With the New Year upon us, HW&Co. would like to wish you a happy, healthy and prosperous New Year. The New Year always brings many changes to the Long-Term Care Industry, even in years that we are not dealing with the challenges of a pandemic. We are pleased to provide you with updates on some of these changes.

In this issue:

  • PRF Reporting Period 2 Now Open
  • 2022 Part B Fee Schedules
  • Therapy Caps Update
  • Part B Services Provided by Therapy Assistants – 15% Payment Cuts Effective January 1, 2022
  • Multiple Procedure Payment Reduction Remains in Effect
  • Medicare Sequestration Delayed Yet Again
  • Make Sure your PS&R System Login is Active!
  • 2021 Medicare Part A Coinsurance & Medicare Part B Deductible
  • January 1, 2021 Ohio SNF Medicaid Rates
  • Medicaid Benchmarking Reports Now Available

PRF Reporting Period 2 Now Open

Reporting Period 2 for Federal Provider Relief Funding is now open.  All providers who received more than $10,000 of Provider Relief Funds (PRF) between July 1, 2020 and December 31, 2020 must report to the Health Resources Services Administration (HRSA) no later than March 31, 2022. This would include any skilled nursing facility that received Infection Control funds, and many providers who received payments under General Distribution Phase II, including many IFC-IID and assisted living providers.

The reporting portal is available on the HRSA website, which also includes information and FAQs on allowable expenses and other reporting matters.  While HRSA gave providers a 60-day grace period for Reporting Period 1, we do not expect a similar grace period for Reporting Period 2.  Therefore, it is important you begin gathering your documentation now to ensure you are able to report successfully by the March 31, 2022 deadline.

The reporting portal can be challenging, and we helped many clients successfully navigate Reporting Period 1.    Please contact us if you need any assistance with your Provider Relief Fund reporting.

Medicare Updates

2022 Part B Fee Schedules

The Medicare Part B Physician Fee Schedule Final rule was released by the Centers for Medicare & Medicaid Services (CMS) on November 2, 2021.  The final rule called for cuts of 3.75% to overall fee schedule payments.

However, on December 10, 2021, President Biden signed the “Protecting Medicare and American Farmers from Sequester Cuts Act” which reduced the cut to approximately .75%.  The final conversion factor, the main underlying component of the fee schedule payment calculation, is $34.61, which is lower than last year’s conversion factor but considerably higher than the 2022 final rule.  As with every year, the payment rates for individual HCPCS codes may vary from the stated percentage change due to changes in the other underlying components of the payment calculation.

The Therapy fee schedules provided below are effective from January 1, 2022 through December 31, 2022.  It is important to forward the fee schedules to your business office personnel to use for January bills. Our Revenue Cycle Consultants are available to assist with any billing questions you may have. In addition, if you use PointClickCare, the Part B fee schedules are automatically updated in your system.

2022 Ohio Therapy Medicare Part B Fee Schedule

Many of the fee schedules change or are updated on a quarterly basis. Please review the appropriate schedule based on the Centers for Medicare & Medicaid Services (CMS) updates. Check the CMS website on a regular basis for updates to these schedules. Please note that these schedules are not all-inclusive. We have attempted to limit this information to the most commonly used Healthcare Common Procedure Coding System (HCPCS) codes for long-term care facilities.

Fee schedules for lab, radiology, PEN, and DMEPOS services are also available.  These fee schedules may be helpful in negotiating contracts with your ancillary service providers.  Please contact your HW Healthcare Advisor if you would like a copy of one of these fee schedules for 2022 services.

Part B Services Provided by Therapy Assistants – 15% Payment Cuts Effective January 1, 2022

As finalized last year in the 2020 Physician Fee Schedule Final Rule, and as required by federal law, CMS requires billing modifiers for services provided by physical and occupational therapy assistants.  Effective January 1, 2020, the CO and CQ modifiers were required to be included when a therapy assistant provides all of the service billed under a given code.  If a therapist is involved throughout the entire service, no modifier is required.  The 2022 Physician Fee Schedule final rule confirmed Part B reimbursement for services provided by therapy assistants, as indicated by the modifiers, will be reduced by 15% effective January 1, 2022.

Therapy Caps Update

The therapy caps for Part B therapy services were eliminated in the Bipartisan Budget Act of 2018.  However, the KX modifier must still be used when services over the limits are provided as a provider attestation of medical necessity.  The limits for 2022 are $2,150 for physical and speech therapy (combined) and occupational therapy.  The 2018 budget act also lowered the threshold for targeted medical reviews of therapy claims from $3,700 to $3,000, which will be in effect through calendar year 2028.

Multiple Procedure Payment Reduction Remains in Effect

The Multiple Procedure Payment Reduction (MPPR) remains in effect for 2022. The MPPR cuts the practice component of the fee schedule payment for certain HCPCS codes by 50% when more than one kind of therapy is provided to a resident in a single day.

For 2022, the MPPR covers therapy services billed under 51 different HCPCS.  The last column of the therapy fee schedules provided above shows the payment that would be made under the MPPR for the affected therapy codes.

Medicare Sequestration Delayed Yet Again

In addition to the fee schedule changes, the “Protecting Medicare and American Farmers from Sequester Cuts Act” included another delay of the imposition of Medicare sequestration on healthcare providers.   Sequestration was removed effective May 1, 2020 when the COVID-19 public health emergency was in its early stages.  Originally scheduled to end December 31, 2020, the re-introduction of sequestration was delayed in late 2020 until December 31, 2021.  However, the bill signed by President Biden in December 2021, delayed sequestration for several months.

Under the bill, sequestration will not be withheld from Medicare payments from January 1, 2022 through March 31, 2022.  Effective April 1, 2022 through June 30, 2022, sequestration of 1% will be withheld, with the full 2% sequestration beginning on July 1, 2022.  In order to pay for the continued delay of sequestration during the public health emergency, Congress included a clause in the bill to increase sequestration during fiscal year 2030.  As a result, sequestration will be withheld at a rate of 2.25% from October 1, 2029 through March 31, 2030 and 3% from April 1, 2030 through September 30, 2030.

Make Sure your PS&R System Login is Active!

Just a quick reminder that passwords for the CMS PS&R system expire every 60 days and must be changed.  In addition, to avoid being locked out, the PS&R system must be accessed at least once every six months.  We recommend you address any password or log-in issues now to avoid delays in accessing your PS&R reports for the Medicare cost reports due in May.

Please contact your HW Healthcare Advisor if you have any questions on accessing the PS&R system.

2022 Medicare Part A Coinsurance & Medicare Part B Deductible

Effective January 1, 2022, the Medicare Part A coinsurance rate for SNFs will increase to $194.50 per day from $185.50 for days 21 through 100. The Part B deductible will be $233.00 for 2022, up $30 from 2021.

Medicaid Updates

January 1, 2022 Ohio SNF Medicaid Rates

The Ohio Department of Medicaid (ODM) has posted updated rate letters to providers’ MITS portals for new rates effective January 1, 2022.  For most providers, the only change was an update to the direct care price for the average of June and September 2021 case mix scores. The rates were recalculated by ODM based upon the average of the 6/30/2021 and 9/30/2021 case mix scores.   The statewide average case mix score decreased (.1136) or 3.8%, resulting in an average rate decrease of ($4.54) or about 2%.    This was not unexpected since the 7/1/2021 rates used the average of the 12/31/2020 and 3/31/2021 case mix scores which had increased substantially due to the COVID-19 outbreaks in the 4th quarter of 2020.

We recommend you review your rate closely to ensure it has been calculated correctly.

Should you believe ODM has made an error, you must file a request for rate reconsideration within 30 days of the date of the rate letter.  Please contact us if you would like an analysis of your rate.

Medicaid Benchmarking Reports Available

The 2020 Medicaid Nursing Facility (NF) Cost Report database from ODM and the ICF-IID cost report database from DODD allow us to analyze annual cost, census, and staffing trends.  We can compare your facility’s expenses, census and staffing against selected competitors, as well as county, peer group and statewide averages.  These reports provide valuable information to assist you in optimizing the operations of your facility.  Please contact us if you are interested in a benchmarking report.

HW Healthcare Advisors

Our team consists not only of CPAs, but also highly trained and experienced billing/revenue cycle consultants, certified medical office managers and LNHAs.  We are dedicated to working with the regulatory, operational and reimbursement challenges that providers face in an ever-changing healthcare environment.

We can assist you in streamlining your processes, optimizing your operations, and identifying potential opportunities and risks.  Please contact any of our HW Healthcare Advisors to discuss how we can help you and your facility stay on the path to success.

Disclaimer:  Information in this article is subject to change and is based upon current information as of the issue date.

Steve Anderson CPA