Section title: Requests for Interpretation
RFI #
2009
Bundling svcs from > 1 claim
Description

Section 1.10.2.6 "Procedure Code Bundling and Unbundling" describes how lines of a claim are to be reported when bundling occurs. The section restricts itself to a discussion of service lines that are all associated to a single claim. I have discovered that our claims department routinely bundles service lines from several claims into a single bundled line on one claim ("...this is not uncommon with lab."). Since section 1.10.2.6 does not mention bundling that spans claims, is this business practice in compliance with section 1.10.2.6? 

RFI Response

The submitter clarified that their current process reports back multiple claims (as submitted) with one line as primary in one claim and all other lines denied in their respective claims. That process does not report adjudicated procedure codes on the denied lines that are different than the submitted procedure codes. The denied lines also report zero submitted charge.
Additional Information from the submitter (not part of the response)

I did request clarification from the submitter - here is the request and response:

Please provide some clarification related to your question in RFI # 2009.

When you state "our claims department routinely bundles service lines from several claims into a single bundled line on one claim ", do you mean that the payment for all of the services is reported on one of the submitted claims and the service lines from the other submitted claims are reported back as not paid? If so, please provide a general example indicating the CARCs and SVC01/06 coding that you use for the paid and unpaid claims/service lines.

Or, do you mean that all of the service lines from the multiple claims are gathered together into a single new claim and reported as required by section 1.10.2?

Response -

“Yes” in answer to the question in the first paragraph, and “No” in answer to the question in the second paragraph.

The example I provide below from production shows that we are not reporting bundled lines correctly.

SVC*HC:84443*0*0~ <- first bundled line

DTM*472*20140827~

REF*6R*6587798~

LQ*HE*M15~

SVC*HC:80053*0*0~ <- second bundled line

DTM*472*20140827~

REF*6R*6587793~

LQ*HE*M15~

SVC*HC:85025*0*0~ <- third bundled line

DTM*472*20140827~

REF*6R*6587792~

LQ*HE*M15~

SVC*HC:80050*172*50.86~ <- final line containing sum of charges of bundled lines and adjudication

DTM*472*20140827~

CAS*OA*A1*121.14~

AMT*B6*50.86~

LQ*HE*N22~

LQ*HE*N663~

LQ*HE*N381~

I have initiated system changes to bring us into compliance with 1.10.2.6, so that the above will be reported as follows:

SVC*HC:80050*84*50.86***HC:84443~

DTM*472*20140827~

CAS*CO*45*121.14~

CAS*OA*94*-88~

REF*6R*6587798~

AMT*B6*-37.14~

LQ*HE*N22~

LQ*HE*M15~

SVC*HC:80050*53*0**0*HC:80053*1~

DTM*472*20140827~

CAS*CO*97*53~

REF*6R*6587793~

LQ*HE*M15~

SVC*HC:80050*35*0**0*HC:85025*1~

DTM*472*20140827~

CAS*CO*97*35~

REF*6R*6587792~

LQ*HE*M15~

And as I read 1.10.2.6, I see no mention of bundling across claims. But our Manager of the Claims department has shown me examples where they are bundling lines from one claim and reporting the adjudication in another claim (for the same provider and date of service). No new claims are created in order to report bundled lines. This appears to be at variance with your 2nd question and that causes me additional concern. Where in 1.10.2 does a single new claim need to be used to report service lines from multiple claims? I can’t find that.

Here is our current 835 reporting for lines bundled across two claims:

CLP*898989898*1*331.55*72.94**HM*232323232*81*1~

NM1*QC*1*Taylor*Donald****MI*666666666~

REF*1L*C12127~

REF*EA*111111111~

REF*CE*XX~

DTM*050*20140925~

SVC*HC:86592*0*0~ <- bundled line

DTM*472*20140922~

REF*6R*2569694701~

LQ*HE*M15~

CLP*343434343*1*59.85*59.85**HM*454545454*81*1~ <- other claim containing charge & adjudication of bundled line

NM1*QC*1*Taylor*Donald****MI*666666666~

REF*1L*C12127~

REF*EA*999999999~

REF*CE*XX~

DTM*050*20140926~

SVC*HC:86762*0*0~ <- bundled line

DTM*472*20140922~

REF*6R*2571736971~

LQ*HE*M15~

SVC*HC:80055*59.85*59.85~ <- adjudicated line containing the two bundled lines

DTM*472*20140922~

AMT*B6*59.85~

LQ*HE*N22~

LQ*HE*N663~

LQ*HE*N381~

Obviously the form of reporting is not consistent with 1.10.2.6, but I question whether this practice of bundling across claims is HIPAA-compliant at all.

While section 1.10.2.6 describes bundling within a single claim and there is no explicit section describing bundling of services from different claims, there is nothing prohibiting that practice. Section 1.10.2.14 does identify the principles necessary for this process. In summary, similar reporting as in bundling would be used on each of the claims involved:

- All related service lines would indicate the adjudicated and submitted procedure codes using SVC01 and SVC06

- Unpaid procedures would use Claim Adjustment Reason Code 97 (which currently reads "The benefit for this service is included in the payment/allowance for another service/procedure that has already been adjudicated. Note: Refer to the 835 Healthcare Policy Identification Segment (loop 2110 Service Payment Information REF), if present.") to adjust those service lines to a $0 payment

When determining other specifics for reporting, implement the message from section 1.10.2.14 - to "...give the provider a message that will not result in calls to customer service." While unspoken in section 1.10.2.14, identification of any remaining patient responsibility would be critical to avoiding calls.

Reporting the denied lines that were bundled across claims without identifying the adjudicated procedure as the paying procedure in SVC01 and the submitted procedure in SVC06 is not consistent with the guide instructions. The denied service lines need to report the submitted charge from the claim and use CARC 97 to adjust the payment to zero in order to be consistent with the guide.

DOCUMENT ID
005010X221