Rural Health Clinic (RHC) News
Rural Health Clinics (RHCs)
Effective January 01, 2008 through December 31, 2008 (i.e., CY 2008), the upper Medicare payment limit per visit is:
- $75.63 for RHCs (increased from $74.29)
The Rural Health Clinics (RHCs) upper payment limit per visit is increased from $74.29 to $75.63. The 2008 rate reflects a 1.8 percent increase over the 2007 payment limit in accordance with the rate of increase in the Medicare Economic Index (MEI) as authorized by the Social Security Act (Section 1833(f)).
Medicare Program; Changes in Conditions of Participation Requirements and Payment Provisions for Rural Health Clinics and Federally Qualified Health Centers.
SUMMARY: This proposed rule would establish location requirements including exception criteria for rural health clinics (RHCs). It would also require RHCs to establish a quality assessment and performance improvement (QAPI) program. In addition, it would: clarify our policies on "commingling" of an RHC with another entity; revise the RHC and Federally Qualified Health Centers (FQHC) payment methodology and exceptions to the per-visit payment limit to implement statutory requirements; revise RHC and FQHC payment requirements for services furnished to skilled nursing facility (SNF) patients; allow RHCs to contract with RHC nonphysician providers under certain circumstances; and update the regulations pertaining to waivers to the staffing requirements. This proposed rule would also add requirements for RHCs and FQHCs to maintain and document an infection control process and to post RHC or FQHC hours of clinical services. In addition, this proposed rule would update the requirements under the emergency services standard and patient health records condition for certification (CfC) CMS-1910-P2 2 to reflect advancements in technology and treatment. Finally, this proposed rule solicits comments on payment for high cost drugs and the appropriateness of a mental health specialty clinic as an exception to the location requirements.
Call us at (864) 233-0254 or E-mail us at consultant@thepmgroupsc.com for more details.
November 19, 2007
To: RHC Community and Friends
From: Bill Finerfrock
Re: CMS Announcement
Below is an important announcement from CMS regarding the first step in the creation of an on-line Medicare enrollment/update process.
CMS has been working for the past several years on the development of an on-line Medicare enrollment process. Using this method, providers will be able to enroll in Medicare using a paperless system and all information will be submitted electronically.
Even for providers already enrolled in Medicare, this new system will be helpful as it will allow you to update information through the on-line portal. This should dramatically improve the Medicare enrollment process.
CMS anticipates rolling out this new process in the near future.
As a first step, providers must establish an on-line account with CMS. Equally important, the provider can designate an authorized representative to access the system on their behalf. This will allow physicians and practices to designate an employee of the RHC as the clinic or provider's designated representative. The designated representative will be able to complete the on-line enrollment, as well as update information as necessary.
I want to draw particular attention to when someone should register as an "individual" versus an "organization". An RHC would always register as an organization. But an individual practitioner will also likely want to register as an "organization".
If the practitioner registers as an "individual" ONLY he or she is authorized to enter or change information. If the physician wishes to allow someone else access (an employee, billing company, etc.), then he/she must register as an "organization".
Please note that this registration is for creating an on-line account with CMS and does not affect any other enrollment process. The fact that a practitioner is enrolled in Medicare as an individual, does not preclude the practitioner from registering an on-line account as an organization.
It is also VERY important that you read the MedLearn Matters article cited in the announcement. There is other information included in the announcement that will help avoid problems and confusion as this process moves forward.
Medicare Fee-For-Service Providers: Register Now for the Individuals Authorized Access to CMS Computer Services - Provider Community (IACS-PC)
In the near future, the Centers for Medicare & Medicaid Services (CMS) will be announcing new online enterprise applications that will allow Medicare fee-for-service providers to access, update, and submit information over the Internet. Details of these provider applications will be announced as they become available.
Even though these new internet applications are not yet available, CMS recommends that providers take the time now to set up their online account so they can access these applications as soon as they are available. The first step is for the provider or appropriate staff to register for access through a new CMS security system known as the Individuals Authorized Access to CMS Computer Services - Provider Community (IACS-PC).
A recent MLN Matters article, the first in a new series on IACS-PC, addresses key questions and answers about the registration process and can be found on the CMS website.
http://www.cms.hhs.gov/MLNMattersArticles/downloads/SE0747.pdf
There have been concerns that Medicare Advantage Plans (PFFS) were not paying cost based reimbursement to Rural Health Clinics as required by law. The following release comes from CMS addressing this issue:
CMS RHC clarification PFFS Payments (PDF)
NARHC 2007 Annual Conference in Charleston, S.C.
Handouts from "Effective Front Office Management"
Telephone IQ Test
Inbound Call Tracking Report
Registration Checklist
Checkout Checklist
The following has been published by the Centers for Medicare & Medicaid Services.
Medlearn Matters Articles (PDF)
Medlearn Matters Number: MM4210 Related Change Request (CR) #: 4210
Related CR Release Date: February 1, 2006 Effective Date: July 1, 2006
Related CR Transmittal #: R820CP Implementation Date: July 3, 2006
Sites of Service Revenue Codes for Rural Health Clinics (RHCs) and Federally
Qualified Health Centers (FQHCs) to Use When Billing Medicare
Provider Types Affected
RHCs and FQHCs billing Medicare fiscal intermediaries (FIs) for services.
Provider Action Needed
STOP - Impact to You
Effective for dates of service on or after July 1, 2006, providers of RHC and FQHC services must use the revenue codes listed below on all claims for services previously billed for using revenue codes 0520, 0521, and 0522. Failure to use these codes could impact your reimbursement.
CAUTION - What You Need to Know
Effective July 1, 2006, the Centers for Medicare & Medicaid Services
(CMS) has redefined certain revenue codes for RHC and FQHC
services, and added new ones, in order to provide information needed for the evaluation of any expansion of the RHC/FQHC programs, and also for various reviews to ensure the integrity of the Medicare program.
GO - What You Need to Do
Make sure that your billing staffs are aware of these revenue code
changes, and bill accordingly beginning on July 1, 2006.
Background
FQHCs currently bill all FQHC services (except for those subject to the Medicare outpatient mental health treatment limitation and the Medicare FQHC supplemental payment) under a single revenue code (0520).
Similarly, RHCs bill most RHC services, except for those subject to the Medicare outpatient mental health treatment limitation, under revenue code 0521; and occasionally use revenue code 0522 to bill when RHC services are provided in the beneficiary's home.
Note: The telehealth originating site facility fee is not an RHC/FQHC service and continues to be billed using revenue code 0780.
Therefore, in order to provide CMS with information needed to improve the administration of the RHC and FQHC programs, effective for all claims for dates of service on or after July 1, 2006, CMS has redefined codes 0521 and 0522 to include FQHC services as well as RHC services.
CMS has also added revenue codes 0524, 0525, 0527 and 0528 (displayed in Table 1, below). The codes in this table must be used for claims with line item dates of service on or after July 1, 2006.
These revenue code changes will enable CMS to identify a broader array of claim types to facilitate data analyses necessary to ensure RHC/FQHC program integrity and to evaluate any program expansion.
RHC/FQHC Revenue Codes Effective July 1, 2006
| Revenue Code | Definition |
|---|---|
| 0521 | Clinic visit by member to RHC/FQHC |
| 0522 | Home visit by RHC/FQHC practitioner |
| 0524 | Visit by RHC/FQHC practitioner to a member, in a covered Part A stay at the SNF |
| 0525 | Visit by RHC/FQHC practitioner to a member in an SNF (not in a covered Part A stay) or NF or ICF MR or other residential facility |
| 0527 | RHC/FQHC Visiting Nurse Service(s) to a member's home when in a home health shortage area |
| 0528 | Visit by RHC/FQHC practitioner to other non-RHC/FQHC site (e.g., scene of accident) |
Note: FIs will continue to accept revenue code 0519 from FQHCs when billing for the FQHC supplemental payment, revenue code 0900 from both RHCs and FQHCs when billing for services subject to the Medicare outpatient mental health treatment limitation, and revenue code 0780 when billing for the telehealth originating site facility fee.
Additional Information
You can find more information about RHC/FQHC revenue codes changes by viewing CR 4210 (PDF) on the CMS web site.
You might also want to look at the revised section of the Medicare Claims Processing Manual, Publication 100.04, Chapter Nine (Rural Health Clinics/Federally Qualified Health Centers), Section 100 (General Billing Requirements), which you can find as an attachment to CR4210.
Announcement of Medicare Rural Health Clinics (RHCs) Payment Rate Increases
The Centers for Medicare & Medicaid Services (CMS) must annually update the Rural Health Clinic (RHC) and Federally Qualified Health Center (FQHC) payment limits according to the rate of increase in the Medicare Economic Index (MEI), in accordance with the Social Security Act, Section 1833(f). Based on the rate of increase in the MEI, the 2007 payment rate for RHCs and FQHCs reflects a 2.8
percent increase over their 2006 payment limit.
Changes in RHC and FQHC Payment Rates
Rural Health Clinics (RHCs)
Effective January 01, 2007 through December 31, 2007 (i.e., CY 2007), the upper
Medicare payment limit per visit is:
$74.29 for RHCs (increased from $72.76).
The effective date of January 1, 2007, is necessary in order to update RHC and FQHC payment rates in accordance with the Social Security Act (Section 1833 (f)). To avoid unnecessary administrative burden, your intermediary will not retroactively adjust individual RHC/FQHC bills paid at previous upper payment limits. However, your intermediary retains the discretion to make adjustments to the interim payment rate (or a lump sum adjustment to total payments already made) to take into account any excess or deficiency in payments to date.
RHC/FQHC Visits Within the SNF Setting:
The Balanced Budget Act (BBA) of 1997 (Section 4432) amended the statute to add consolidated billing for SNFs in the SSA (Section 1862 (a) (18)). Similar to the hospital bundling provision in the SSA (Section 1862(a)(14)), this provision bundled all Part B services furnished to SNF patients into the SNF Prospective Payment System, except those services specifically excluded by law.
RHC services were not among the excepted services. Consequently, when a SNF resident received RHC or FQHC services during a covered Part A stay, the services were bundled into the SNF's comprehensive per diem payment for the covered stay itself, and were not separately billable as RHC or FQHC services to the Fiscal Intermediary (FI). This meant that, rather than submitting a separate bill to the FI for these services, the RHC or FQHC looked to the SNF for its payment.
However, the Medicare Prescription Drug Improvement and Modernization Act of 2003 (MMA), Public Law 108-173, (Section 410) amended the BBA (Section 4432) to specify that when an SNF Part A patient receives the services of a physician from an RHC or FQHC, those services are not subject to SNF CB just because the services were furnished under the auspices of the RHC or FQHC. Note that this also applies to services provided by other types of practitioners that the law identifies as being excluded from SNF CB.
In accordance with the MMA (Section 410), services that are included within the scope of RHC and FQHC services and are also described in the SSA (Clause (ii) of Section 1888(e)(2)(A)) are excluded from the SNF CB provision. These services are limited to physician, physician's assistant, and nurse practitioner services. Only this subset of RHC/FQHC services may be covered and paid through the RHC/FQHC benefit when furnished to RHC/FQHC patients in a covered Part A, SNF stay.
The MMA amendment enables such RHC and FQHC services to retain their separate identity as excluded "practitioner" services. As such, these RHC and FQHC services are separately billable to the FI when furnished to an SNF resident during a covered Part A stay, effective with services furnished on or after January 1, 2005.
Implementation
The implementation date for this instruction is January 3, 2005.
Additional Information
For complete details, please see the official instruction issued to your intermediary regarding this change.