CMS Issues 4 Home Health Policy Change Requests

The Centers for Medicare & Medicaid Services (CMS) has issued four change requests that provide guidance on home health policy and claims processing issues, seeking to improve compliance and prevent program vulnerability.

The first, Change Request 8699, prevents duplicate payments when overlapping inpatient and home health claims are out of sequence. The request improves safeguards to prevent inappropriate payments on home health claims when a beneficiary is an inpatient of a hospital or skilled nursing facility, CMS says. The change will be effective Jan. 1, 2015, with an implementation date of Jan. 5.

Second, Change Request 8710, also effective Jan. 1 with implementation beginning Jan. 5, seeks to prevent payment on Requests for Anticipated Payment (RAPs) when home health beneficiaries are enrolled in Medicare Advantage (MA) plans. This will modify original Medicare systems to ensure RAPs are not paid when the final claim for a home health episode will not be payable due to an MA enrollment, according to the document. 


Original Medicare claims for home health services are not payable when the home health episode dates fall entirely within an MA enrollment period. RAPs are currently being paid for such episodes, but with the change request, CMS states that these RAPs will be processed but paid at 0%. 

“This will allow the final claim to be received and rejected appropriately, but will prevent any program vulnerability,” CMS writes. 

The third change request, number 8813, adds editing for principal diagnoses that are not appropriate for reporting on the home health claim.


Home health agencies are required to report diagnosis codes on their claims and must adhere to certain coding guidelines. But an analysis of 2011 claims revealed that some agencies weren’t complying with these guidelines, so with this change request, CMS hopes to “ensure greater compliance guidelines for primary diagnosis codes.” 

This change request will be effective Jan. 1, 2015, with an implementation date of Jan. 5.

Finally, Change Request 8818 clarifies the “confined at home” definition, removing vague terms to ensure clear and specific requirements of the definition. It will take effect Sept. 2, 2014, with implementation beginning that day. 

“This will prevent confusion, promote a clearer enforcement of the statute, and provide more definitive guidance to HHAs [home health agencies] in order to foster compliance,” the document states. 

Written by Emily Study

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