Healthcare Integrated General Ledger Accounting System (HIGLAS)

Jurisdiction 14 (J14) Part A HIGLAS Transition: Impact on J14 Part A RI Medicare Providers
(Excluding Home Health and Hospice)

April 15, 2010

Dear Provider:

Effective April 16, NHIC, Corp., 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 the Fiscal Intermediary Standard System (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.

NHIC, Corp. HIGLAS Transition

The purpose of this letter is to explain the impact that the NHIC, Corp. 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

NHIC, Corp. published an introduction article that is available at www.medicarenhic.com website under “What’s New”.

A web-based training event entitled “Introduction to HIGLAS” is being offered on April 9 – April 30, 2010. All Part A training workshops can be accessed by selecting Training/Events on the NHIC, Corp. website.

Announcements about the HIGLAS implementation will be provided on the CMS website at http://www.cms.hhs.gov/HIGLAS. Any future updates or information from NHIC, Corp. will be issued in our weekly e-mail lists and published in our bulletins.

Waiver of the Payment Floor

Transition Activities

The HIGLAS transition activities will begin by NHIC, Corp. running the last payment cycle on April 15, 2010 (see Transition Timeline below).

• The waiver of the payment floor rules above will result in all payments being issued early. This will include both checks and EFTs.
• Providers should continue to submit claims and make any routine corrections through Direct Data Entry (DDE) as normal.
• The NHIC, Corp. schedule for payments and Remittance Advices (RAs) will resume normal distribution following the transition of HIGLAS the week of April 19, 2010.

HIGLAS Remittance Advices

Because payments are not being issued, Electronic Remittance Advices (ERAs) and paper RAs will not be issued from April 16, 2010, through April 19, 2010 (depending on if EMC or paper claims are submitted). As NHIC, Corp. resumes issuing payments, providers will be able to retrieve available ERAs as usual on April 20, 2010.

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.

HIGLAS Penalty Withholding Impact – Two 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:

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.

Currently, the online system is available on Federal holidays and, on most Federal holidays we 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 the entering and correcting of 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 Provider Contact Center toll-free at (877)-757-7783. Receive future updates by subscribing to our e-mail list at www.medicarenhic.com.

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04/15/2010