2013 Home Health PPS Proposed Rule Webinar Q&A, Handout

PPS Proposed Rule.

On August 9th, HEALTHCAREfirst hosted a webinar explaining the 2013 Proposed Rule for Home Health and Hospice.  We had a great turnout!  If you missed the webinar, we have made a recording for you to view now.

Click here to view the webinar handout.

There were several questions asked during the webinar.  We have included those questions and answers below.  If you have other questions, please comment below.

When CMS starts denying Home Health claims for Physicians not found in PECOS are they going to deny all claims that include orders from that Doctor?  E.g., if Doctor orders X-ray and isn’t listed in PECOS, will CMS deny payment for that X-ray? This might motivate Doctors.

For the phase 2 edits, if the Ordering/Referring Provider does not pass the edits (reason code 37236 and 37237), the claim will be denied. This means that the billing provider will not be paid for the items or services that were furnished based on the order or referral.

We use the Chris Endres website for ICD9 which is extremely helpful.  Is there a resource like this planned that you are aware of?

I am not familiar with Chris Endres, but after reviewing his ICD-9 site it appears to be similar to the CMS ICD-10 free lookup tool.

If a patient has both Hospice and Home Health, and Hospice lists a comorbidity that is primary to Home Health, will that cause Home Health to be unbillable or is it just primary Dx?

I sent this question to our Billing Services department. Normally when a patient has both Hospice and Home Health seeing a patient, the Home Health is addressing something the Hospice cannot and the primary Home Health diagnosis would be specific to just what applies to Home Health. We don’t recommend listing the diagnosis you are using as the Home Health primary diagnosis as one of the Hospice co-morbidities and chances are it will not be something that applies to Hospice.

The proposed Alternative Sanctions seem somewhat similar but maybe even more onerous than those for Nursing Homes.   Has anyone looked at how those sanctions affected Nursing Homes and their industries? 

Not to my knowledge but I will research this.

Is PECOS for Hospice as well?

While all provider and supplier organizations need to be enrolled in PECOS, there are currently not any PECOS edits geared towards Hospice claims. To my knowledge CMS doesn’t have any currently planned. I followed up with NAHC for their thoughts on this and they said they do suspect that PECOS edits for Hospice will happen at some point in the future.  Please see the bottom of page 2 of the Medlearn Matters PECOS fact sheet for the full definition of all provider and supplier organizations.