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Pete Harmon's HFS Blog

Health Financial Systems – Director, Government Relations

On July 8, 2010, CMS rescinded the J-15 (Ohio and KY) award to Highmark, and awarded it to CIGNA, due to a protest.  We now hear this has been protested by Highmark and Cahaba.  When the “dust settles”, I’ll let you know!

CMS is changing the MAC bidding/award process to compress the original 15 MACs down to 10.  The current Jurisdictions 1, 9, 10, 11, and 12, will remain as is.  Jurisdictions 2 and 3; 4 and 7; 5 and 6; 8 and 15; 13 and 14; will be combined into 5 bids/awards.  For the details on this change, see the link below, or go to www.hfssoft.com, and click on the News Tab.

http://www.hfssoft.com/pdfs/MAC-Round2-Special-Notice.pdf

CMS has indicated the new 2540-10 for SNFs, will be effective for FY Begin 12/1/2010 and after.  We have not seen the “Final” forms yet, so when we do, I will update this post.  We know the “final” we have seen to date, must change for the addition of 22 new RUGs, effective for Services on or after 10/1/2010.

CMS must issue Transmittal 22 for the 2552-96, to incorporate changes required by the Patient Protection and Affordable Care Act (ACA).  The TOPS extension for small rural hospitals, and Sole Community hospitals, through 12/31/2010 is the most significant change.  CMS is also changing the “effective date” for the use of line 29, on S-3 part I, for the Labor/Delivery Days, which need to be included in the DSH calculation, per the CMS 1498R Ruling.  FI/MAC will be able to use line 29 for FY prior to 10/1/2009 (currently line 29 can only be used for FY Begin 10/1/2009 and after).  There are also 22 new RUGs for hospital based SNFs.  These are effective for Services on or after 10/1/2010.  When we receive T.22, I will post the details.

West Coast Providers (CA, HI, NV) formerly serviced by Mutual of Omaha.

Mutual of Omaha served the Medicare program as a fiscal intermediary for several decades.  The Mutual of Omaha fiscal intermediary workload was, and still is, identified in Medicare data systems as “workload number 52280.”  Wisconsin Physician Services (WPS) took over the legacy Mutual workload in 2006.  Providers serviced by WPS under that fiscal intermediary contract have remained in that workload pursuant to 42 CFR 421.104.  We refer to that body of providers as “the legacy WPS workload.”  This set of providers has been serviced under a distinct contract and maintained in a WPS workload separate from the Jurisdiction 5 A/B MAC workload.  CMS is currently planning to move a limited set of the providers in the 52280 legacy WPS workload to their destination assignments. 

The first set to move will be those providers destined to be assigned to the Jurisdiction 1 MAC pursuant to the geographic assignment rule and its exceptions.  A broad discussion of geographic assignment rule and its exceptions can be found in Medicare Learning Matters article number “MM5979.” 

The CMS is currently transitioning the Jurisdiction 1 providers out of the legacy WPS workload and expects to complete the transition no later than April 2010.  The balance of legacy Mutual of Omaha providers will remain in workload number 52280 until further notice.

The table below gives the current status of all MAC jurisdictions.

Jurisdiction Contractor Status
A National Heritage Insurance Corp.                             Fully Implememted Fully Implemented
B National Government Services                                     Fully Implememted Fully Implemented
C CIGNA Government Services                                        Fully Implememted Fully Implemented
D Noridian Administrative Services                               Fully Implememted Fully Implemented
1 Palmetto Government Benefits Administrators     Fully Implememted Fully Implemented
2 PROTEST OF CONTRACT AWARD                                Bid Corrective Action Bid Corrective Action
3 Noridian Administrative Services                               Fully Implememted Fully Implemented
4 TrailBlazer Health Enterprises                                      Fully Implememted Fully Implemented
5 Wisconsin Physicians Services                                      Fully Implememted Fully Implemented
6 PROTEST OF CONTRACT AWARD                                Bid Corrective Action Bid Corrective Action
7 PROTEST OF CONTRACT AWARD                                Bid Corrective Action Bid Corrective Action
8 PROTEST OF CONTRACT AWARD                                Bid Corrective Action Bid Corrective Action
9 First Coast Service Options, Inc                                   Fully Implememted Fully Implemented
10 Cahaba Government Benefit Administrators          Fully Implememted Fully Implemented
11 PROTEST OF CONTRACT AWARD                                Bid Corrective Action Bid Corrective Action
12 Highmark Medicare Services                                         Fully Implememted Fully Implemented
13 National Government Services                                     Fully Implememted Fully Implemented
14 National Heritage Insurance Corp.                              Fully Implememted Fully Implemented
15 PROTEST OF CONTRACT AWARD                                 Bid Corrective Action Bid Corrective Action

CMS will not transition providers from legacy fiscal intermediaries and carriers to the following MACs until procurement corrective action on the respective contract awards has concluded.

  • A/B MAC Jurisdiction 2
  • A/B MAC Jurisdiction 6
  • A/B MAC Jurisdiction 7
  • A/B MAC Jurisdiction 8
  • A/B MAC Jurisdiction 11
  • A/B MAC Jurisdiction 15

The legacy fiscal intermediaries and carriers will continue to service the providers in those workloads until further notice. 

DME Re-compete:

In 2006, the Centers for Medicare and Medicaid Services (CMS) awarded the first MAC contracts to administer Medicare claims for DME benefits in jurisdictions A and B.  Under the Medicare Prescription Drug, Improvement and Modernization Act of 2003 (MMA) the Secretary of Health and Human Services must re-compete its Medicare Administrative Contractors contracts every five (5) years.  Therefore, on Thursday, December 30, 2009, CMS issued a solicitation for the first “second generation” MAC contractors for DME Jurisdictions A and B.  Currently, National Heritage Insurance Company (NHIC) is serving as the DME MAC in Jurisdiction A, and National Government Services (formerly doing business as AdminaStar Federal Inc.) is serving as the DME MAC in Jurisdiction B.  CMS anticipates awarding these contracts and fully transitioning the workloads to new MAC contracts by no later than December 2010.

In my earlier Posts (and our web site, www.hfssoft.com), I had FY Begin and FYE 10/1/2009, for the effective date of T.17.  This is to clarify that the SNF T.17 is effective for FY END 10/1/2009 and after (i.e. MUST be used for this FYE).  Also, CMS rescinded the change to S-2 line 20, to require an answer of F/L/N for a Full, Low, or No Medicare Utilization report.  S-2 line 20 reverts back to T.16, where you ONLY complete it with an L or N, for Low/No utilization.  If it is a Full report, line 20 is left Blank.

HFS recently received approvals for the Hospital 2552-96, Transmittal 21 (our version 21.0.119.0), which we posted 3/12/2010; SNF 2540-96, Transmittal 17 (our version 17.0.119.0); HHA 1728-94, Transmittal 14/15 (our version 15.0.119.0); and RHC/FQHC 222-92, Transmittal 8/9 (our version 9.0.119.0).  All of these MUST be used for cost reports with FYE on or after 10/1/2009.  We expect to post the SNF, HHA, and RHC/FQHC updates this week (week of 3/15/2010).  CMS was late with these approvals, so if you have begun your report on an older version, you simply need to do a Check for Updates (under Help in our software), and get the new version(s).  You must use these new version to file reports with FYE of 10/1/2009 and after.  See my earlier posts for the detailed changes in these Transmittals.

CMS recently pulished updated info about MAC Jurisdiction J-7 (AR, LA, MS).  CMS said “In taking corrective action CMS plans to issue a new solicitation to procure the A/B Medicare Administrative Contractor Jurisdiction 7 workload previously solicited under RFP-CMS-2007-0002.  CMS anticipates initiating the new procurement action in calendar year 2010.”  In essence, CMS is re-bidding J-7, so who knows when we will see a final award!