Ask the payment expert ... about the observation stay loophole

What significant changes in Medicare occurred for us in 2014?

There haven’t been a lot of changes this year, but providers are still getting used to last year’s changes — and getting ready for some new clarifications coming in October.

The biggest moves last October were the addition of two areas to the therapy area of Section O.  Section O0400A3a, B3a, and C3a all include the co-treatment minutes. 

Although the Centers for Medicare & Medicaid Services staff members state this does not affect payment, they are tracking the information. 

Section O0420 tracks distinct calendar days of therapy. This section does affect payment and added the requirements that RM (Rehab Medium) has five distinct calendar days of treatment and RL (Rehab Low) has three distinct calendar days of treatment, along with the required six out of seven days of restorative care.

The biggest change that providers were not aware of last October was the changes to Section K0710. In order to receive reimbursement for feeding tube residents, you must meet the requirements of calories and/or fluids during the entire seven-day “look-back” period in K07103. Make sure your staff is aware of that for Medicare and RUGs IV Medicaid.

In October 2014, we expect only some changes to Section A dates and definitions. Other changes that have recently been put on hold include the implementation of ICD-10, which is being delayed until Oct. 1, 2015. 

You will also see implementation of HETS (HIPAA Eligibility Transaction System), a HIPAA compliant program that will replace the CWF (Common Working File). It presently has been delayed but CMS states it will give us a 90-day notice of implementation.