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Patient transfers from one home health agency to another can be tricky, and now transfers might get even more complicated with a new billing requirement.

Come July, the Centers for Medicare & Medicaid Services is eliminating source of admission codes "B" and "C," CMS says in Feb. 5 Transmittal No. 1904 (CR 6757). That's because the National Uniform Billing Committee has changed the former source of admission codes to "point of origin" codes that must specify a place rather than a referral source, CMS explains.

Old way: Code "B" currently represents "transfer from another home health agency" and code "C" indicates "readmission to the same home health agency." Both codes trigger a partial episode payment adjustment (PEP).

New way: For dates of service July 1 or later, HHAs will use new condition code "47" instead of code "B." Code "47" will indicate "the patient was admitted to this home health agency as a transfer from another home health agency," according to CMS Transmittal No. 1917 (CR 6801).

HHAs won't use any special coding for situations where they currently use code "C," CMS instructs in the transmittals.

Although the change is fairly straightforward, it could still cause problems for HHAs and CMS, predicts billing expert M. Aaron Little with BKD in Springfield, Mo. "Any kind of a billing/coding change after 10 years can be a little tricky," Little cautions.

Unexpected: It's a bit surprising that CMS doesn't have any code to use when agencies PEP themselves by readmitting a patient, Little says.

"According to the new transmittals, the Medicare claims processing edits will recognize that it was the same provider that initiated the previous episode and will automatically know to allow the new episode to overlap the previous episode," he notes. That will result in a PEP adjustment to the previous episode.

Right now, Medicare has "a rather clear instruction that in any overlapping episode situation, the only change to claim coding is to select the most appropriate SOA code of B or C," Little observes.

But the new process will require a new condition code in one situation and no special claim coding in the other situation.

"This could very likely result in some confusion by billing personnel," Little predicts. They might ask, "When do I use the condition code 47 vs. when do I have to do nothing special to the claim for it to process?" That, in turn, could result in claims being returned with errors.

HHAs will also have to go through the hassle of training billing staff and making sure their software accommodates the change, Little adds. And agencies should monitor Medicare payments to make sure the change didn't cause errors in the claims system.