The Situation Report | April 29, 2024
The U.S. Centers for Medicare and Medicaid Services (CMS) has released Change Request (CR)14543 (https://www.cms.gov/files/document/r12577cp.pdf) that re-enforces the requirement for certified home health agencies C(HHAs) to report county codes on claims, and makes clarifications on the Notice of Admission (NOA) timeliness exceptions and reporting for telehealth visits.
County Codes
A recent report from the Office of Inspector General (OIG) noted that county code reporting on home health claims was incomplete and recommended Medicare edit claims to ensure the county code is present on all claims. CR 14543 creates such an edit in the Fiscal Intermediary Shared System (FISS) to require the presence of value code 85 and a Federal Information Processing System (FIPS) county code on all claims with Type of Bill 032x.
Exceptions to the NOA
CMS clarifies the criteria for requesting an exception to the NOA. The Medicare contractors shall grant an exception for the late NOA if the HHA is able to provide documentation showing:
- When the original NOA was submitted;
- When the NOA was returned for correction or was accepted and available for correction and;
- Evidence the HHA resubmitted the returned NOA within two business days of when it was available for correction or cancelled an accepted NOA within two business days and submitted the new NOA within two business days after the date that the cancellation NOA finalized.
- CHHAs should provide sufficient information in the Remarks section of its claim to allow the contractor to research the case. If the remarks are not sufficient, Medicare contractors shall request documentation. Documentation should consist of printouts or screen images of any Medicare systems screens that contain the information shown above.
CMS Clarifies Telehealth Reporting Requirements for CHHAs.
CHHAs must submit services furnished via telecommunications technology in line-item detail and with covered charges. This is a new instruction and a new requirement that will require HHAs to report all services furnished via telecommunications technology as covered charges.
Two occurrences of G0320 or G0321 on the same day for the same revenue code shall be reported as separate line items with the same date of service and with service units reporting 1. Services furnished via telecommunications technology are not considered by Medicare systems when enforcing requirements for matching visit dates on home health claims.
This is an already implemented exclusion CMS made last year. CMS later added this information to the narrative for Reason Code 31755 in FISS, requiring that the revenue code 0023 line-item date of service must match the date of service for the first in-person home health visit on the claim, however they did not issue a transmittal, nor did they update the manual at that time. This new language serves as a clarification and updates the manual with the appropriate instruction.