Vol. 17, No.7

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