CCC Updates: Uniformity for Claims and DMAS Signals Intent to Extend the CCC

MMPs Will Be Applying More Uniformity to CCC Claims:  The three Medicare/Medicaid Plans (MMPs) are collectively working on guidance to nursing facility providers to achieve more uniformity and clarity on billing under the CCC program.  There have been several billing issues primarily since the switch to RUGs-based billing back in November.  VHCA has been working with the Department of Medical Assistance Services (DMAS) and the MMPs for the past several months on various claims processing concerns, most recently through the formation of a claims processing workgroup involving VHCA members.

One specific issue that has been identified is the difficulty the three MMPs have in identifying Medicare versus Medicaid claims since the transition to Medicare-like RUGs-based billing in Medicaid.  Originally, the parties had all agreed to utilize certain revenue codes on claims to distinguish between the two programs.  Specifically, skilled nursing facility (Medicare) claims should be billed using Revenue Code 120 for Room and Board services; custodial claims (Medicaid) should be billed using Revenue Code 190 for Room and Board services.  There has been some confusion around the use of revenue codes and some providers have not adopted their use to distinguish these claims.  

Further, DMAS guidance provided for RUGs-based billing post November 1 dates of service indicated that Occurrence Code 50 is required on custodial Medicaid nursing facility claims.  Specifically, DMAS instructed, “The nursing facility should report the assessment reference date with the Occurrence Code 50 for each Health Insurance Prospective Payment System Code (HIPPS) reported on the claim.”  DMAS has not yet modified its claims processing system to enforce this requirement, which has led to some facilities not adhering to the guidance.  At least one MMP did initially enforce this requirement through its claims edit array.  Given the issues that ensued, the MMP subsequently turned off the edit.  However, DMAS will eventually enforce this requirement on fee for service; VHCA maintains that it needs to also be enforced consistently across the three MMPs for CCC.

To that end, the three MMPs will begin requiring the proper revenue codes and Occurrence Code 50 on facility claims beginning October 1.  We are working with the three MMPs to encourage a transition period (i.e., working with providers who are not adhering to these requirements before going completely mandatory).  It appears Anthem has already agreed to allow a 90-day grace period for providers to make whatever system or practice modifications are necessary.  We will update the membership as we learn more about what the other plans intend to do.

DMAS Files Letter of Intent to Extend the CCC Demonstration:  As reported in the July 24 CareConnection, CMS announced an opportunity for states involved with a dual demonstration program to extend the program for an additional two years beyond the initial demonstration end-date.  Under the original demonstration timeline, the demonstration was scheduled to end on December 31, 2017.  Based on the new CMS option, it appears Virginia could opt to extend the CCC program through December 2019, simply through modification to the existing Medicare/Medicaid Plan (MMP) contracts.

At the time of the previous article, DMAS had not yet announced its intentions.  However, we have been informed that DMAS submitted the required letter of intent by the September 1 deadline.  DMAS did reiterate to VHCA that the letter was non-binding, meaning DMAS has kept open the opportunity to extend the CCC program, but the letter of intent does not guarantee that the program will be extended beyond the current December 31, 2017 end-date.  This decision will be made at some point in the future, and we will keep you updated as the discussion unfolds.