From the folks who brought you IPS . . .

A glance at other provisions of the BBA

Although the Interim Payment System, per beneficiary caps, and surety bonds have been stealing all the thunder lately, there are other distant rumblings from the Health Care Financing Administration (HCFA) that are about as ominous for home health providers. Attending the recent National Association for Home Care (NAHC) policy conference in Washington, Hospital Home Health listened as HCFA and NAHC officials discussed the status of these various provisions:

· A to B shift.

HCFA delayed the change requiring that the 101st and all subsequent visits after hospitalization be billed under Medicare Part B rather than Part A. HCFA postponed the provision's implementation from April 1, 1998, to May 4, 1998, to make final adjustments to its Common Working File, which contains all Medicare beneficiary information, says Margaret Hoffman, associate director for regulatory affairs at NAHC. Providers had been scrambling to accommodate this "administratively seamless" promulgation, which necessitated sometimes extensive software revision to begin line-item billing for the first time.

Though granted a temporary reprieve, the provision promises home health agencies additional challenges. HCFA also reportedly plans to require sequential billing, which would prevent any particular claim's processing until all prior claims are paid or denied.

· Revised Conditions of Participation.

HCFA is on track to issue revised conditions of participation this summer, says Mary Vienna, director of the center for hospital community care at HCFA. The agency received more than 1,800 comments following its March 1997 proposed rule publication, she notes. Key provisions expected in the final rule include required staff criminal background checks and stiffer home health agency administrator qualifications.

· Proposed 15-minute billing increments.

Although there is no regulatory language or program memorandum demanding it, HCFA is considering a 15-minute billing increment provision. Being "pushed from the Hill," according to Janice Flaherty, director of the division of home care and therapy for HCFA, this new requirement would give HCFA a better feel for how long a visit takes.

· Branch office definition.

A BBA provision changes reimbursement based upon where agencies provide services as opposed to their main administrative office location. But a home health agency branch apparently means different things to different parties, including fiscal intermediaries. To instill consistency and diminish confusion, NAHC, on behalf of its members, has requested that HCFA outline the national criteria for a branch office, reports Mary St. Pierre, director of regulatory affairs.

· Homebound criteria study.

In the BBA, Congress mandated that HCFA study the Medicare homebound status criteria. Though the legislative language requires the Health and Human Services secretary to report study findings by Oct. 1, 1998, HCFA has not yet convened a study panel. It has however, pledged to seek industry input in fulfilling this requirement, St. Pierre says.

HHH will continue to monitor and report developments on these issues.