Regulatory/Compliance Updates
March 4 th, 2008
General Regulatory/Compliance Updates//News
CareCentric Update, Software Updates Provided December 2006 thru December 2007 CareCentric exceeded its goal of providing updates for all applicable CareCentric products for PPS Reform and for reporting of additional data to describe services on Hospice claims in December, 2007, prior to the January 2008 deadline. Over the 12 month period prior to Jan., 2008, CareCentric has delivered the following software updates, prior to their respective mandated effective dates; National Provider Identifier data fields/EDI updates, the new HCFA 1500 form (approved by the OMB, 07/21/2006), the UB-04(approved by the OMB, 08/28/2006) and Hospice billing software changes for Line Item Billing which were effective on January 1 st, 2007.
For additional information on the above regulatory requirements, please refer to the specific details/website links listed below and/or contact your DME MAC /Fiscal Intermediaries.
Electronic Transaction and Code Set Standards Standards/Unique Id’s
CareCentric products currently meet national coding and transaction set standards. However, code sets (ICD-9, NDC, CPT-4, HCPCS) continue to be under review by HHS, and an NPRM for revisions to the adopted code set standards was expected in March, 2007, although it has not yet been released. In addition to the above, an NPRM for modifications to the electronic transactions and code sets was expected in June, 2007, however still has not yet been released. Once the final rule(s) for modifications to the electronic transactions and codes sets are published, we will begin work on any necessary programming modifications to all applicable CareCentric products. National Employer Identifier and National Provider Identifier data fields/EDI updates have already been made available in all of our software products. National identifiers for the Individual IDremain undefined by HHS, and the plans for the development of the National Health Plan ID have been withdrawn by CMS, as of February, 2006. As always, CareCentric will remain close and respond quickly to any developments that result in changes to these identifiers, transaction sets and code sets.
CMS Information
NPI Implementation Update - Summary of Key Medicare Dates, as posted on CMS’s website, 02/2008
MARCH 1ST IS A CRITICAL DATE!
Prior to March 1, 2008:
Claims with both an NPI and a Medicare legacy number are rejected if the pair is not found on the Medicare NPI Crosswalk.
Claims submitted with just a Medicare legacy number are being paid (unless of course, they have other errors that cause them to be rejected).
As of March 1, 2008:
Claims with both an NPI and a Medicare legacy number will continue to be rejected if the pair is not found on the Medicare NPI Crosswalk.
Claims without an NPI in the primary provider field will be rejected!
Claims with only a Medicare legacy number in the primary provider field will be rejected!
This means that you will not be able to get paid for any Medicare services you provide until you begin using your NPI. Also, if needed, you must correct any data which may be preventing an NPI/legacy match on the NPI crosswalk. The correction might require that you file a CMS-855 Medicare Provider Enrollment form with your Medicare carrier, A/B MAC, or DME MAC a process which can take a number of months to accomplish.
Test Your Medicare Claims Now!
After you have submitted claims containing both NPIs and legacy identifiers and those claims have been paid, Medicare urges you to send a small batch of claims now with only the NPI in the primary provider fields. If the results are positive, begin increasing the number of claims in the batch. (Reminder: For institutional claims, the primary provider fields are the Billing and Pay-to Provider fields. For professional claims, the primary provider fields are the Billing, Pay-to, and Rendering Provider fields. If the Pay-to Provider is the same as the Billing Provider, the Pay-to Provider does not need to be identified.)
Key Medicare NPI Implementation Dates
January 1, 2008 - As of this date, 837I electronic claims and UB04 paper claims without an NPI in fields identifying the primary provider (billing and pay-to) will be rejected. Legacy identifiers paired with NPIs in the primary provider fields on the claim will still be acceptable as will legacy-only numbers in secondary provider fields (see clarification below).
March 3, 2008 - Medicare fee-for-service 837P and CMS-1500 claims must include an NPI in the primary fields on the claim (i.e., the billing, pay-to, and rendering fields). You may continue to submit NPI/legacy pairs in these fields or submit only your NPI on the claim. You may not submit claims containing only a legacy identifier in the primary fields. Failure to submit an NPI in the primary fields will result in your claim being rejected or returned as unprocessable beginning March 1, 2008. Until further notice, you may continue to include legacy identifiers only for the secondary fields.
May 23, 2008 - In keeping with the Contingency Guidance issued on April 3, 2007, CMS will lift its NPI contingency plan, meaning that only the NPI will be accepted on all HIPAA electronic transactions (837I, 837P, NCPDP, 276/277, 270/271 and 835), paper claims and SPR remittance advice. This also includes all secondary provider fields on the 837P and 837I. The reporting of legacy identifiers will result in the rejection of the transaction. CMS will also stop sending legacy identifiers on COB crossover claims at this time.
Helpful MLN Matters Articles for Medicare NPI Implementation
- SE0725 – common enumeration errors in NPPES, helpful enumeration Dos & Don'ts, and how to use your NPI on Medicare claims
- SE0744 – Important NPI and Enrollment Information for Physicians and Non-Physician Practitioners
- MM5595 – Implementation of Medicare FFS Contingency Plan
See below for NPI Related MLN Matters Articles in the Related Links section to view these articles.
The Importance of Reporting Medicare Legacy Numbers in NPPES
The reporting of legacy numbers in the "Other Provider Identifier"/"Other Provider Identifier Type Code" fields in the National Plan and Provider Enumeration System (NPPES) will assist Medicare in successfully creating linkages between providers' NPIs and the identifiers that Medicare has assigned to them (such as PINs).
You should be aware that if you remove your legacy numbers from the "Other Provider Identifier"/"Other Provider Identifier Type Code" fields, linkages that Medicare has established using the reported Medicare legacy numbers will be broken and your Medicare claims could be rejected.
For more information, go to CMS’s NPI Implementation website:
http://www.cms.hhs.gov/NationalProvIdentStand/06_implementation.asp#TopOfPage
PPS Reform
On August 29 th, 2007 CMS released the final ‘PPS Reform’ rule, followed soon thereafter on October 4 th, 2007 by the ‘Final Rule Corrections’, which they are planning to implement in January, 2008. The rule was designed to give incentives to MC Home Health Agencies in order to provide more efficient care for Medicare beneficiaries, as well as to ensure that more appropriate payments are provided for MC home health agencies. The ‘PPS Reform’ final rule contains the first refinements to the MC home health prospective payment system (HH PPS) since the year 2000. This rule also contains the annual update to the Medicare HH PPS payment rates.
For additional information, please refer to the websites listed below:
http://www.cms.hhs.gov/center/hha.asp
http://www.cms.hhs.gov/apps/media/press/release.asp?Counter=2133
http://www.cms.hhs.gov/apps/media/fact_sheets.asp
http://www.cms.hhs.gov/HomeHealthPPS/downloads/CMS-1541-P.pdf
Validation of Non-Routine Supply Reporting on Home Health Prospective Payment System (HH PPS) Claims
As per transmittal #1371, dated November 2 nd, 2007:
SUMMARY OF CHANGES: This transmittal creates a new process to ensure non-routine supplies are reported appropriately on HH PPS claims. It allows a grace period where HHAs will receive alerts informing them of missing supply charges. After the completion of the grace period, claims with missing supply charges will be returned to the provider.
New/Revised Material
Effective Date: Home health episodes beginning on or after January 1, 2008
Implementation Date: April 7, 2008
Policy: Effective for claims for HH PPS episodes beginning on or after January 1, 2008, which are received after April 7, 2008, Medicare systems will ensure that all HH PPS claims report non-routine supply charges unless the HHA explicitly reports on the claim that such supplies were not reported. The 5 th position of the HIPPS code can contain two sets of values. One set of codes (the letters S through X) indicate that supplies were provided. The second set of codes (the numbers 1 through 6) indicate the HHA is intentionally reporting that they did not provide supplies during the episode. If a claim reporting a HIPPS code that indicates supplies were provided does not report non-routine supplies through the presence of either revenue code 027x or 0623, Medicare will take one of the following actions:
• If the claim is received on or after April 7, 2008, and before October 1, 2008, the claim will be paid and a message appended to the remittance advice warning that supplies should have been reported.
• If the claim is received on or after October 1, 2008, the claim will be returned to the provider for correction. The HHA must report charges for the non-routine supplies that they provided or correct their HIPPS code to accurately report that no such supplies were provided.
The period between April 7 and October 1, 2008 provides a ‘grace period’ in which HHAs may use the alert messages on their remittances to target examples of claims where required supply reporting is being neglected.
During this period, HHAs are expected to make any necessary changes to their administrative processes to ensure this reporting is completed.
Revised… Validating Required Reporting of Supply Revenue Code
With the advent of the refined HH PPS, the payment system includes a separate case-mix adjustment for non-routine supplies. Effective for HH PPS episodes beginning on or after January 1, 2008, non-routine supply severity levels will be indicated on HH PPS claims through a code value in the 5th position of the HIPPS code. The 5th position of the HIPPS code can contain two sets of values. One set of codes (the letters S through X) indicate that supplies were provided. The second set of codes (the numbers 1 through 6) indicate the HHA is intentionally reporting that they did not provide supplies during the episode. See section 10.1.9 for the complete composition of HIPPS under the refined HH PPS.
HHAs must ensure that if they are submitting a HIPPS code with a 5th position containing the letters S through X, the claim must also report a non-routine supply revenue with covered charges. This revenue code may be either revenue code 27x, excluding 274, or revenue code 623, consistent with the instructions for optional separate reporting of wound care supplies.
Medicare systems will return the claim to the HHA if the HIPPS code indicates nonroutine supplies were provided and supply charges are not reported on the claim. When the HHA receives a claim returned for this reason, the HHA must review their records regarding the supplies provided to the beneficiary. The HHA may take one of the following actions, based on the review of their records:
• If non-routine supplies were provided, the supply charges must be added to the claim using the appropriate supply revenue code.
• If non-routine supplies were not provided, the HHA must indicate that on the claim by changing the 5th position of the HIPPS code to the appropriate numeric value in the range 1 through 6.
After completing one of these actions, the HHA may return the claim to the Medicare contractor for continued adjudication.
For additional information, please see Transmittal #1371, at:
http://www.cms.hhs.gov/Transmittals/Downloads/R1371CP.pdf
Based on the above, CareCentric will be modifying its Home Health PPS software products to accommodate the proper reporting of PPS Supplies prior to the October 1 st, 2008 effective date. These changes will apply to both paper and electronic claims.
Hospice, Reporting of Additional Data to Describe Services on Hospice Claims
CMS Notification, MLN Matters on CR 5745, Revised January 2008
Billing Instructions for Hospice Payment Based on Location of Service
The original Change Request 5745 was released October 15, 2007 to be effective January 1, 2008. The article was revised in January 2008 to add references to CR 5567 (Reporting of additional data to describe hospice services on claims) and CR 5745 (documenting location of inpatient hospice level of care). CR 5745 announced for routine home care and continuous home care a National Uniform Billing Committee (NUBC) approval of a new value code (G8) to identify where inpatient hospice services are delivered and redefined value code 61 to apply to place of residence where routine home care and continuous home care are delivered only. It was noted that “if hospice services are provided to the beneficiary in more than one CBSA area during the billing period, you should report the CBSA that applies at the end of the billing period.”
Based on the above, CareCentric will be modifying it’s Hospice software products shortly to report both value code ‘G8’ and ‘61’ when both home care and facility care are provided. These changes will apply to both paper and electronic claims.
CMS Notification, 11/02/2007
CMS has issued a revision to Transmittal 1304 (Change Request 5567) which was entitled "Reporting of Additional Data to Describe Services on Hospice Claims." This revision changes the effective date of Transmittal 1304 for additional service data on the claims only. Reporting of additional service data on hospice claims is now OPTIONAL for hospices effective on January 1, 2008. This reporting now becomes MANDATORY on July 1, 2008.
Hospices should note that all Medicare systems changes described in Transmittal 1304 will be implemented January 7, 2008 as scheduled. This is to allow hospices to exercise their option to beginning reporting for January dates of service. The changes are necessary for the optional information to be received and processed correctly.
It is important to note that this also means that the Medicare system edit restricting the use of V-codes as the principal diagnosis on a hospice claim will still go into effect for January 1, 2008 dates of service. Hospices must ensure they cease reporting V-codes as a beneficiary's principal diagnosis for January 1, 2008 dates of service whether or not they exercise their option to report additional service data.
The revision is found in Transmittal 1304 which can be accessed at the CMS Transmittals website: http://www.cms.hhs.gov/Transmittals/2007Trans/list.asp
Revised 1500 Form
The CMS-1500 form is the standard paper claim form used by a non-institutional provider or supplier to bill Medicare carriers and Medicare administrative contractors (MACs). The 1500 form is only accepted from institutional providers that are excluded from the mandatory electronic claims submission requirement. The 1500 form is also used to bill Medicaid State Agencies. The CMS-1500 claim form was updated to accommodate the National Provider Identifier (NPI). The major difference between Form CMS-1500 (08/05) and the prior form CMS-1500 is the split provider identifier fields. Although HIPAA does not require that NPI’s be reported on paper claim forms, HIPAA does allow health care plans the option to require NPI’s on paper claims. Medicare has chosen to require NPI’s on paper claim forms.
The deadline for required submission of the Form CMS-1500 (08-05) is July 2 nd, 2007.
http://www.cms.hhs.gov/MLNMattersArticles/downloads/MM5616.pdf http://www.cms.hhs.gov/MLNMattersArticles/downloads/MM5060.pdf
http://www.cms.hhs.gov/MLNMattersArticles/downloads/MM5595.pdf
http://www.cms.hhs.gov/MLNMattersArticles/downloads/MM4293.pdf
http://www.cms.hhs.gov/ElectronicBillingEDITrans/16_1500.asp
UB-04 Form
The UB-04, which is only accepted from institutional providers that are excluded from the mandatory electronic claims submission requirement, incorporates the National Provider Identifier (NPI), taxonomy, and additional codes. At its February 2005 meeting, the National Uniform Billing Committee (NUBC) approved the UB-04 (CMS-1450) as the replacement for the UB-92. Starting May 23, 2007, all institutional paper claims must be submitted on the UB-04. The UB-92 will no longer be acceptable, even as an adjustment claim, after May 22, 2007.
http://www.cms.hhs.gov/MLNMattersArticles/downloads/MM5072.pdf
Hospice Line Item Detail
This transmittal provides billing instructions for hospices and requirements for Regional Home Health Intermediaries regarding billing continuous home care services on separately dated line items in 15 minute time increments and reporting HCPCS codes to identify the service location of all hospice levels of care.
EFFECTIVE DATE: *January 1, 2007
IMPLEMENTATION DATE : January 2, 2007 http://www.cms.hhs.gov/transmittals/downloads/R1011CP.pdf
Related Websites:
CMS NPI Implementation Information
http://www.cms.hhs.gov/NationalProvIdentStand/06_implementation.asp
CMS Hospice Information
http://www.cms.hhs.gov/center/hospice.asp
CMS PPS Information
http://www.cms.hhs.gov/HomeHealthPPS/01_overview.asp
National Uniform Billing Committee (NUBC) – UB-04 Form News
http://www.nubc.org/
National Uniform Claims Committee (NUCC) – Revised 1500 Form News
http://www.nucc.org/
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