2012 Fee Schedules & Industry Updates
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H E A L T H C A R E U P D A T E |
January 6, 2012 |
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2012 Fee Schedules & Industry Updates |
For additional information and discussion on this topic, please get in touch with your regular HW&Co. professional or one of our Healthcare Advisors listed below. Paula Z. Reape, CPA, LNHA
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With the New Year upon us, all of us at HW&Co. would like to wish you a happy, healthy and prosperous New Year. As always, the New Year brings many changes to the Long-Term Care Industry. We are pleased to provide you with updates on some of these changes. In this issue: Medicare Updates 1. 2012 Part B Fee Schedules – Cuts Delayed by Two Months 2. Therapy Caps Exception Process Extended 3. Multiple Procedure Payment Reduction Remains in Effect 4. Keep Up on Your Part A Coinsurance Bad Debts! 5. 2012 Medicare Part A Coinsurance and Medicare Part B Premium and Deductible
Medicaid Updates 1. January 1, 2012 Medicaid Rates 2. Leave Day Payment Changes Effective January 1, 2012 3. New Quality Incentive System Reminders
MEDICARE UPDATES2012 Part B Fee Schedules - Cuts Delayed by Two Months After much uncertainty, both chambers of Congress agreed to a two-month delay of an expected 27% cut to the Medicare Part B fee schedules with passage of the Temporary Payroll Tax Cut Continuation Act of 2011. While many news releases have said that there will be "no cuts" to fee schedule payments, this does not mean that the fee schedules will not change effective January 1, 2012. There have been various adjustments to the factors that are used to calculate the payments. The Therapy and Radiology fee schedules provided below are effective from January 1, 2012 through February 29, 2012. Both Senate and House leaders have stated that they will work towards a year-long extension. We will keep you updated as to the status of any legislation that may extend the delay of the potential cuts. It is important to forward the fee schedules to your business office personnel to use for January bills. The schedules are available in PDF format in the links below. Our Revenue Cycle Consultants are available to assist with any billing questions you may have. In addition, if you use PointClickCare, we can electronically upload the fee schedules for you. Many of the fee schedules change or are updated on a quarterly basis. Please review the appropriate schedule based on the Centers for Medicare & Medicaid Services (CMS) updates. Check the CMS website on a regular basis for updates to these schedules. Please note that these schedules are not all inclusive. We have attempted to limit this information to the most commonly used Healthcare Common Procedure Coding System (HCPCS) codes for long-term care facilities. Many providers use only the therapy fee schedules. We have provided the lab, radiology, PEN and DMEPOS schedules in order to help you identify potential cost savings for your Medicare Part A and Managed Care residents. The fee schedules may be useful in negotiating and verifying the rates being paid to ancillary services providers and will provide guidance to ensure you are paying a cost effective rate. Ohio Medicare Part B Fee Schedules 2. Radiology 3. Clinical Diagnostic Laboratory 4. Parenteral & Enteral Nutrition Items & Services (PEN) - National 5. Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) Items: o Ostomy, Tracheostomy & Urology o Supplies o DME: non-billable, Part B by SNF
Therapy Caps Exception Process Extended The extension bill passed by Congress also included a two-month extension of the therapy caps exception process through February 29, 2012. The caps for physical and speech therapy (combined) and occupational therapy will be $1,880 for 2012, an increase of $10 from 2011.
The Multiple Procedure Payment Reduction (MPPR), which was introduced effective January 1, 2011, remains in effect for 2012. The MPPR cuts the practice component of the fee schedule payment for certain HCPCS codes by 25% when more than one kind of therapy is provided to a resident in a single day. Congress enacted the policy in the Physician Payment and Therapy Relief Act of 2010. CMS initially proposed a 50% cut, which was then reduced to 25% for services provided in an institutional setting (including SNFs) and 20% for services provided in an office setting. CMS believed that certain activities were being paid for twice even though they are only performed once for a given patient (e.g., greeting the patient, cleaning equipment and providing post-treatment assistance). As a reminder, Part B rates are comprised of three components: work, practice and malpractice. The work component covers the clinical services actually provided. The practice component covers expenses related to the administration of the practice (e.g., office, rent, wages). The malpractice component covers the cost of malpractice insurance. The MPPR policy only affects the practice component of the payment. The MPPR covers therapy services billed under 45 different HCPCS codes (click here for a list of affected codes). The last column of the therapy fee schedules provided above shows the payment that would be made under the MPPR for the affected therapy codes.
It is important to continually monitor your Part A coinsurance bad debts to ensure maximum reimbursement. Some facilities are leaving money on the table and reducing profit unnecessarily by not following CIGNA Government Services (CGS) requirements. It is imperative that you have a bad debt policy and that you follow the policy prior to writing off any coinsurance bad debts. CGS has stated that they will continue to follow all bad debt policies used by National Government Services. Common mistakes include not reducing coinsurance amounts claimed by partial payments from ODJFS, failing to remove the coinsurance amount from your aging and the resident accounts receivable history, improperly applying patient liability, and improper use of income statement accounts for recording Medicaid coinsurance bad debts on the general ledger (i.e., there is no impact on income for coinsurance amounts related to dual eligible residents since Medicare will currently reimburse 100% of the coinsurance that has not been paid by Medicaid).
2012 Medicare Part A Coinsurance & Medicare Part B Premium and Deductible Effective January 1, 2012, the Medicare Part A coinsurance rate for SNFs will increase to $144.50 per day for days 21 through 100. The Part B deductible will decrease to $140.00 per year. The standard Medicare Part B monthly premium for most beneficiaries will be $99.90. This represents a $3.50 increase for most beneficiaries who currently have the Social Security Administration (SSA) withhold their Part B premium and have incomes of $85,000 or less (or $170,000 or less for joint filers). If income exceeds $85,000 (single) or $170,000 (married filing jointly), the Medicare Part B premium may be higher than $99.90 per month.
MEDICAID UPDATES
January 1, 2012 Medicaid Rates With the pricing system changes implemented in H.B. 153, Medicaid rates for all Ohio nursing facilities will change effective January 1, 2012. These rates will be calculated using the average of the June 30, 2011 and September 30, 2011 Medicaid case mix scores. For those providers whose rates dropped more than 10% on July 1, 2011, this will be the last rate setting period with a stop loss provision. On July 1, 2012, all facilities will be “at price”. We have provided our cost reporting clients with estimates of their January 1 Medicaid rates. If you would like us to provide you with a rate estimate, please contact your HW Healthcare Advisor. ODJFS will not send rate settings to all providers. If you would like a formal rate setting, you can request a copy from ODJFS.
Leave Day Payment Changes Effective January 1, 2012 H.B. 153 changed the reimbursement for leave days paid for Medicaid residents in skilled nursing facilities. Historically, ODJFS paid up to 30 leave days per year at 50% of the facility’s Medicaid rate. Beginning January 1, 2012, leave days will only be paid at 50% if the facility has an occupancy of 95% or greater. All facilities with occupancy of less than 95% will be reimbursed only 18% of the facility’s Medicaid rate. Each resident remains eligible for up to 30 leave days in a calendar year. ODJFS has stated that they will initially calculate the occupancy percentage based on the 2010 Medicaid cost reports. When the 2011 cost reports have been received and processed, they will redetermine each facility’s leave day payment rate and make a retroactive adjustment, if necessary.
New Quality Incentive System Reminders Governor Kasich recently signed the new quality incentive system into law. Facilities must earn at least 5 of 20 available points in order to earn the full $16.44 quality incentive in their Medicaid rates on July 1, 2012. The new incentive replaces both the current quality incentive and your facility’s franchise permit fee reimbursement. With each point in the new system valued at $3.29 per day, any score of less than five points will have a significant negative impact on your facility’s operations. It is extremely important that you have the necessary policies in place and meet the requirements for at least five of the points. Please see our previous e-blast for more detail on the new system and its components. Medicare Updates 1. 2012 Part B Fee Schedules – Cuts Delayed by Two Months |
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