VA to Pay Non-Contract Providers Using Medicare Payment Models
October 29, 2014 08:40 AM
The Department of Veterans Affairs (VA) has begun issuing notices that inform home health providers of the VA’s revised payment methodology for skilled home health services. Beginning October 1, 2014, the VA will require an Outcome and Assessment Information Set (OASIS) to be completed to generate a health insurance prospective payment system (HIPPS) code in order to reimburse non-contracted home health agencies for skilled home health services using the Medicare home health prospective payment system (HHPPS). For non-contracted hospice providers the VA will continue to pay a per diem rate.
On February 18, 2010, the VA issued a proposed rule to implement certain payment methodologies for all non-contracted inpatient and outpatient health care professionals and providers, which included paying according to Medicare fee schedules and prospective payment systems, as applicable. When the final rule was published on December 17, 2010 the regulation included an exception for implementing the payment methodologies for home health and hospice services. The VA cited administrative and systems problems that prevented their ability to implement the Medicare payment system for home health and hospice services on such short notice. Since the final rule, the VA had delayed the effective date for the payment changes several times.
The effective date was finally set for June 1, 2014 with an implementation date of October 1, 2014.
The following was recently issued by the VA:
“The Chief Business Office Purchased Care (CBOPC) has announced the Veterans Health Administration (VHA) has revised the payment regulation related to non-VA medical care claims for home health and hospice services.
As part of a revision to Title 38 Code of Federal Regulations (CFR) § 17.56, the change in the payment regulation, also known as AN98, will impact non-VA medical care providers for home health and hospice services that do not have an existing contract or provider agreement in place. If VA does not have a contract, provider agreement, or negotiated rate in place, VA will pay non-VA home health and hospice claims utilizing the Centers for Medicare and Medicaid Services’ (CMS’) Home Health Prospective Payment System and hospice payment methodology, when possible. The effective date for the new payment methodology was June 1, 2014, however, the implementation date was on October 1, 2014.
Services included in the AN98 regulatory revision include:
Skilled home health care
Home health aides
Home respite care services
Home hospice care
Services not included in the regulation revision for home health care include:
Bowel and bladder care
Adult day care
Home respiratory care
Home dialysis care
Veteran-Directed and Community Based Services
Home infusion therapy
Adopting CMS pricing methodology for these home health and hospice schedules and services will allow VA Medical Centers to use their resources more efficiently to meet Veterans’ needs. The adoption of Medicare rates will also help ensure consistent, predictable medical costs, while also helping to control costs and expenditures. The AN98 implementation team has ensured the home health claims process, field procedure guide and associated training are updated to reflect this implementation.”
Agencies that do not have a contract or negotiated rate for their VA patients will be reimbursed by the HHPPS. According to the VA, any home health contract or negotiated agreement must be executed through a VA contracting office. The VA also clarified that for episodes beginning on or after October 1, 2014, the VA will require an OASIS and HIPPS code on claims. Initially, claims will not be rejected if the HIPPS code is not present, and will be paid at the current VA fee amount.
Home health agencies may bill the same as with Fee for Services Medicare including submitting a RAP with type of bill (TOB) 322, final claim TOB 329, 60/40 split percentage paid on initial claims, and 50/50 for subsequent claims, and LUPAs. The Central VA office will continue to issue guidance to the local VAs over the next several weeks.