Home Health Agencies Can Now Bill Medicare Separately for Furnishing New Disposable Negative-Pressure Wound Therapy Devices

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January 1, 2017, was a historic day for patients who receive home health services under the Medicare home health benefit. The 2017 Home Health Prospective Payment System Final Rule (www.gpo.gov/fdsys/pkg/FR-2016-11-03/pdf/2016-26290.pdf) was implemented to comply with Section 504 of the Consolidated Appropriations Act of 2016 (www.congress.gov/114/plaws/publ113/PLAW-114publ113.pdf).
This Act requires Medicare to separately pay home health agencies (HHA) when they furnish new disposable negative-pressure wound therapy (NPWT) devices to Medicare beneficiaries. The following link connects to the Centers for Medicare & Medicaid Services transmittal that updated the Medicare Claims Processing Manual with this new separate payment instruction: www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/Downloads/R3655CP.pdf. This new separate HHA payment is historic because it required an act of Congress, and is a win-win situation for both patients and HHAs.
Like all other HHA services, the patient must receive the new disposable NPWT devices under a HHA plan of care that is developed in consultation with the agency staff and periodically reviewed by the patient’s physician. The HHA plan of care should cover all pertinent diagnoses, including the types of services and equipment required for the treatment of those diagnoses, as well as any other appropriate items, including the new disposable NPWT devices.
As with any new payment system, the HHA will need to make a few operational changes to begin furnishing new disposable NPWT devices and to begin separately billing Medicare and other payers. Making these operational changes is relatively simple, but should be done at the onset of providing this service. See the Table for a checklist of the operational changes that each HHA should implement to take advantage of the opportunity to furnish new disposable NPWT devices to its patients and to bill separately for 97607/97608.
Although these operational changes are relatively simple, and the 2017 Home Health Prospective Payment System Final Rule, which was published on November 3, 2016, clearly describes how to appropriately document and submit separate claims when the HHA furnishes a new disposable NPWT device, this separate HHA payment opportunity has generated many questions from HHAs. Following are some of the most frequently asked questions this author has received since the new payment system was implemented on January 1, 2017.
Q: What documentation is required when a HHA furnishes a new disposable NPWT device?
A: As always, the HHA’s documentation should “paint the picture” why the patient needs disposable NPWT and what work the licensed nurse or therapist performed. This documentation should minimally include the following:
Q: What are the codes that HHAs should use to separately bill for a new disposable NPWT device?
A: The American Medical Association established 2 CPT®* codes for NPWT using disposable medical equipment:
97607—Negative-pressure wound therapy (eg, vacuum-assisted drainage collection), utilizing disposable, nondurable medical equipment including provision of exudate management collection system, topical application(s), wound assessment, and instructions for ongoing care, per session; total wound(s) surface area less than or equal to 50 square centimeters.
97608—Negative-pressure wound therapy (eg, total wound(s) surface area greater than 50 square centimeters
Q: Is the separate Medicare payment for a new disposable NPWT device (97607/97608) paid out of the patient’s Part A or Part B Medicare benefit?
A: Medicare pays for 97607/97608 out of the patient’s Medicare Part B benefit.
Q: Because Medicare pays for a new disposable NPWT device out of the Part B benefit, does the HHA have to acquire a durable medical equipment (DME) supplier license to bill Medicare Part B?
A: No, disposable NPWT devices are not DME. The HHA simply submits a separate claim, identified as Type of Bill 34x, and Medicare will automatically pay for it out of the patient’s Medicare Part B benefit.
Q: Most of our patients have multiple comorbidities.
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