National Government Services, Inc. Medicare Monthly Review Part A and B
A Combined Part A and Part B Newsletter

MMR-2008- 03A, March 2008

Healthcare Integrated General Ledger Accounting System (HIGLAS)
Article Summary:
Effective March 5, 2008, National Government Services, Inc. will be transitioning our Part A financial accounting system from the Fiscal Intermediary Standard System (FISS) to the Healthcare Integrated General Ledger Accounting System (HIGLAS). This transition involves only our financial accounting system. We will continue to use FISS for all claims processing activity.

Implementation of HIGLAS will enable the Centers for Medicare & Medicaid Services (CMS) to track Medicare payments and to accurately pay claims for over 40 million Medicare beneficiaries. The transition will also provide CMS with enhanced oversight of contractors’ accounting systems, as well as access to more accurate, timely, and consistent data for decision-making and for performance evaluations.

National Government Services HIGLAS Transition
The purpose of this article is to explain the impact that the National Government Services’ HIGLAS transition will have on your organization’s Medicare payments. It also provides a detailed transition timeline, revised payment schedules, and other important information regarding upcoming changes. In an attempt to make the transition as smooth as possible, we are providing you with this information to ensure minimal disruption in your Medicare payments. We ask that you please take time to read this information carefully and share it with appropriate staff.

Introduction to HIGLAS
A HIGLAS computer-based training module entitled, “Introduction to HIGLAS,” is available on the National Government Services Web site. The Part A training module can be accessed on our Web site at www.NGSMedicare.com.

Announcements of HIGLAS implementation information will also be provided on our Web site, issued in our Listserv messages, and published in our monthly newsletter, the Medicare Monthly Review.

Temporary Waiver of the Claims Processing Payment Floor
CMS has approved {Medicare Contractor Name}’ plan to release claims already approved for payment on March 5, 2008. This payment will include all claims on the payment floor (FISS status/location PB9996). This waiver of the payment floor rules will result in all payments being issued early, including both checks and Electronic Funds Transfers (EFT). This may give the appearance that revenues have increased, when in fact payment has simply been made early on some of your claims.

Transition Activities
The HIGLAS transition activities will begin with National Government Services running the last FISS payment cycle on March 5, 2008. (See Transition Timeline below)

• The temporary waiver of the payment floor rules described above will result in all payments being issued early. This includes both checks and EFTs.
• Providers should continue to submit claims and make routine corrections through Direct Data Entry (DDE) as they normally would.
• The schedule for payments and Remittance Advice (RAs) will return to normal following the transition to HIGLAS the week of March 10, 2008.

HIGLAS Remittance Advice
Because payments are not being issued, Electronic Remittance Advice (ERA) and paper RA issued during the transition will include no-pay claims only. As National Government Services resumes issuing payments, remits will include all claims as usual on March 11, 2008.

National Government Services Transition Timeline

Changes Providers Will See as a Result of HIGLAS

Provider Address Utilized for Overpayment Demand Letters
Currently, the overpayment demand letters for Part A providers are mailed to an Audit and Reimbursement contact previously identified by the provider. After the implementation of HIGLAS, the overpayment demand letters will be mailed to the master physical address of the facility (Address 1 in FISS). This is defined as the “Practice Location Information” in Section 4A on the Provider/Supplier Enrollment application, CMS-855A form.

Claims Displayed on the HIGLAS RA
Prior to the HIGLAS transition, a provider would not see a Periodic Interim Payment (PIP) claim, adjustment, or claim with a status of R (reject) or D (medical denial) in the FISS payment floor (location PB9996). Under HIGLAS, adjustments with a change in the provider reimbursement and all PIP claims will now go to location PB9996. The processing of these claims will be delayed one day. Claims displayed in the PB9996 location are not considered finalized; therefore, providers will not see these claims on the RA statement until the claims have finalized in location PB9997. The one-day delay in the payment of PIP claims and adjustments in PB9996 is not an error. This has been identified as a permanent change resulting from the HIGLAS transition.

HIGLAS Impact on Voided/Reissued Checks
Currently, when a check/payment needs to be voided and reissued, it is a manual process completed in FISS. The reissued payment appears on the Refund payment line of the RA. After the implementation of HIGLAS, if a check needs to be voided and subsequently reissued, the transaction will take place in HIGLAS. The reissued amount will be reflected in the Voided/Reissued line on the RA, and any withholding against reissued payments will be included in the Settlement Withholding line of the RA.

For Example, provider JKL receives a mutilated check. The check was for $1,000. Provider JKL requests that the fiscal intermediary void the check and reissue the payment.

In the current environment, the reissued check would be added to the payment activity for that provider on the date of reissue. Additionally, if the provider has any outstanding withholdings, the reissued payment maybe reduced by any withholdings.

In HIGLAS, the $1,000 voided payment will be included in a future payment, and the $1,000 reissued payment will be noted on the Voided/Reissued line of the RA. No carbon copy of the original RA will be sent. Additionally, if provider JKL has outstanding receivables at the time of reissue, the $1,000 reissued payment may be reduced by any eligible receivables. This will be reflected on the Settlement Withholding line of the RA. Lastly, if provider JKL has additional claim payments at the time of the reissue, those claim payments will be added to the $1,000 reissued payment resulting in a different check amount than the original, mutilated check.

Claims and Settlement Payments Subject to Penalty Withholding
Providers are placed on penalty withholding for late cost reports and credit balance reports. Currently, the penalty withholdings are applied to the net payment after any overpayments have been offset. In HIGLAS, the penalty withholding will be applied at the claim level. As a result, the money withheld for a penalty withholding will be reflected as credited to any overpayment until the penalty withholding is released. Please see the two examples illustrated at the end of this letter for further clarification.

Change for Home Health Providers Only
For home health only, if a final claim paired with a request for anticipated payment (RAP) as a debit/credit pair results in an accounts receivable, the final claim will be returned from HIGLAS prior to the payment floor being satisfied.

HIGLAS Impact on Recoupments from Affiliated Providers
In instances when settlement overpayments are determined, a letter is sent to the provider notifying them of the amount owed to the Medicare Program. If payment is not received within the specified time period, all payments to the provider are recouped until the overpayment is collected. Currently, recoupments also will include any affiliated provider. Under HIGLAS, recoupments will continue in this same manner. Affiliated providers are all providers that have the same Tax Identification Number (TIN). On the ERA, a code of “OA” is used for Part A Affiliated Withholdings, and a code of “OB” is used for Part B Affiliated Withholdings; however, the paper RA does not contain any information to distinguish affiliated withholdings from other withholdings.

Note: It has been determined that some RAs are not displaying withholding information properly under HIGLAS. In some cases, amounts expected to be withheld are not displaying in the summary section. In other cases, a withholding amount is being displayed when in fact there are no withholdings because the payment amount is accurate. This discrepancy between the detail section of the RA and the summary section forces a dollar amount in the Adjustment to Balance line. CMS and the shared system maintainer are addressing this problem.

HIGLAS Penalty Withholding Impact Examples
(1) Provider ABC is on full penalty withholding for failure to submit a cost report. The following claim activity is on the provider’s RA:

Claim 1:       Original Claim for $1,000
Claim 2a:      Positive portion of net positive adjustment for $800
Claim 2b:      Negative portion of net positive adjustment for ($600)
Claim 3a:      Positive portion of net negative adjustment for $400
Claim 3b:      Negative portion of net negative adjustment for ($2,000)

In the current environment, the claims detail would net together to a negative balance of ($400), and an accounts receivable for $400 would be created. No penalty withholding would be assessed.

In HIGLAS, Claim 1 for $1,000, the net of Claims 2a and 2b for $200, and Claim 3a for $400 would be subject to full penalty withholding. Therefore, $1,600 will be held for penalty withholding, and an accounts receivable amount of $2,000 will be established.

(2) Provider XYZ receives a Notice of Payment Suspension letter with the following determinations:

In the current environment, if provider XYZ is on 100-percent penalty withholding, the $7,000 underpayment is first netted against the $4,000 overpayment, and the $3,000 net underpayment is withheld for penalty.

In HIGLAS, the $7,000 underpayment will be subject to 100-percent penalty withholding. However, the $4,000 overpayment will be reduced by the $7,000 underpayment, thus reflecting the correct receivable balance at the time the Notice of Payment Suspension letter is issued.

Claim Processing Impact
Currently, the online system is available on federal holidays and, on most federal holidays we do not process claims. With the implementation of HIGLAS, claims will no longer be processed on federal holidays; however, the online system will continue to be available to providers for entering and correcting claims. Any claims entered or corrected by providers on federal holidays will not be processed until the next night’s claims processing cycle. Payments will not be affected because we do not currently issue checks or EFTs on federal holidays

If you have any questions regarding the information contained in this letter, please contact the Part A Customer Care Contact Center toll-free at (866) 288-0783

Part A Providers in Illinois, Indiana, Kentucky, and Ohio