Memo from CMS for July 2014

[Cecilianurse]

I got this memo from CMS. See below. Does it mean I have to submit 14D, 30D even if they are HMO? Right now I create one, but do not submit.

CMS MEMO

As noted in the November 4, 2013 HPMS memo, "Encounter Data Submission of HIPPS Codes," the disposition for the HIPPS codes edits will be changed from 'Informational' to 'Reject' effective with July 1, 2014 dates of service (DOS) for any Skilled Nursing Facility (SNF) and Home Health Agency (HHA) encounters submitted without HIPPS codes. The purpose of this memo is to provide additional details about this requirement, and encourage MAOs and other entities to continue to work with SNF and HHA providers to meet this requirement.

I. HIPPS Codes for SNF Encounters Starting with July 1, 2014 Dates of Service

CMS is clarifying that for 2014 DOS beginning on or after July 1st, MAOs must submit a HIPPS code on a SNF encounter that comes from the initial OBRA-required comprehensive assessment (Admission Assessment). Specifically, SNF encounters with "from" dates July 1, 2014 or after that are submitted without a HIPPS code will be rejected. The OBRA-required tracking records and assessments are federally mandated for all residents of Medicare and/or Medicaid certified SNFs and nursing facilities.

For 2014 encounter data submissions, CMS will not require MAOs to submit HIPPS codes from any other OBRA-required comprehensive or non-comprehensive assessments; we also will not require submission of HIPPS codes for any scheduled or unscheduled SNF Prospective Payment System (PPS) assessments. Nevertheless, we do encourage you to submit the HIPPS codes both from other OBRA assessments and from PPS assessments when available from the providers. We especially encourage submission of the HIPPS code based on the Discharge Assessment, which is based on a OBRA-required assessment.

[Talino]

CMS only requires HMO to include the HIPPS code obtained from the Initial Adm MDS. Your contracted HMO may require additional MDS or not so it is best to get in touch with them and find out what each MAO needs.

Also, very important - if your HMO only wants one HIPPS obtained from an admission MDS make sure you ask them "What if there was no admission MDS done because the resident's stay was less than 14 days?

[Cecilianurse]

If they do not complete the 8 days, I always complete a 5 day without submitting to CMS, so billing can use the RUGS. This will satisfy billing, but with regards to requirements will this do?

[Talino]

Good question. There is actually no specific guideline from CMS to the MAOs regarding this situation (DC prior to completion of the Adm MDS). I just want to point out the difference between the HIPPS codes.

• RUX01 - Ultra High Rehab plus Extensive with an ADL Index of 11-16 from a stand-alone OBRA Admission MDS
  
• RUX10 - Ultra High Rehab plus Extensive with an ADL Index of 11-16 from a stand-alone PPS 5-day or Readmission/ return MDS
  
  

According to the memo you posted...

MAOs must submit a HIPPS code on a SNF encounter that comes from the initial OBRA-required comprehensive assessment (Admission Assessment)

On the other hand, it says...

Nevertheless, we do encourage you to submit the HIPPS codes both from other OBRA assessments and from PPS assessments when available from the providers.

I must assume it's ok but it's best to ask the MAO.

CMS must be confused when they said this --

We especially encourage submission of the HIPPS code based on the Discharge Assessment, which is based on an OBRA-required assessment.

There is no HIPPS code generated in a discharge MDS.

[Cecilianurse]

CMS is more confusing that ever. I will continue to complete assessments for billing and see how I can contact the MAO or if I can.

[Cecilianurse]

THANK YOU !!!!