CMS rescinds partial hospitalization program modifications

CMS rescinded Transmittal SE1607 August 18, which was related to its enforcement of the 20 hours per week billing requirement for its partial hospitalization program. CMS issued the transmittal March 31, 2016, modifying the PHP to the effect that mandated providers would have to provide at least 20 hours a week of therapeutic services. Starting July 5, 2016, all claims which did not meet the new update would have been denied by CMS.

The modifications came with their own set of problems for providers. “Weekly billing is challenging. While there are fewer volume restrictions on the initial bill at the beginning of treatment, ongoing and final bills require the weekly minimums,” said Stephen Gillis, director of compliance coding, billing, and audit at Partners HealthCare in Boston in a report.

Because partial hospitalization doesn’t have its own billing designation, billing has become a complex matter for PHP services. The solution some facilities have found is using condition code 41 to indicate to Medicare that the services were provided in a PHP. Now, with the recent cancelation of the Medicare billing changes, providers will no longer face the burden of weekly billing requirements.