Archive for March, 2017

March 28, 2017

Another Way for Them to Take Your Money

The requirement of submission of OASIS data within 30 days after the M0090 date has always been a part of the Conditions of Participation since the inception of OASIS. The OASIS had to be ready to submit prior to “dropping” of the RAP (Request for Anticipated Payment). Over the years, agencies have received denials in the Additional Development Request (ADR) process when the HIPPS code on the claim did not match the HIPPS code on the OASIS. However, OASIS was submitted to the Quality Information and Evaluation System (QIES) via the state, and claims were submitted to the Medicare Administrative Contractor (MAC) and the two weren’t compared automatically.

Several years ago, the OIG in their annual report, suggested that Medicare should deny claims for which the OASIS was not submitted on time (within 30 days of M0090). Medicare’s response was that they wanted providers to correct any errors in OASIS and when OASIS was corrected, the system saved the new date and not the date the OASIS was first submitted. Well, CMS has come up with a way to ensure that an OASIS is in the system for each claim. MACs have automated the denial of Home Health Prospective Payment System (HH PPS) claims when the condition of payment for submitting patient assessment data has not been met.

That new process will be effective for claims with dates of service on or after April 1, 2017. Upon receipt of a final claim with service dates after April 1, 2017, Medicare systems will check whether the corresponding OASIS assessment is present in the QIES. If the OASIS assessment is not found AND the receipt date of the claim is more than 30 days after the assessment completion date reported on the claim, Medicare systems will deny the HH claim.

While the regulation requires the assessment to be submitted within 30 days of completion, the initial implementation of this process will allow 40 days. Medicare systems will check for assessments used to determine the HIPPS code on the claim (Start of Care, Recertification and certain Resumption of Care assessments). Again, for the claim to be denied, the assessment must be both missing AND past due. When denying the claim, Medicare will apply the following remittance messages:

  • Group Code of CO
  • Claim Adjustment Reason Code 272

Prior to submitting an End of Episode claim, ensure the OASIS assessment has completed processing and was successfully accepted into the QIES National Database. The HHA can verify this by reviewing the OASIS Agency Final Validation Report or OASIS Submitter Final Validation Report for the submission which included the assessment. This may require communication between the provider’s billers and clinical staff that submits the OASIS to CMS.

The following information will be used to find the OASIS to check against the claim so double check this information prior to submission.

HHA CMS Certification Number (OASIS item M0010)

Beneficiary Medicare Number (OASIS item M0063)

Assessment Completion Date (OASIS item M0090)

Reason for Assessment (OASIS Item M0100) equal to 01 (SOC), 03 (ROC) or 04 (Recertification)

Tip: Get the M0090 date right! Remember that M0090 is usually technically NOT the date of assessment. Although, the time period does not include the quality checks, it does include the time it takes to complete best practices. For example, the patient has a medication issue that needs to be reported to the physician and the physician does not respond until the next day. That next day is the M0090 date. Another example: The physician is called for orders for best practices like falls risk, pain mitigation or diabetic foot assessment and care and confirms three days later the orders for those best practices. M0090 is that date, not the actual SOC visit date.

Warning: Medicare managed care plans also require an OASIS to be submitted for each episode and agencies have been denied ALL claims on ADRs because they have not submitted the OASIS.

Best Tip: Behind in your quality checks of OASIS assessments? Selman-Holman CoDR—Coding Done Right can help you catch up and keep up, and ensure accuracy and completeness in a timely manner. Contact Linda@selmanholman.com for more information.

You may also want to review MLN Matters Article MM9585, which is available at https://www.cms.gov/Outreach-and-Education/Medicare-Learning-NetworkMLN/MLNMattersArticles/Downloads/mm9585.pdf.

March 15, 2017

HAPPY ST. PATRICKS DAY & All THINGS GREEN

Wearing your favorite green clothes or accessories for this particular holiday is common, sharing a pint of green beer is considered festive, but actually ‘turning’ green can be a whole different game changer.

There are several instances when your skin and even your blood can become green. For instance, many people have worn jewelry that have caused their skin to become green. It is due to the copper in the metal. When people sweat, it reacts with the copper resulting in the corrosion of copper, hence salt compounds are created. The salt of copper is green.

Another example of greenish skin is due to anemia. An iron deficiency can cause the green tint. On the other side, if you take an iron supplement, your stools can turn green due to a significant effect on the digestive system. Same goes if you eat large quantities of leafy green vegetables or high doses of certain antibiotics, or lots of licorice jelly beans (but you didn’t hear that from me).

It has also been noted that blood has turned green after taking higher than prescribed doses of sumatriptan.

The most dangerous notations of green skin is organ failure, which requires due diligence when recognizing any discoloration of your skin.

 

So enjoy your corned beef and cabbage or your green beer but never dismiss this symptom if it presents without obvious explanation.

 stp