We are preparing for Home Health Electronic Visit Verification (EVV) implementation and are concerned about requirements published by State Health Care Authority (HCA) for implementation of EVV. We would appreciate your help or guidance on the matter.
The concern is that HCA outlined a potentially non-compliant requirement in their EVV plan. Specifically, they are requiring agencies, which are operating and billing under a group NPI, to add individual NPI numbers for staff who performed the visit to the rendering provider loop on the 837i claim. See the message below from HCA referencing 837 Technical Report for Type 3 Professional Health Care Claims.
Messaging received from the HCA:
“HCA’s approach to collect the “Individual Who Provided the Service” is for the home health agencies to submit the information via the claim record (837I or DDE) in the “Rendering Provider” loop. HIPAA requires provider NPI’s in the claim submission for individuals who are eligible to obtain an NPI. (See page 264 of the following publication: 005010X222 • 837 TECHNICAL REPORT • TYPE 3 HEALTH CARE CLAIM: PROFESSIONAL; the link to purchase the guide is: Products | X12)”
Clarification needed:
Based on published X12 standards for 837i claims used by Home Health Agencies (HHA) to bill Medicare, HHA would expect CMS/MAC to deny claims if in compliance with the HCA EVV plan outlined above since this plan does not seem to conform to SSA 1903 (l)(2). We are seeking clarification from CMS regarding claims compliance in conjunction with the State HCA EVV plan.
Is it allowed for a Medicare home health claim, in L2420C, to have a NPI of an individual home health direct care worker? Is it allowed for a Medicare home health claim, in L2310E, to have the clients service location? Formatted NM1*77*2*Clients Location (Home or otherwise). Is it allowed for a Medicare home health claim, in L2400 SV202-7, to have visit time information? This field is intended to further describe the procedure on the service line, so it is questionable whether this is an appropriate location for timing information.
If this business situation meets the situational criteria of the 005010 837I Rendering Provider Segment (2420C), then that provider’s NPI is allowed to be sent.
Similarly, if the business situation meets the situational criteria of the 005010 837I Service Facility Location Name (2310E), then that loop can be used to report the location of the service.
2400 SV202-07 says “Required when, in the judgment of the submitter, the Procedure Code does not definitively describe the service/product/supply and Loop ID-2410 is not used.”
So it is up to the submitter, if the time is necessary to be sent in SV202-07
If the Situational rules for Rendering Provider and Service Location are not able to be met and there are State or Federal regulations requiring so, then the K3 segment process can be followed (See 005010 837I K3 Situational rule).