Update on New Medicare Advantage HIPPS Code Requirement
Tuesday, July 2, 2013
by: VNAA Policy Team

Section: Public Policy and Advocacy

On June 25, VNAA staff spoke with officials at the Centers for Medicare and Medicaid Services (CMS) regarding the new requirement for Medicare Advantage (MA) plans to require Health Insurance Prospective Payment System (HIPPS) codes on all home health claims. CMS officials clarified that while the requirement goes into place on July 1, 2013 CMS will do only “informational edits” for this data until at least September when audits could impact reimbursement.   

During the call with CMS, VNAA raised several concerns:

1) Communication between CMS, MA plans and home health agencies is inadequate, as many providers were not informed of this change. CMS should post guidance provided to MA plans as so that home health agencies will be informed.  

2) A July 1 reporting requirement is unreasonable given the time needed by software vendors to make changes in the software and the late notice to providers. 

3) HIPPS codes are designed for an episode of care while most MA services are provided on a per visit basis. This will make the data transition difficult and could impact access to care.

4) A major hurdle is that software systems must be redesigned to accommodate this change and that will take time. Staff will also need training. 

5) VNAA also raised concerns about the legislative or regulatory authority for this new collection of data.

Additional details are still forthcoming from CMS. CMS states its goal is that HIPPS code should be available on MA claims as they are on fee-for-service Medicare.
Providers should contact health plans to determine what specifically is required related to including the HIPPS code on claims and work with their vendors make sure the appropriate data is submitted. 
VNAA will continue to update members as more information becomes available.
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