Current Difficulties with Rural Health Clinic Claims Processing
by Debbie Mackaman, RHIA, CPCO, CCDS
Earlier this year, I wrote several articles about changes to the Medicare Benefit Policy and Claims Processing Manuals that would directly impact RHCs. Effective April 1, date of service, revenue codes, HCPCS codes, and charges are required on separate lines for each service provided. This requirement was a major change for RHCs and the anticipated problems with claims processing appear to be worse than originally predicted.
Around April 12, CMS requested that all MACs hold RHC claims with dates of service on or after the April 1 implementation date. Unfortunately, CMS is experiencing claims processing difficulties and does not anticipate a technical solution until April 25. Considering that Medicare already holds all claims for 14 days from the submission date prior to processing, it is anticipated that this snag will have little impact on the financial picture for RHCs; however, I am certain that RHCs will not agree with that projection.
CMS representatives on the Rural Health Open Door Forum Call held on April 14 spent little time addressing the issue. However, other sources state that CMS is well aware of the significant financial problems that extended delays in payments will cause RHCs and they are exploring all options to minimize the impact.
How well an RHC copes with the changes may have to do with whether they are provider-based or independent. I was out teaching the Rural Health Clinic Boot Camp® about a week after the implementation of the required reporting change and it appeared that provider-based RHCs associated with hospitals were having an easier time with the transition since they were familiar with and most likely had access to a current list of revenue codes. Independent RHCs were less likely to be familiar with revenue codes outside of their usual 052X, 0900, and 0780 choices. Unfortunately, CMS no longer provides detailed UB-04 field information in Chapter 25 of the Medicare Claims Processing Manual. However, the various codes reported on the claim are supposed to be available from MACs and can also can be purchased from the National Uniform Billing Committee.
Just days before the April 1 effective date, CMS broadcast a Technical Assistance Call and did clarify that the charges for the additional lines on the claim did not have to be the actual charge that would already be included in the qualifying visit line and could instead be listed as $0.01. This clarification was welcome guidance for RHCs who had been concerned about the appearance of double billing to the patient, not to mention the accounting nightmare that would be created by billing the full charge twice. Those slides can be found on the CMS Rural Health Center website.
To view the complete article that appeared on Medicare Compliance Watch, click here.