On March 13, 2003, the Centers for Medicare & Medicaid Services ("CMS") issued Program Memorandum Transmittal No. B-03-021 to Carriers instructing them to publish a provider education article regarding home health consolidated billing ("HH CB") and provider liability. The provider education piece is designed to remind independent therapists and DME suppliers of their responsibility to determine whether a beneficiary is in a home health episode of care, which requires Medicare payments for such services to be made to the home health agency as part of HH CB and not to the therapist or supplier. HH CB has been in effect since October 1, 2000, and therapy and supply claims subject to HH CB that were received after a home health agency claim had been paid have been denied by Medicare since that time. CMS has now developed a process to enforce HH CB (i.e., identify and recover payments) in cases where a "consolidated" therapy or supply claim was received and paid prior to the payment of the home health agency claim. CMS is developing an information system to assist independent therapists and suppliers in identifying beneficiaries who are in a home health episode of care, but until that time providers will have to obtain such information by contacting their carriers or by directly asking the beneficiary.

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