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:: NAHC Report
 
NAHC Report: Issue# 2457, 6/25/2014
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ARTICLE ARCHIVES MEMBER RESOURCES eNEWSLETTERS CARING STORE
Medicare Claims Audits Focus on OASIS Submissions: A Guide to Responding to Denials
Hospices Experiencing Problems with Billings for Pumps
For Your Information: NAHC President Val J. Halamandaris Releases Video Announcing Senator Ron Wyden as a Keynote Speaker at this Year’s Annual Meeting
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Medicare Claims Audits Focus on OASIS Submissions: A Guide to Responding to Denials

The Medicare Supplemental Medical Review Contractor, SHS, has initiated audits of home health agencies in New England states with a focus on OASIS submissions in 2010. The audits were triggered by a recent OIG study that found a high incidence of Medicare paid claims where the home health agency did not have an accepted OASIS prior to the date of billing. Beginning in 2010, OASIS submission became a condition of payment for home health services under federal regulations at 42 CFR 484.55. While the rule references OASIS submissions, CMS has applied the rule to require the acceptance of an OASIS prior to billing as a payment requirement.

Until recently, the OASIS submission/acceptance condition of payment has not been audited or enforced. An OIG report highlighted this as a risk area for HHAs. Generally, an HHA will submit a batch of OASIS shortly after the start of episodes of care. The OASIS validation report then provides the HHA with a HIPPS code for billing purposes. In most circumstances, that OASIS report will be received prior to billing of the final claim on the episode. In the event that the OASIS submission is rejected, the HHA will be so informed and a corrected OASIS submission will occur. However, in some instances the HHA bills Medicare prior to the submission and acceptance of a compliant OASIS. In these circumstances, the HHA runs the risk of a claim denial based on the untimely (premature) billing.

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Hospices Experiencing Problems with Billings for Pumps

Some hospices have been experiencing problems with billing of infusion pumps on claims, and those claims are being caught in suspension.  NAHC and its affiliate Hospice Association of America (HAA) understands that the billing problems related to the pumps is a system-wide edit - in the Medicare Code Editor - that must be corrected by CMS. 

HAA has learned from CMS that while the edit likely won’t be completely corrected until January 2015, they have in development a workaround that will allow the MACs to override and allow claims to process with the pumps. CMS will likely have more information on this issue by the next Open Door Forum.

While the date for the next Open Door Forum has not yet been published, the expected date is July 9.

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NAHC President Val J. Halamandaris Releases Video Announcing Senator Ron Wyden as a Keynote Speaker at this Year’s Annual Meeting

NAHC President Val J. Halamandaris recently posted a video to NAHC’s home page announcing that Senator Ron Wyden (D-OR), the Chairman of the powerful Senate Finance Committee, will be a keynote speaker at this year’s Annual Meeting & Exhibition in Phoenix, AZ October 19 – 22.

In the video, Mr. Halamandaris states that Senator Wyden, “will have more to say than anyone on the future of healthcare…The good news is he is a great advocate for hospice and home care.”

To view the full video message, please click here.

To register to attend NAHC’s Annual Meeting, please click here.

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