The Centers for Medicare & Medicaid Services has confirmed that the edit to reject Medicare Advantage (MA) plan claims for not having a health insurance prospective payment system (HIPPS) code for home health services will not be activated until December 1, 2013. MA plans and the HHAs have until that time to make the necessary system adjustments. Additionally, CMS has instructed MA plans to communicate the HIPPS code requirements with providers so that they are able to make any changes to their systems or operations.
Several weeks ago, the National Association for Home Care & Hospice (NAHC) learned that, effective July 1, CMS will require HIPPS codes on all MA plan claims for home health and skilled nursing facility services. In a follow-up conference call, CMS officials informed NAHC that, although MA plans have been instructed to include a HIPPS codes on claims effective July 1, the edits for this requirement will not be turned on until sometime in September.
CMS will get back to NAHC with a firm date for implementation in the near future. NAHC has learned that the edits will be further delayed until December 1, 2013 giving agencies and vendors 5 months to prepare. CMS is requiring the HIPPS codes on home health claims in order to accurately price home health encounters.
Health plans are responsible for communicating with their contracted agencies how they plan to implement and enforce compliance with the requirement. Health plans have the authority to reject home health claims that do not include a HIPPS code. However, since there will be no consequence for MA plans that do not submit a HIPPS code for home health services until December, home health claims should not be held up further.
NAHC urges you to contact your health plans to determine what specifically they are - or are not - requiring with respect to the HIPPS code on claims.