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Consolidated billing exception in the works.

A rare carve-out for non-routine medical supplies could put more cash in agencies’ hands —but it will come with some billing hassles.

Old way: Currently, the Centers for Medicare & Medicaid Services pays separately for nondisposable negative pressure wound therapy (NPWT) devices as durable medical equipment. But if the NPWT device is disposable, home health agencies must cover it under their NRS payment rates (see chart, p. 195).

New way: In its Home Health Prospective Payment System proposed rule for 2017, CMS notes that a law passed earlier this year requires the agency to pay separately for disposable NPWT devices. HHAs can bill Medicare Part B for certain NPWT codes (CPT codes 97607 and 97608 [APC 5052 — Level 2 Skin Procedures]). Medicare will pay for it under the Hospital Outpatient Prospective Payment System.

However: “These services/equipment are subject to a 20 percent coinsurance” for the patient, the National Association for Home Care & Hospice points out in its member newsletter.

Complication: Also, “for instances where the sole purpose for an HHA visit is to furnish NPWT using a disposable device, Medicare will not pay for the visit under the HH PPS,” CMS says.

“Instead, we propose that since furnishing NPWT using a disposable device for a patient under a home health plan of care is to be paid separately … which includes payment for both the device and furnishing the service, the HHA must bill these visits separately under type of bill 34x (used for patients not under a HH plan of care, Part B medical and other health services, and osteoporosis injections) along with the appropriate HCPCS code (97607 or 97608). Visits performed solely for the purposes of furnishing NPWT using a disposable device are not to be reported on the HH PPS claim (type of bill 32x),” CMS instructs.

Other billing instructions include:

• When an agency furnishes both NPWT and a home health-covered service on the same visit, “the HHA must not include the time spent furnishing NPWT in their visit charge or in the length of time reported for the visit on the HH PPS claim (type of bill 32x),” CMS proposes.
• For patients under a home health plan of care, only registered nurses, physical therapists, or occupational therapists can perform NPWT using a disposable device, CMS says.
• NPWT visits “would be reported on the type of bill 34x using revenue codes 0559, 042X, 043X,” the agency instructs.

Since the item/service no longer will be subject to consolidated billing under HH PPS, other practitioners furnishing it won’t have their claims denied and won’t have to demand payment from HHAs, observers note.