RHC Update
Seminar—Spring, 2005
Click
here to download the 2005 RHC Update Seminar Brochure
Spring is here once again, and
it’s time to prepare the Rural Health Clinic Medicare & Medicaid =
Cost
Reports. That means it’s a great time to get caught up on all that has
changed regarding Cost Reporting, Billing and Certification issues over the
last year. With this in mind, Healthcare Business Specialists is again offe=
ring
our popular, one-day Rural Health Clinic Update Seminars. The popularity of=
the
seminars is affirmed by a quote in Focus on Rural Health by Mary Amundson, =
MA.
She states ”attending these seminars is a virtual rite of spring...So=
me
participants have attended four or five years in a row.”
Most people are aware that the
12/24/2003 Final Conditions of Participation related to RHCs have been
rescinded. This means RHCs do not have to implement a Quality Improvement
Program and are not subject to being decertified at this time. We will disc=
uss
options related to the QAPI or Annual Evaluation process and compare the
responsibilities related to each of the programs. HIPAA Security procedures=
to
be completed by April 21, 2005 will also be covered.
New Medicare Cost Reporting Forms w=
ere
issued January 2005 which facilitate the preparation of the Cost Reports
electronically. We will discuss the new forms and the electronic filing
procedures and review billing changes that have occurred for 2005 (including
changes to skilled nursing billing, swing beds, Hospice, deductibles and new
preventive services). We will cover in detail the new 168-pg. book from
Medicare called The Guide to Medicare Preventive Services. We will also rev=
iew
billing for home care oversight, hospital services, office surgery, injecti=
ons,
radiology and laboratory billing.
To download a copy of the Brochure =
for
the 2005 Update Seminars, go to:
Click here to download the 2005 RHC Update Semi= nar Brochure
CMS
releases guidance on Preventive Services in January, 2005
In
January, 2005, CMS released guidance for billing preventive services in rur=
al
health clinics. This 168 page manual is a great resource for rural he=
alth
clinics with questions regarding billing preventive services including the
“Welcome to Medicare” Physical (IPPE), Pap Smears, Pelvic Exams,
Mammography, Cancer Screenings, Diabetes screening tests, and many other
preventive services. If you would like to download the book please go to:
&n=
bsp; =
;
http://www.cms.hhs.gov/medlearn/psguid.pdf
This publication is =
also
included in our RHC Update Seminar CD in Tab 7 - Billing and will be discus=
sed
in our Update Seminars.
&qu=
ot;Welcome
to Medicare" Physical (IPPE)
&qu=
ot;The
Medicare Prescription Drug Improvement and Modernization Act (MMA) of 2003
expanded Medicare’s coverage of preventive services. Central to the
Centers for Medicare & Medicaid Services' (CMS') initiative to move
Medicare toward a more prevention-oriented program is the new initial
preventive physical examination (IPPE) also referred to as the "Welcom=
e to
Medicare" Physical Examination. All beneficiaries enrolled in Medicare
Part B with effective dates that begin on or after January 1, 2005 will be
covered for the IPPE benefit. This one-time benefit must be received by the
beneficiary within the first six months of Medicare Part B coverage. The go=
al
of the IPPE, which also includes an electrocardiogram (EKG) are health
promotion and disease detection and includes education, counseling, and
referral to screening and preventive services also covered under Medicare P=
art
B."
The specific guidance regarding RHC billing is as follows:
• RHCs and FQHCs should follow normal billing
procedures for RHC/FQHC services.
• Encounters with more than one health professional
and multiple encounters with the same health professionals that take place =
on
the same day and at the same location constitutes a single visit.
• The technical component of the EKG performed at =
an
independent RHC/FQHC is billed to the carrier using the practitioner ID and
billing instructions.
• The
technical component of the EKG performed at a provider-based RHC/FQHC is bi=
lled
on the applicable TOB (Table 3) and submitted to the FI using the base prov=
ider
number and billing instructions.
• RH=
Cs and
FQHCs use revenue code 052X.
Effect=
ive
April 1, 2005, RHCs and FQHCs will no longer have to report additional line
items when billing for preventive and screening services on TOBs 71x. Except
for telehealth originating site facility fees reported using revenue code 0=
780,
all charges for RHC services must be reported on the revenue code line for =
the
encounter, 052x, or 0900.
|
F=
acility
Type |
Type of Bill |
Basis of Payment |
Revenue Code |
|
Rural
Health Clinic (RHC) (ind=
ependent
and provider-based) |
71X=
|
All=
-inclusive
Rate =
(for
professional services) |
52X |
Some reminders regarding preventive services. The
professional components of Pap smears and Pelvic exams are not subject to
medical necessity edits (only frequency) according to guidance from Riverbe=
nd
Government Benefits Administrator. An example of a preventive service
that may not meet medical necessity guidelines is Bone Density Scans. =
The
Technical Component would always be billable to the Part B Carrier/Base
(Mother/Hospital) Intermediary if frequency guidelines are meet; however,
Medicare may not consider it medically necessary for a physician to have a
face-to-face encounter with a patient and deny the professional component if
billed to the Intermediary. Physicians do not normally perform Bone
Density scans as they can easily be conducted by an X-Ray Technician. =
Other
publications on preventive services can be found at:
http://www=
.cms.hhs.gov/medlearn/preventiveservices.asp
CMS
issues Billing Instructions for Completion of Form CMS-1450 (UB-92)<=
/b>
Effective April 1, 2005 on November
12th & 19th, 2004
CMS issued billing instructions for completion of the UB-92 on
November 12, 2004. and effective April 1, 2005. This document provides
updated information regarding the proper completion of the 86 Form Locators=
on
the UB-92 Form. If you would like to download the document; just clic=
k on
the following hyperlink:
http://www.cms=
.hhs.gov/manuals/pm_trans/R368CP.pdf
The CMS description of this document is as follows:
"(Rev.368, Issued: 11-12-04, Effective: 04-01-05, Implementation:
04-04-05) This section contains Medicare requirements for use of codes
maintained by the National Uniform Billing Committee that are needed in
completion of the Form CMS-1450 and compliant X12N 837 version 4010A1
institutional claims. Instructions for completion are the same for inpatient
and outpatient claims unless otherwise noted.
If required data is omitted, the FI obtains it from the provid=
er
or other sources and maintains it on its history record. The FI need not se=
arch
paper files to annotate missing data unless it does not have an electronic
history record. It need not obtain data that is not needed to process the
claim. Data elements in the CMS uniform electronic billing specifications a=
re
consistent with the Form CMS-1450 data set to the extent that one processing
system can handle both. Definitions are identical. In some situations, the
electronic record contains more characters than the corresponding item on t=
he
form because of constraints on the form size not applicable to the electron=
ic
record."
In addition on November 19, 2=
004,
CMS issued 31 additional pages of billing instructions for rural health
clinics. This document can be accessed using the following link:
RHC UB-92 Billing Instructions issued November 19, 2004
These instructions indicate that, effective April 1, 2005, RHCs
will no longer have to report additional line items when RHCs bill Medicare=
for
preventive and screening services for RHCs and except for telehealth
originating site facility fees reported using revenue code 0780, all charges
for RHC/FQHC services must be reported on the revenue code line for the
encounter, 052x, or 0900.
The general billing instructions in chapters 9, 18 and 32 of
Pub.100-04, Medicare Claims Processing Manual are being updated to provide =
more
detailed instructions overall. CMS is eliminating the additional
line item reporting for preventive services in RHCs. Currently, RHCs are
required to report a second line item when certain preventive services are =
billed.
Currently, the second revenue code line for reporting preventive services m=
ay
contain charges. Except for the telehealth originating site facility fee
reported using revenue code 0780, all charges must now be reported on the
revenue code line for the encounter, 052x or 0900.
Only three types of services are billed by Rural Health Clinic=
s on
the UB-92:
NOTE: Telehealth is not an RHC/FQHC service. As such, the
originating site facility fee is billed in addition to the appropriate
encounter billed in revenue code 052x or 0900.
Values for the fourth digit of Revenue code 052x are: <=
span
style=3D'color:black'>
There does appear to be some discrepancies in the two versions=
of
the instructions. In the past, many RHCs have used revenue code 520 as
the revenue code for nursing home visits. The instructions appear to =
indicate
that revenue code 520 effective April 1, 2005 is reserved for FQHCs. I
asked for clarification for this point on the February 23, 2005 Open Door c=
all
with CMS and they did indicate that effective April 1, 2005, Revenue Code 5=
20
should only be used by FQHCs. Nursing Home visits should be billed us=
ing
revenue code 522 after April 1, 2005.
Swing Beds are Billable as RHC visits effective January 1, 20=
05
In the Febr=
uary
23, 2005 CMS Rural Open Door session, David Wargo indicated that effective =
January
1, 2005, RHCs can bill swing beds as a rural health clinic covered
service. Previously, CMS had considered a swing bed as being licensed=
as
a hospital bed and would not allow a rural health clinic to bill this servi=
ce
as a RHC service. (We billed the Part B Carrier/(Base/Mother/Hospital
Intermediary) and was paid fee-for-service for swing bed services.
For information on skilled nursing go to the following link:
http://www.cms=
.hhs.gov/manuals/pm_trans/R390CP.pdf
=
New RHC =
Cost
Report Forms issued in January, 2005
In January, 2005, CMS issued new cost reporting forms and
instructions for Independent Rural Health Clinics This transmittal adds new
material in the form of electronic cost reporting specifications to Chapter=
29,
Rural Health Clinic (RHC) Form CMS-222-92 to be completed by RHCs. This
transmittal also includes instructional revisions to insure consistency with
the electronic reporting specifications. The following is a list of the rev=
ised
cost reporting forms:
To downlo=
ad the
instructions and the Cost Report Forms in an Excel Spreadsheet; please clic=
k on
the following hyperlinks:
http://www.cms=
.hhs.gov/manuals/pm_trans/R7P229.pdf
To downlo=
ad the
new cost report forms in Microsoft Excel (Filename R7P229.zip) click here.<=
/span>
http://cms.hhs.gov/manuals/pm_trans/R7P229.zip
RHC Cost Reports should not be submitted to the Intermediary u=
ntil
these changes are reflected in the electronic cost report and filing system
that you are using in order to comply with new electronic filing
requirements. Also, you be sure to use the new forms to complete the =
cost
report.
HIPAA Se=
curity
Compliance due April 21, 2005
Are your Ready? Have you started?<= o:p>
RHCs have a big deadline coming up for HIPAA compliance.
HIPAA Security measures are to be implemented by April 21, 2005.
Unfortunately, many providers have had a Chicken Little attitude towards th=
ese
new regulations. Providers are thinking "Every one said the sky =
was
falling when we had Y2K, HIPAA - Privacy, HIPAA –transactions, =
and
nothing happened - Why should security be any different?” I am not su=
re
if HIPAA Security will be any different; however, RHCs should take steps to
comply with these regulations.
One of the best, easiest, and cheapest ways to comply is by go=
ing
to the SharpWorkGroup website and downloading tools, policies and procedure=
s,
and presentations regarding HIPAA Security. The Sha=
rpWorkGroup
Security work group goal is to inform providers of the HIPAA Security Rule.
With your help they want to provide the HIPAA Security help you need with a
reasonable effort to understand the rules and become compliant!
They focus on small providers and offer information and donate=
d or
developed tools that can assist in provider compliance efforts. In
addition, they plan to provide links to other web sites that may be of inte=
rest
to providers in their compliance efforts. They also do an outreach ed=
ucation
series to promote HIPAA Security awareness and provide broad guidelines for
provider compliance with the regulation.
SharpWorkGroup conducts frequent presentations and we highly
recommend attending one of their sessions. We have invited them to sp=
eak
at our RHC Update Seminars this spring. Here are just a few of the us=
eful
tools on the website. I would recommend downloading some of the many
presentations on the site.
|
D=
escription
|
Links to SharpWorkGroup Website <=
/span> |
|
Home=
Page Road=
Map Pres=
entation Asse=
ssment |
http://www.sharp=
workgroup.com/newsecurity.html http://www.sharpworkgroup.com/presentations/SHARPPhysicalSecur=
ity012605.pdf http://www.sharpworkgroup.com/security/HIPAA%20Security%20Self%2=
0Assessment.pdf |
End
of Newsletter
Mark R. Lynn
Healthcare Business Specialists
Telephone: (423) 899-0945
Toll-free: (800) 768-0278
Fax: (423) 892-9437
Email: mrlhbs@aol.com
Email: marklynn@bellsouth.net
Web: =
www.ruralhealthclinic.com
Healthcare
Business Specialists