By: Susan Sumrell

January 1, 2011 brings the implementation of many important provisions from the Affordable Care Act, as was noted in an earlier NACHC blog, The New Year Introduces New Health Care Provisions. Among these important provisions are two concerning health centers and their Medicare patients.

Section 10501 of the Affordable Care Act adds several new preventive services to the list of Medicare-covered FQHC services. Additionally, the new law calls for the creation of a new Medicare reimbursement structure for health centers beginning in 2014. In order to create this system, the law requires health centers to begin reporting Healthcare Common Procedure Coding System (HCPCS) codes beginning January 1, 2011. These codes are used to indicate the types of services being provided at each visit. CMS has updated their Claims Processing Manual for FQHCs with the following information:

FQHC Affordable Care Act (ACA) Requirements
(Rev2034, Issued: 08-24-10, Effective: 01-01-11, Implementation: 01-03-11.)

Section 1834 (o)(1)(B) of the Affordable Care Act (ACA) requires the collection of data necessary to develop and implement the Medicare FQHC prospective payment system which is scheduled to be implemented in 2014. Beginning with dates of service on or after January 1, 2011, when billing services on a 77X type of bill, all services provided should be listed with the appropriate revenue code and HCPCS code for each line.

This data reporting will be as follows:

For each billable visit, FQHCs must submit the appropriate revenue code as explained in section 100, and a valid HCPCS code for all claims with DOS on or after January 1, 2011.

In addition, FQHCs must submit separate service lines with revenue codes and HCPCS codes to reflect any cost associated with all FQHC covered services provided by the FQHC but not reflected on the service line submitted for the billable visit. For example, for Part B covered injectable drugs administered in an FQHC during a billable visit, the FQHC should report a separate line item with the appropriate revenue code and HCPCS codes to reflect the charge for the drug and its administration which is covered as an incident to service.

Pneumococcal, influenza and hepatitis B vaccine and their administration should be reported separately with the appropriate HCPCS code and revenue codes.

It is imperative that health centers review these new requirements and code their services correctly, because under the current law these codes will be used in the upcoming years to develop the new Medicare reimbursement structure for FQHCs. Look for more information to come from NACHC on these new requirements.