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Ron L. Nelson, PA
Rural Health Clinics Technical Assistance Conference Call Presentation, Dec. 14, 2004

RHC Billing Issues TOP


Slide 1: HEALTH SERVICES ASSOCIATES, INC

Ron L. Nelson, PA

www.hsagroup.net

2 East Main Street
Fremont, Michigan 49412
Ph: 231-924-0244
Fx: 231-924-4882 Email:nelson@hsagroup.net

RHC Billing Issues TOP


Slide 2: Understanding Billing Issues

  • RHC Services
  • Part B Services
  • Provider Based vs. Independent
RHC Billing Issues TOP


Slide 3: Part B Services

  • Inpatient - Professional Component
  • Lab - Technical
  • Xray - Technical
  • Diagnostics - Technical
RHC Billing Issues TOP


Slide 4: Vaccines

  • Flu
  • Pneumococcal
What information do I need to capture?
RHC Billing Issues TOP


Slide 5: Billing for Procedures

  • Endoscopies
  • Biopsies
  • Surgical Procedures (office based)
  • Commingling - defined
How can we correctly carve out procedures?
RHC Billing Issues TOP


Slide 6: MEDICAID – What is Covered?

  • Core Services
  • Other Services
  • Managed Care

How to analyze its impact

RHC Billing Issues TOP


Slide 7: Behavioral Health Services

  • Clinical Psychologist (PhD)
  • Clinical Social Worker (CSW)
  • Change in billing - do not use 910 Revenue Code effective August 2004. Use 900 Revenue Code to bill therapeutic Behavioral Health.
RHC Billing Issues TOP


Slide 8: Provider-Based Issues

  • Only Visits Billed to Intermediary
  • Ancillaries Billed Under Hospital Fee Schedule Hospital provider type
  • Exceptions - CAH - offsite clinics
RHC Billing Issues TOP


Slide 9: SNF Visits

  • Part A Stay, bill to Part B
  • Non-Part A Stay, bill to RHC Program
  • January 1, 2005 - bill all to RHC FI
RHC Billing Issues TOP


Slide 10: Telehealth

  • Bill to RHC Program
  • Q3014 code is paid separately from all all-inclusive rate
  • Bill for $20, transmission fee
  • Real Time Audio/Video Transmission
  • Separate service not subject to fee schedule restrictions
RHC Billing Issues TOP


Slide 11: Billing Crossovers

  • Problems with EOB
  • How to get Paid
  • How to Remain Compliant
RHC Billing Issues TOP


Slide 12: What constitutes a visit

  • Face to face encounter a patient and a physician, physician assistant, nurse practitioner, nurse-midwife, or visiting nurse.
  • Encounters with more than one health professional and/or multiple encounters with the same health profession that take place on the same day at a single location constitutes a single visit.
RHC Billing Issues TOP


Slide 13:

Pap/Pelvic

Bill Professional component to FI under revenue code 521
Bill Technical component to the Part B Carrier
See Medi 913-01

Colorectal Screening/Bone Mass/Prostate CancerScreening

Bill Professional component to FI under revenue code 521
Bill Technical component to the Part B Carrier
See Medi 799-00

Diabetic Outpatient Self-Management Training Services

Not reimbursed by Medicare at this time for services rendered by RHC.

RHC Billing Issues TOP


Slide 14: SERVICES RENDERED ON NON-VISIT DAYS

CAN BE COMBINED WITH CLAIMS WITH VISITS

RECOMMEND THEY BE WITHIN 30 DAYS

LIST ONLY THE DATE OF THE VISIT

SHOW CHARGES FOR ALL SERVICES

ADJUSTMENTS OK

OTHERWISE, HANDLED THRU COST REPORT

RHC Billing Issues TOP


Slide 15: LIST ACTUAL CHARGES

THE RHC SHOULD LIST THEIR ACTUAL CHARGE FOR EACH SERVICE. DO NOT AUTOMATICALLY DEFAULT TO LISTING
THE ALL-INCLUSIVE RATE AMOUNT ONLY.

RHC Billing Issues TOP


Slide 16: SIGNATURES

MEDICAL RECORDS-

ACCEPTABLE- HANDWRITTEN
ELECTRONIC
STAMPED + HANDWRITTEN

UNACCEPTABLE- STAMPED

STAMPED + INITIALS

CLAIMS-

ACCEPTABLE - HANDWRITTEN
ELECTRONIC
STAMPED
“SIGNATURE ON FILE”

RHC Billing Issues TOP


Slide 17: Medicare and Medicaid Reimbursement

Medicare reimbursement is on a reasonable cost basis as determined by the provider’s Medicare cost report.

However during the year, Medicare payments are based on an interim rate that is based on historical reasonable cost as reflected on filed Medicare cost reports.

RHC Billing Issues TOP


Slide 18: Medicare Reimbursement

Rural Health Clinics provide both

rural health clinic services
and
non-rural health clinic services

RHC Billing Issues TOP


Slide 19: Medicare Reimbursement (continued)

  • Rural Health Clinic Services (billed to intermediary on UB92) include:
    • Office Visits
    • Most nursing home visits
    • Home visits
    • Physician and mid-level services are reimbursed at the same rate
RHC Billing Issues TOP


Slide 20: Medicare Reimbursement (continued)

Non-RHC

99211 $20.14
99212 $35.20
99213 $48.47 most common
99214 $75.18
99215 $109.36

 

RHC Billing Issues TOP


Slide 21: Medicare Reimbursement (continued)

99211 $68.65
99212 $68.65
99213 $68.65 most common
99214 $68.65
99215 $68.65
RHC Billing Issues TOP


Slide 22: Medicare Reimbursement (continued)

99211 $75.00-$125.00
99212 $75.00-$125.00
99213 $75.00 most common
99214 $75.00-$125.00
99215 $75.00-$125.00
RHC Billing Issues TOP


Slide 23: Medicare Reimbursement (continued)

  • ONE RHC VISIT PER PATIENT PER DAY WITH FEW EXCEPTIONS
  • SECOND ENCOUNTER ON SAME DAY MAY BE BILLED IF UNRELATED (SORE THROAT AND BROKEN HAND)
  • MAY BILL FOR A PART A RHC VISIT AND A PART B NON-RHC VISIT (HOSPITAL VISIT) ON SAME DAY
RHC Billing Issues TOP


Slide 24: Medicare RHC Payments

Example if no patient deductible:

Assumptions: CPT code 99212
  Standard charge $58
  Medicare interim rate $100

Medicare pays 80% of the $100 or $80.00
Patient pays 20% of $58 or $11.60
Total payment $91.60

RHC Billing Issues TOP


Slide 25: Medicare RHC Payments (continued)

Example if no patient deductible:

Assumptions: CPT code 99212
  Standard charge $58
  Medicare interim rate $100

Medicare pays 80% of the $100 or $80.00
Patient pays 20% of $79 or $6.60
Total payment $95.80

RHC Billing Issues TOP


Slide 26: Medicare RHC Payments (continued)

If the patient owes deductible:

  • Patient pays 100% of charges up to the full deductible due
  • Medicare pays 80% of the interim rate less patient deductible
  • Patient pays 20% of charges less patient deductible
RHC Billing Issues TOP


Slide 27: Medicare RHC Payments (continued)

Example if patient owes deductible:

Assumptions: CPT code 99212
  Standard charge $58
  Medicare interim rate $100
  Patient deductible $25

Medicare pays 80% of the $100 - $25 or $60.00
Patient pays 20% of $58 - $25 or $6.60 plus $25.00
Total payment $91.60

RHC Billing Issues TOP


Slide 28: Medicare RHC Payments (continued)

Example if patient owes deductible:

Assumptions: CPT code 99212
  Standard charge $58
  Medicare interim rate $100
  Patient deductible $100

Medicare pays 80% of the $100 - $58 or $33.60
Patient pays 20% of $58 - $58 or $0.00 plus $58.00
Total payment $91.60

RHC Billing Issues TOP


Slide 29: Medicare RHC Payments (continued)

Example if patient owes deductible: EXTREME EXAMPLE

Assumptions: CPT code 99213
  Standard charge $79
  Medicare interim rate $70
  Patient deductible $79

Medicare pays 80% of the $70 - $79 or -$7.20
Patient pays 20% of $79 - $79 or $0.00 plus $79.00
Total payment $71.80

RHC Billing Issues TOP


Slide 30: Medicare RHC Payments (continued)

DOES IT MATTER HOW WE CODE A VISIT?
Patient payment is affected

  • Medicare considers over coding as a violation of the fraud and abuse regulations because of the additional reimbursement
  • Medicare considered under coding as a violation of the fraud and abuse regulations because it encourages patients to overuse the clinic
RHC Billing Issues TOP


Slide 31: Medicare non-RHC Billing and Payments

Services provided in the hospital (hospital visits, emergency room visits, operating room procedures)

Option A

RHC bill using the physician’s Medicare number on 1500 to part B carrier – payment based on fee scale

RHC Billing Issues TOP


Slide 32: Medicare non-RHC Billing and Payments

Services provided in the hospital (hospital visits, emergency room visits, operating room procedures

Option B

critical access hospital only

Method II Billing Election

Hospital must bill outpatient physician services with hospital outpatient charges on UB92 – physician portion of payment based on fee scale plus 12% (80% of 15%) and hospital payment unchanged

RHC bill for inpatient services using the physician’s Medicare number on 1500 to part B carrier – payment based on fee scale

RHC Billing Issues TOP


Slide 33: Medicare non-RHC Billing and Payments

Other non-RHC services provided (Skilled nursing home visit)

Until December 31, 2004

RHC bill using the physician’s Medicare number on 1500 to part B carrier – payment based on fee scale

After December 31, 2004

RHC bill using the clinic’s Medicare number on UB92 to intermediary – payment based RHC rate

RHC Billing Issues TOP


Slide 34: Medicare non-RHC Billing and Payments

Other non-RHC services provided (laboratory, radiology, EKG)

Option A

Hospital bill using the hospital’s Medicare number on UB92 to intermediary using bill type 14X – payment based on fee scale

RHC Billing Issues TOP


Slide 35: Medicare non-RHC Billing and Payments

Other non-RHC services provided (laboratory, radiology)

Option B

critical access hospital established

provider-based laboratory and radiology department
in RHC

Hospital bill using the hospital’s Medicare number on UB92 to intermediary using bill type 85X – payment based on cost

RHC Billing Issues TOP


Slide 36: Medicare non-RHC Billing and Payments

Other non-RHC services provided (non-encounters, other immunizations, other)

Option A

Clinic add to other bill which includes encounter and bill using the clinic’s Medicare number on UB92 to intermediary – additional reimbursement equal to 20% of charges (patient coinsurance) and cost will be included in cost per visit calculation and Medicare will pay 80% of additional cost

Option B

Clinic writes off charge and no bill is generated – loss of 20% of charges; however cost will be included in cost per visit calculation and Medicare will pay 80% of additional cost

RHC Billing Issues TOP


Slide 37: Medicare Reimbursement (continued)

Medicare bad debt reimbursement (part A deductibles and coinsurance only) at 100 percent of unpaid amount

  • Not paid by the patient as a reasonable/standard collection effort for 120 days from date of initial bill to patient has been made
  • Any denials by Medicaid as secondary payor as long as actually billed and denied - immediate
  • Documented charity care write-offs - immediate
RHC Billing Issues TOP


Slide 38: Medicare Reimbursement (continued)

Pneumonia and Influenza immunizations

  • Medicare will pay cost at the end of the year on the cost report.
  • Cost based reimbursement is two to three times standard payment levels
  • Do not bill Medicare. The clinic is only required to maintain a log
RHC Billing Issues TOP


Slide 39: Medicare Reimbursement (continued)

Pneumonia and Influenza logs required

Must include all patients

Separate log for pneumonia and for influenza

Information needed:

  • Date of service
  • Patient name
  • Patient Medicare number, if Medicare patient
RHC Billing Issues TOP


Slide 40: Bonus Payment Non RHC Part B Services

Health Professional Shortage Area:
HPSA Geographic
10%
Physician Scarcity Areas:
PSA
5%
Specialty Physician Scarcity Area:
SPSA
5%

www.cms.hhs.gov/providers/bonuspayment

Apply to physician services – not services provided by non physicians.

  


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