Home Health Agencies across the country are at risk for penalties and recouped claims if the FIPS code is NOT reported on ALL CLAIMS!
CHANGE REQUEST 10782 that was originally released on August 3, 2018 and recommunicated on November 15, 2018 is very clear that the Federal Information Processing Standards (FIPS) State and County Code of the place of residence where the home health services is delivered MUST be present on all claims with a date of service January 1, 2019 and later.
The CURRENT STATE OF EMERGENCY IS TWO-FOLD
1) The Medicare MACs are currently processing and paying claims even if the FIPS code is not present unless the CBSA code identifies a RURAL County. The Medicare MACs state that whether the edit is in place or not THIS IS MANADATORY! One MAC referenced the fact that OASIS was required to be transmitted before you bill final claims since October 1, 2000, yet there was not a billing edit for that until April 2017. The MAC also stated that agencies are at risk for penalties and claim recoupment if the agency is identified as not having reported the FIPS codes on ALL claims!
2) The next issue and the one that has caused agencies to be at risk! Not all software/EMR vendors have gotten this correct. There are EMRs that are not allowing/requiring the FIPS code on the home health RAPs and Finals unless the CBSA code is RURAL and this is NOT correct! Agencies need to contact your EMR IMMEDIATELY AND INSIST THAT THIS BE CORRECTED!
The Medicare MACs are stating that there are no exceptions to this requirement and that ALL claims billed in 2019 without the required FIPS code should be ADJUSTED! When the Medicare MAC was informed that EMRs are not getting this right the MAC responded, as always, that the EMR Vendors do not the contracts with Medicare the home health agency does and the agency WILL BE HELD RESPONSIBLE!
Take immediate action to get all claims adjusted that have already been filed and have immediate conversations with your EMR vendors to get the problem solved ongoing!
HPS is here to assist if there is anything that we can do to help!