Home Health Code Update: Modifier Code Rescinded, Place of Service Clarified
April 8, 2013 07:27 PM
In Transmittal 2650, dated February 1, 2013, the Centers for Medicare and Medicaid Services (CMS) announced plans to require home health agencies to report new claims data. The new data requirements, which would be effective July 1, 2013, included “place where services were provided” and a modifier to identify visits made solely to provide services ordered by physicians other than the certifying physician.
The National Association for Home Care & Hospice (NAHC) discussed its concerns about these new coding requirements with CMS. NAHC told CMS that a place of service code that did not define “assisted living facility” would result in unreliable data - since there are various facility titles and definitions across the country. Additionally, NAHC asked that clarification be provided for the non-certifying physician modifier and that additional time be given for software vendors to write programs and home health agencies to implement them.
On April 2, 2013 CMS issued Transmittal 2680 rescinding and replacing 2650, which is available here.
Non-certifying Physician Modifier Requirement Rescinded
In Transmittal 2680, CMS announced its decision to remove the requirement to report a modifier where additions/changes to the plan of care that result in an increased number of visits/increased services or a change in the type of services. NAHC supports CMS’ decision to rescind this requirement - as it would have created a new burden for home health agencies, clinicians, and software vendors.
Site of Home Health Services Refined
Although CMS retained its plans to require home health agencies to report the location where services are provided beginning on July 1, 2013, in Transmittal 2680 CMS further defined assisted living facilities. According to the Transmittal, assisted living facilities are places of residence “as defined by the State in which the beneficiary is located.” This change in policy will not appear in the Medicare Benefit Policy Manual until CMS’ next manual update, which is expected by January 2014.
The HCPCS codes and their definitions, as reported in February, will remain unchanged:
Q5001: Hospice or home health care provided in patient’s home/residence
Q5002: Hospice or home health care provided in assisted living facility
Q5009: Hospice or home health care provided in place not otherwise specified
Transmittal 2680 reiterated previous instructions for reporting the location where services were provided. The location must be reported along with the first billable visit in an HH PPS episode by reporting an additional line item with the same revenue code and date of service, reporting one of the three Q codes (Q5001, Q5002, and Q5009), one unit and a nominal charge (e.g, a penny). If the location where services were provided changes during the episode, the new location should be reported with an additional line corresponding to the first visit provided in the new location.