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Rural Health Question/Answer Forum

 This forum is dedicated to questions that have been asked regarding rural hospital and rural health clinic billing, coding, grant applications, and policy.  For more information or questions not answered, please contact us at president@mississippirural.org.

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As a Rural Health Clinic, are there regulations against my ability to bill for private or commercial insurance due to our maintaining this status?

No, you are able to bill as normal.  RHC status is essentially an agreement between you and CMS.  It does not affect your relationship with other payers, with the exception of speciality programs like MSCAN.

 

For obstetric care, how do you bill the delivery and post partum visit?  Do you bill the delivery only and then the post partum or do you bill the global delivery and the post partum visit.  Are there rural health guidelines for deliveries and surgeries with follow-up care?

The information below can be found in our Administrative Code Part 222 Chapter 1 Rule 1.5:  Medicaid reimburses delivering physicians for maternity services provided to eligible Medicaid beneficiaries. Providers must utilize evaluation and management procedure codes to bill antepartum visits.  A. Providers must utilize appropriate procedure codes to be reimbursed for deliveries, postpartum care, postpartum hospital visits and office visits. Postpartum care is inclusive of both hospital and office visits following vaginal and cesarean section deliveries.  B. Physicians may bill the appropriate evaluation and management procedure code for reimbursement when the postpartum office visit is the only service provided by the physician.  C. The applicable modifier which identifies “obstetrical treatment/services, prenatal and postpartum” must be reported with each procedure code for antepartum visits and deliveries and postpartum care.   1. Medicaid utilizes this modifier to track data and to bypass the physician visit limitation of twelve (12) visits per fiscal year.  2. Antepartum office visits are not subject to this limitation.

 

Must a Rural Health Clinic employ an RN?

No, RHC regs don't specifically require an RN.   However, you must employ (W-2) a mid level practitioner (NP, PA, Certified Mid-Wife) to be present 50% of the time the clinic is open.  CMS does not direct the type of support staff you use for that provider.  One benefit of using an RN is if you want him/her to order labs based on the history they take from the patient before the provider sees them. 

 

Incorrect Place of Service Codes to Automatically Deny Beginning March 1, 2013

 

The Mississippi Medicaid Provider Billing Handbook states that claims for services provided in an ambulatory clinic setting should be filed with the following place of service codes:

FQHC - 50

RHC - 72

Effective March 1, MississippiCAN and Mississippi CHIP claims submitted by Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) with incorrect place of service codes will automatically deny, but will be considered for payment as soon as a corrected claim is filed. This change will help ensure we post appropriate payments and pay accurate amounts to the FQHC or RHC.

 

Our staff seems to be spending as much time maintaining logs as they do with actual patient care. Is it necessary to have written forms of all of the following log books in rural clinic?  Urine Control for patient/control; Hemoglobin for patient/controlIcon (Pregnancy test) for patient/control; Glucose for control/patient; Pap Smear for patient's results; Temp of Room/Fridge for Lab and Med Room - I know that VFC requires the temp and room log; Blood draw - This is to check off that we did check the patient lab in front of them; Medication Sample Log - What's going in and out with Lot #'s and Exp dates; STD Log- Who has an STD and the treatment received 

Some logs, whether electronic or on paper are necessary for RHC designation.  You must keep a control log on all the machines you use in your lab…just follow the manufacturer’s directions.  Fridge logs and in/out logs for sample medications are required along with your monthly check for all medicines whether stock or samples for outdates is required.  The STD, blood draw and Pap Smear result logs may just be a safety net for your clinic…they are not required by RHC regulations.  I know…it’s a bit of a pain, but in order to stay in compliance you must keep some of these logs.

 

What medications need to be included in a clinic crash cart?

The clinic or center provides medical emergency procedures as a first response to common life-threatening injuries and acute illness and has available the drugs and biologicals commonly used in life saving procedures, such as analgesics, anesthetics, antibiotics, anticonvulsants, antidotes, and emetics, serums, and toxoids.

 

If we are changing medical directors and clinic hours who specifically, and to what address, do we send the notification to?

For any change in the medical director, hours of operation or ownership, you need to notify the Mississippi State Department of Health's Office of Survey and Certification.  In addition, you need to notify in writing the CMS regional office in Atlanta.  The contact information is below:

Centers for Medicare & Medicaid Services (CMS) Region IV Atlanta Federal Center  |  61 Forsyth Street, S.W., Suite 4T20  |  Atlanta, Georgia 30303-8909  |  Phone: (404) 562-7500 

 

What are a list of incentive reimbursements from Magnolia Health Plan?

            Magnolia Incentives.  Supplied on June 7, 2012

 

Our clinics have been considering charging to fill out FMLA forms. Do you do this, and can we charge Medicaid patients?

Filling out FMLA forms does not meet the face-to-face requirements to Medicare and Medicaid patients in the RHC setting.  If you see the patient and fill out the forms, I recommend billing the E&M and 99080 for the FMLA paperwork.  Bundle the cost and submit it to Medicare on one line and collect the 20% from the patient.  For all other carriers, you can simply bill the 99080.

 

Are there special staffing requirements for RHCs?

RHCs must be staffed by at least one nurse practitioner (NP) or physician assistant (PA) or certified nurse midwife (CNM). The NP, PA, or CNM   must be on-site to see patients at least 50% of the time the clinic is open. A physician (MD or DO) must supervise the midlevel practitioner in a manner consistent with state and federal law. There is no specific FTE percentage or employed/contracted agreement for physicians in an RHC, however there is a minimum federal RHC requirement that the medical director be present at least once every two weeks to assure quality of care and see patients, if necessary.from this link:  http://www.raconline.org/topics/clinics/rhcfaq.php#staffing

 

Can anyone tell me where to find more info on the Rural Health Clinic regulations for nurse practitioners, opening a new Rural Health Clinic, what percentage of medicaid/medicare is required, etc? 

Some good information on how to start an RHC...http://www.narhc.org/uploads/pdf/RHCmanual1.pdf.  There are no federal requirements on the % of Medicare/Medicaid patients you treat.

 

Does our sample drug closet need to be locked?  Do we need a log in and out sheet for it?  Do we log in our drugs we give patients? 

Yes. Your sample drug closet needs to be locked…all your medicines need to be locked along with your sharps. You do not have to keep a separate log for stock medications, but you do need to keep a log on all sample medications.  It should have the name of the drug, lot number, name of patient and the quantity you gave them.

 

We are a critical access rural hospital.  Our doctors make rounds in the hospital, acute and swing bed facilities, and nursing homes.  Do we bill these services to Pinnacle? 

Acute visits are billed to Medicare Part B (1500 claim form), by the RHC unless your CAH is option II billing methodology, if that is the case then the hospital business office would bill the professional charges.  The swing beds can be billed as a RHC visit – Please see the attached document.

 

Are the service codes for acute and swing beds the same?  What is the revenue code? 

Nursing Home claims go to Pinnacle on a UB04 form using either revenue code 524 or 535

 

We are a provider-based rural health clinic.  You stated that we can bill services rendered for medicare and medicaid through the hospital.  Is that just for the 6 CLIA waved test or injections or for breathing treatments, mole removal, and other services?  

You should be billing all lab tests (including the 6 required) under the “main hospital” provider number.  These are now cost based and it is a good advantage for your hospital lab.  Mole removal, and various other procedures completed in the RHC should indeed be coded and charged for, but for Medicare patients you’re only going to receive your all inclusive rate and the charges should be bundled into one line item under revenue code 521.  It is important to charge for all services rendered so you can collect your 20% co-pay. 

 

Update for CMS - Centers for Medicare and Medicaid Contracts 

Effective Sunday, January 1, 2012, Diversified Service Options, Inc, a wholly-owned subsidiary of Blue Cross and Blue Shield of Florida Inc, acquired Highmark Medicare Services from its parent company, Highmark Inc. As a result, Highmark Medicare Services changed its name to Novitas Solutions, Inc. www.Novitas-Solutions.com. Novitas Solutions, Inc. will process Medicare fee-for-services claims and other administrative services for hospitals and other institutional providers, physicians, and health care practitioners in these states following the transition.

 

A question on how to bill flu vaccines to the Medicare Advantage Plans.  Are these on the cost report just like the traditional Medicare patients, or on the Plan?

I only include Medicare Part A patients, not Medicare Managed Care Part C, on the cost report. Since the HIC # must be included on the log, those Part C claims could easily be identified and rejected. The plan should be billed, very similar to Medicare Part B physician billing.