HCFA caves in on sequential billing requirement
By MATTHEW HAY
HHBR Washington Correspondent
WASHINGTON The Health Care Financing Administration (HCFA; Baltimore) instructed its fiscal intermediaries (FI) last week to discontinue sequential billing and payment policies for home health claims, effective July 1, 1999. The change followed a recent Senate resolution offered by Sen. Kit Bond (R-MO) and Sen. Jeff Bingaman (D-NM) that urged HCFA to examine the impact of sequential billing on home health agencies.
Congressional resolutions, while not legally binding, have become a favorite tool for the home care industry. The resolution regarding sequential billing offered by Bond, who plays a key role as chairman of the Small Business Committee, was reminiscent of a similar resolution he offered last spring that prompted HCFA to postpone its surety bond regulation. The National Association for Home Care (NAHC; Washington) was instrumental in helping to craft both resolutions.
The memorandum released by HCFA last week instructed FIs to remove all edits from their claims processing system by July 1. It added that, "Claims for which the prior claim has not yet been received or the prior claim has been received, but not finalized may now be processed upon receipt."
Bond’s resolution also noted the importance of making sure that the shift of certain home health claims from Medicare Part A to Part B is completed without any disruption in payment. That request refers to a requirement in the Balanced Budget Act of 1997 (BBA) that transferred the financial responsibility of Medicare home health visits from Part A to Part B after 100 visits.
The HCFA memorandum noted that this shift remains in effect. The first 100 visits will be counted in the order in which they are processed, according to HCFA. "Providers should also be encouraged to continue submitting current and future claims in sequence if possible," the memorandum added. "Processing of backlogged claims will be subject to current payment floor requirements."
"We are glad the industry was able to make Congress realize sequential billing was putting the squeeze on the industry," said Home Care Association of America’s (Jacksonville, FL) Scott Lara.
But Lara quickly pointed out that the change takes place on July 1, which is the same day 15-minute incremental billing begins. The 15-minute incremental billing provision, also required by the BBA, requires that as of July 1, claims for home health services must contain a code that identifies the length of time of each service visit in 15 minute increments.
Lara and other home care representatives said they are already busy educating House Ways and Means health subcommittee staff about the burden this requirement will place on agencies.
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