TARA BANNOW May 29, 2019
Most people don't put much thought into whether
to spell out "Street" or use the abbreviated
"St." in an address.
Come July, though, hospitals that choose the
wrong one won't get paid by Medicare, at least temporarily, for certain
outpatient services. That's when the CMS will start enforcing its exact match
program. It requires that the addresses hospitals use on their claims for
services provided at off-campus, outpatient departments exactly match those
entered for its Medicare enrollment of those locations.
And when CMS says exactly, they mean exactly. In
a test run last summer, the agency found a number of discrepancies—mainly minor
things like writing out "suite" or "road" versus
abbreviating them to "Ste." or "Rd." But even those
would be enough to have claims returned.
"That's how detailed this exact match is
going to be," said Monica Hon, vice president with the healthcare
consultancy Advis Group, which has helped hospitals prepare. "You wouldn't
think they would be a big deal, but they are."
If Christus Health Shreveport-Bossier hadn't
cleaned up its claim addresses to match its Medicare enrollment addresses, the
Louisiana system likely could have had millions of dollars in claims returned
under the upcoming policy, CEO Isaac Palmer said. That's not counting the
thousands of dollars it could have spent assigning someone to work on getting
those claims paid.
"It's a big deal," he said.
"That's hard for hospitals to keep up with. We spend so much time on operations
and quality and everything else. Keeping up with the intricate rules of CMS is
tough."
If the addresses don't match, hospitals will
receive a return-to-provider notice. They will then have to work with their
Medicare administrative contractor to resubmit the claims. The process could
take some time, which may result in a temporary cash flow problem for some
health systems, attorneys said.
Worst-case scenario: It could prevent hospitals
from filing the claims within one year from the date of service, as is required
for payment under the Affordable Care Act, Hon said.
The change supports the CMS' site-neutral
payment policy, which is designed to pay providers the same regardless of where
they're located. It holds that services provided at non-grandfathered
hospitals' off-campus, outpatient departments are reimbursed the same in
aggregate as physician's office payments and not under the higher hospital
rates. It's being challenged in the form of a bill before the U.S. House of
Representatives and in lawsuits.
Off-campus outpatient departments that hospitals
operated before Nov. 2, 2015, are grandfathered under the new law, meaning they
still receive the higher hospital rates.
Exact match is intended to ensure the CMS is
paying departments at the correct rates. The agency is concerned, for example,
that hospitals might have a grandfathered outpatient location on one floor of
an office building, and then start practicing out of another floor in the same
building, the latter of which would not receive the higher rate, said Timothy
Fry, a healthcare associate with McGuireWoods in Chicago. Under the new rule,
hospital outpatient departments are paid 40% of their grandfathered peers, he
said.
Fry said he doesn't think hospitals with
discrepancies are trying to game the system; it's mostly accidental. The CMS
has put implementation of the new rule on hold until July to ensure hospitals
have had time to make the changes, he said.
"But do I expect that a lot of our
hospitals across the country are behind on this? Absolutely," Fry said.
"And do I think a lot of hospitals will be scrambling in a few weeks if
this rolls out? You bet."
Once hospitals know which addresses need to be
fixed, it takes 30 to 45 days to have Medicare administrative contractors
approve changes to a providers' enrollment information, Hon said. Corrections
are a lot easier and faster to make to a provider's own claims submission
system, Fry said.
The changes will be more difficult for larger
health systems with many hospitals and outpatient locations than it will be for
smaller systems, Hon said.
"I think you're going to see more of these
things falling through the cracks in the larger systems than you would with the
smaller systems that don't have many off-campus locations," she said.
Staff at Christus Health Shreveport-Bossier
began preparing for the change last year, and Palmer said he doesn't foresee
running into problems in July.
"I'm hoping this is going to be like
Y2K," he said.
https://www.modernhealthcare.com/operations/hospitals-have-month-fix-medicare-addresses-or-go-unpaid?utm_source=modern-healthcare-daily-dose-wednesday&utm_medium=email&utm_campaign=20190529&utm_content=article3-readmore
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