PARA Weekly Update For Users August 15, 2018 by CorroHealth

Date

PARA WEEKLY

UPDATE For Users

I mproving T he Business of H ealthCare Since 1985 August 15, 2018

NEWS FOR HEALTHCARE DECISION MAKERS

IN THIS ISSUE QUESTIONS & ANSWERS - 86617 Versus 86618 - IV Infusion Denied - Chiropractor Orders For X-Ray - GC Modifier On 99291, 99292

OPPS PROPOSED RULE CUTS OFF-CAMPUS REIMBURSEMENT REPRINT: TECHNICAL CHANGE TO INPATIENT ORDERS RULE FOR 2019 IPPS RURAL HEALTHCARE GRANTS MLNCONNECTS MEDICARE PROPOSES TO CEASE THERAPY G-CODES IN 2019 PARA OUTMIGRATION REPORTS

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The number of new or revised Med Learn (MLN Matters) articles released this week. All new and previous Med Learn articles can be viewed under the type "Med Learn", in the Advisor tab of the PARA Dat a Edit or . Click here -------------------------------------------------------

The number of new or revised Transmittals released this week. All new and previous Transmittals can be viewed under the type "Transmittals" in the Advisor tab of the PARA Dat a Edit or . Click here.

Administration: Pages 1-39 HIM /Coding Staff: Pages 1-39 IV Therapy: Page 3 Providers: Pages 2,4,5,7,21,23,33 Chiropractic Care: Page 4 Imaging Services: Page 4 PDE Users: Page 7

Finance: Page 7 Home Health: Page 25 Pharmacy: Page 19 Hospitalists: Page 10 Ambulatory Care: Page 7 DM E: Pages 17, 20 Hospice: Page 18

PARA Weekly Update: August 15, 2018

86617 VERSUS 86618

We perform a screening test for Lyme Disease and charge CPT® 86618 and if positive, we send it on to a reference lab for a confirmatory Western Blot, 86617. We have recently changed to a new reference lab to performs the ?confirmatory? test, but they charge us the CPT ®86618. Our claims for two units of 86618 get denied for duplicate testing and would prefer to not have to use a modifier. Is there any reason we can?t charge the 86617 since it is confirmatory? These codes do not seem to specify methodology. Answer: The methodology is only briefly mentioned in the CPT® description for 86617, however, there are differences and we are obligated to report the test that was performed. Here are the full CPT® descriptions:

According to the Coder?s Desk Reference, the two tests have different methodologies. Here?s what it says: 86617 - This test may be ordered as a Lyme disease confirmation test. Borrelia burgdorferi is the causative agent of Lyme disease, (the vector being a tick). Antibodies usually build up in patients several weeks or longer into an infection. This test is confirmatory, meaning previous diagnostic work has been performed. Blood specimen is serum. CSF specimen is obtained by spinal puncture that is reported separately. This test reports a second test for confirmation by immunoblot or Western blot. It may also be used to establish a diagnosis following indeterminate ELISA results. 86618 - This test may be ordered simply as a Lyme disease antibody test. Borrelia burgdorferi is the causative agent of Lyme disease,(the vector being a tick). Antibodies usually build up in patients several weeks or longer into an infection. Blood specimen is serum. CSF specimen is obtained by spinal puncture, which is reported separately. Methods include enzyme-linked immunosorbent assay (ELISA), enzyme immunoassay (EIA), indirect fluorescent antibody (IFA), or specific IgG, IgM, and IgA by antibody capture. We don?t recommend changing the code that was reported by the reference lab without verifying how they performed the test. The CPT® reported needs to match the testing performed. Instead, we recommend contacting the reference lab to verify whether they performed the service ordered (western/immunoblot) or elected to perform the immunoassay (also check how the order was communicated to them ? they may have been following the order placed.) It is always possible that they reported the wrong CPT® code. And finally, Medicare?s ?Medically Unlikely Edit? (MUE) for either 86617 or 86618 is 2 per DOS, therefore it should not be a problem whether billing two units on one line (which does not require a modifier) or two lines with modifier 91 (Repeat Clinical Laboratory Test) on the second line. Incidentally, Medicare often ?packages? payments for these lab tests when reported on the same claim as other payable hospital services, such as an ED visit.

PARA Weekly Update: August 15, 2018

IV INFUSION DENIED

We have had some minor issues with payers denying infusion/injections, etc. Attached are two sample claims along with the remittance advice.

Answer: When reporting outpatient services, IV therapy must be coded for each calendar date of service with a primary code. Therefore, coding add-on HCPCS 96361 without a primary IV therapy code such as 96360 for DOS 4/2/18 will not be reimbursed. Here?s an excerpt from the claim (no PHI):

Here's an excerpt from the remittance:

We also point out that a total of ten10 hours of hydration is unlikely. If an IV remains open at a low flow for the purpose of keeping it available should other medications be required, do not report hydration 96360 or 96361. We recommend billing hydration only if at least 500cc of hydration fluid is administered per hour. You may want to check that medical record to verify the flow rate and/or the number of cc?s of hydration fluid that was administered during the 10 hours reported with 96361.

PARA Weekly Update: August 15, 2018

CHIROPRACTOR ORDERS FOR X-RAY

Can a chiropractor order x-rays for a patient whose has commercial insurance? And, can a mid-level provider working for the chiropractor order x-rays and MRIs for both Medicare and commercial insurances?

Answer: A mid-level provider cannot order procedures and Medicare does not cover x-rays ordered by chiropractors. Another physician may order an x-ray for use by a chiropractor, but the chiropractor order does not qualify for reimbursement. Attached is a MedLearn article that discusses this point, It is written for an audience of chiropractors: https://www.cms.gov/Outreach-and-Education/ Medicare-Learning-Network-MLN/MLNMattersArticles /downloads/se0416.pdf A midlevel working for the chiropractor (such as a PA or nurse practitioner) may order plain x-rays for the chiropractor, but not an MRI. If the purpose of the MRI is to inform the chiropractor, it will not meet coverage requirements.

PARA Weekly Update: August 15, 2018

GC MODIFIER ON 99291, 99292

Is it appropriate to use the GC modifier with critical care codes 99291 and 99292 for professional billing in the emergency department?

Answer: It is acceptable to use the GC modifier (THESE SERVICES HAVE BEEN PERFORMED BY A RESIDENT UNDER THE DIRECTION OF A TEACHING PHYSICIAN) on critical care codes 99291 and 99292 if the documentation indicates that the teaching physician was present for the entire period of time reported on these time-based codes. The GC modifier is reported by a teaching physician to claim reimbursement for services s/he supervised, but were performed by a resident.

Chapter 12 of the Medicare Claims Processing Manual offers the following guidance: https://www.cms.gov/Regulations-and-Guidance/ Guidance/Manuals/Downloads/clm104c12.pdf

Here is the pertinent language under section 100, referenced: 100.1.8 - Physician Billing in the Teaching Setting (Rev. 2303, Issued: 09-14-11, Effective: 06-01-11, Implementation: 07-26-11) A. A/B MAC (B) Claims The method by which services performed in a teaching setting must be billed is determined by the manner in which reimbursement is made for such services. For A/B MACs (B), the shared system suspends claims submitted by a teaching physician, for review. 5

PARA Weekly Update: August 15, 2018

GC MODIFIER ON 99291, 99292

B. Billing Modifiers Effective January 1, 1997, services furnished by teaching physicians involving a resident in the care of their patients must be identified as such on the claim. To be payable, claims for services furnished by teaching physicians involving a resident must comply with the requirements in sections 100.1 through 100.1.6 of this chapter, as applicable. Claims for services meeting these requirements must show either the GC or GE modifier as appropriate and described below. 1. Teaching Physician Services that Meet the Requirement for Presence During the Key/Critical Portion of the Service Claims for teaching physician services in compliance with the requirements outlined in sections 100.1 -100.1.6 of this chapter must include a GC modifier for each service, unless the service is furnished under the primary care center exception described in section 100.1.1C (refer to number 2, below). When a physician (or other appropriate billing provider) places the GC modifier on the claim, he/she is certifying that the teaching physician has complied with the requirements in sections 100.1 through 100.1.6. 2. Teaching Physician Services Under the Exception for E/M Services Furnished in Primary Care Centers Teaching physicians who meet the requirements in section 100.1.1C of this chapter must provide their A/B MAC (B) with an attestation that they meet the requirements. Claims for services furnished by teaching physicians under the primary care center exception must include the GE modifier on the claim for each service furnished under the primary care center exception. ? 100.1.4 - Time-Based Codes (Rev. 811, Issued: 01-13-06, Effective: 01-01-06, Implementation: 02-13-06) For procedure codes determined on the basis of time, the teaching physician must be present for the period of time for which the claim is made. For example, a code that specifically describes a service of from 20 to 30 minutes may be paid only if the teaching physician is physically present for 20 to 30 minutes. Do not add time spent by the resident in the absence of the teaching physician to time spent by the resident and teaching physician with the beneficiary or time spent by the teaching physician alone with the beneficiary. Examples of codes falling into this category include: - Individual medical psychotherapy (HCPCS codes 90804 - 90829); - Critical care services (CPT codes 99291-99292); - Hospital discharge day management (CPT codes 99238-99239); - E/M codes in which counseling and/or coordination of care dominates (more than 50 percent) of the encounter, and time is considered the key or controlling factor to qualify for a particular level of E/M service; - Prolonged services (CPT codes 99358-99359); and - Care plan oversight (HCPCS codes G0181 - G0182).

PARA Weekly Update: August 15, 2018

OPPS PROPOSED RULE CUTS OFF-CAMPUS REIMBURSEMENT

n the 2019 OPPS Proposed Rule, CMS proposes to reduce payment for all off-campus hospital outpatient clinic visits (HCPCS G0463) at 40% of the APC rate that would apply for an on-campus visit, regardless whether the clinic was ?excepted? (grandfathered) or non-excepted (non-grandfathered, i.e. established after November 2, 2015.) (This provision would apply only to OPPS APC reimbursed facilities, it does not appear to affect CM S pr oposes t o r edu ce paym en t f or all reimbursement paid to Critical Access of f -cam pu s h ospit al ou t pat ien t clin ic visit s Hospitals, although CAHs are not (HCPCS G0463) at 40% of t h e APC r at e t h at specifically addressed.) w ou ld apply f or an on -cam pu s visit , r egar dless In other words, under OPPS, Medicare w h et h er t h e clin ic w as ?except ed?. reimbursement for HCPCS G0463 would be reduced to 40% of the on-campus APC rate when the visit is provided at an off-campus hospital department location, as indicated by either modifier PO or modifier PN modifier is appended to G0463. Modifier PO (Services,procedures and/or surgeries furnished off-campus provider-based outpatient departments) must be appended to HCPCS for services provided at an excepted/grandfathered clinic location, and modifier PN (Non-excepted items and services for provider-based department (PBD)) must be appended to HCPCS for services provided a non-excepted/non-grandfathered off-campus hospital location.

Outpatient visits billed with G0463 on the hospital campus and at dedicated emergency departments will apparently be paid at the full APC rate, however. HCPCS code G0463 is the most commonly reported service billed at off-campus locations which serve as physician office locations. Hospitals began acquiring physician clinics and establishing their location as provider-based departments in 2001, when CMS loosened the criteria for establishing a provider-based clinic. The idea of purchasing and converting physician offices to off-campus hospital locations caught great momentum as word spread that the same physician visit billed by a provider-based clinic could yield more than double the Medicare payment as compared to billing by a free-standing physician office location. Now that this practice has proliferated, the rate of reimbursement is unsustainable, and Medicare now seeks to reduce the financial burden that it previously unleashed by relaxing its regulations. CMS intends that this change would result in overall savings (between both the Medicare Program and beneficiary copayments) of $760 million for 2019.

PARA Weekly Update: August 15, 2018

OPPS PROPOSED RULE CUTS OFF-CAMPUS REIMBURSEMENT

Additionally, on page 37050 of the 2019 OPPS Proposed Rule, CMS proposes to pay at the lower Medicare Physician Fee Schedule for any new services offered at off-campus locations. ?? if an excepted off-campus PBD furnishes a service from a clinical family of services for which it did not previously furnish a service (and subsequently bill for that service) during a baseline period, services from this new clinical family of services would not be covered OPD services. Instead, services in the new clinical family of services would be paid under the PFS.? Here are excerpts from the proposed rule pertinent to off-campus location reimbursement: ?? We believe that the higher payment that is made under the OPPS, as compared to payment under the PFS, is likely to be incentivizing providers to furnish care in the hospital outpatient setting rather than the physician office setting. In 2012, Medicare was paying approximately 80 percent more for a 15-minute office visit in a hospital outpatient department than in a [[Page 37142]] freestanding physician office. ? ?Therefore, given the unnecessary increases in the volume of clinic visits in hospital outpatient departments, for the CY 2019 OPPS, we are proposing to use our authority under section 1833(t)(2)(F) of the Act to apply an amount equal to the site-specific PFS payment rate for nonexcepted items and services furnished by a nonexcepted off-campus PBD (the PFS payment rate) for the clinic visit service, as described by HCPCS code G0463, when provided at an off-campus PBD excepted from section 1833(t)(21) of the Act (departments that bill the modifier ``PO'' on claim lines). Off-campus PBDs that are not excepted from section 603 (departments that bill the modifier ``PN'') already receive a PFS-equivalent payment rate for the clinic visit. In CY 2019, for an individual Medicare beneficiary, the standard unadjusted Medicare OPPS proposed payment for the clinic visit is approximately $116, with approximately $23 being the average copayment. The proposed PFS equivalent rate for Medicare payment for a clinic visit would be approximately $46 and the copayment would be approximately $9. This would save beneficiaries an average of $14 per visit. Under this proposal, an excepted off-campus PBD would continue to bill HCPCS code G0463 with the ``PO'' modifier in CY 2019, but the payment rate for services described by HCPCS code G0463 when billed with modifier ``PO'' would now be equivalent to the payment rate for services described by HCPCS code G0463 when billed with modifier ``PN''.? 8

PARA Weekly Update: August 15, 2018

OPPS PROPOSED RULE CUTS OFF-CAMPUS REIMBURSEMENT

And finally, in 2019, CMS intends to limit reimbursement of drugs purchased under the 340b drug discount program to the same rate paid in the on-campus setting (ASP ? 22%) when the drugs are dispensed at an non-excepted/non-grandfathered off-campus location. Non-excepted off-campus locations are not subject to the 340b reimbursement changes put in place as of 1/1/2018. Here is an excerpt in regard to the change in payment for drugs supplied under the 340b program at an off-campus location: ?? the difference in the payment amounts for 340B-acquired drugs furnished by hospital outpatient departments-- excepted off-campus PBDs versus nonexcepted off-campus PBDs--creates an incentive for hospitals to move drug administration services for 340B- acquired drugs to nonexcepted off-campus PBDs to receive a higher payment amount for these drugs, thereby undermining our goals of reducing beneficiary cost-sharing for these drugs and biologicals and moving towards site neutrality through the section 603 amendments to section 1833(t) of the Act. Therefore, for CY 2019, we are proposing changes to the Medicare Part B drug payment methodology for drugs and biologicals furnished and billed by nonexcepted off-campus departments of a hospital that were acquired under the 340B Program. Specifically, for CY 2019 and subsequent years, we are proposing to pay under the PFS the adjusted payment amount of ASP minus 22.5 percent for separately payable drugs and biologicals (other than drugs on pass-through payment status and vaccines) acquired under the 340B Program when they are furnished by nonexcepted off-campus PBDs of a hospital. Furthermore, in this CY 2019 OPPS/ASC proposed rule, we are proposing to except rural sole community hospitals, children's hospitals, and PPS-exempt cancer hospitals from this payment adjustment. We believe that our proposed payment policy would better reflect the resources and acquisition costs that nonexcepted off-campus PBDs incur for these drugs and biologicals.? The full text of the 2019 Medicare Physician Fee Schedule Proposed rule is available on the PARA Data Editor Advisor tab using the search phrase ?2019?:

PARA Weekly Update: August 15, 2018

TECHNICAL CHANGE TO INPATIENT ORDERS RULE FOR 2019 IPPS

edicare published the 2019 Inpatient Prospective Payment System Final Rule at the link below: https://s3.amazonaws.com/public-inspection.federalregister.gov/2018-16766.pdf Among other changes in the Final Rule, Medicare provided new latitude for claim auditors in enforcing the IPPS requirement for signed and dated physician order to admit the patient to inpatient status by changing the language of regulations at 42 C.F.R. § 412.3(a). The language that Medicare will delete in the Code of Federal Regulations appears in strikethrough below: https://www.gpo.gov/fdsys/pkg/CFR-2013title42-vol2/pdf/CFR-2013-title42-vol2sec412-3.pdf § 412.3 Admissions. (a) For purposes of payment under Medicare Part A, an individual is considered an inpatient of a hospital, including a critical access hospital, if formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitioner in accordance with this section and §§ 482.24(c), 482.12(c), and 485.638(a)(4)(iii) of this chapter for a critical access hospital. This physician order must be present in the medical record and be supported by the physician admission and progress notes, in order for the hospital to be paid for hospital inpatient services under Medicare Part A. In addition to these physician orders, inpatient rehabilitation facilities also must adhere to the admission requirements specified in § 412.622 of this chapter. Based on the proposal to change the regulatory language in the IPPS proposed rule for 2019, providers were optimistic that Medicare?s new regulation would permit hospitals to report services lacking an order to admit, but which otherwise qualify for inpatient status as inpatient admissions, and an inpatient encounter reimbursed under Part A. However, the final rule falls far short of providing the full extent of relief providers had hoped to gain. The responses provided by CMS to questions submitted by commenters indicate that the new language is intended primarily to allow medical review auditors more latitude in allowing payment under Part A if the physician order is incomplete in some technical respect, so long as the rest of the documentation in the medical record appears to support the physician?s intent to admit to inpatient status. In its responses to commenters on the proposed rule, CMS clearly does not invite hospitals to relax their current processes for obtaining a physician order as a condition of submitting a claim for inpatient reimbursement. Specifically, commenters asked if the new language allows for billing an inpatient-only procedure performed before the order to be an inpatient is placed as an inpatient claim, provided that the intent of the physician was to admit the patient; CMS did not fully understand this question, and therefore stated it would not address that comment. 10

PARA Weekly Update: August 15, 2018

TECHNICAL CHANGE TO INPATIENT ORDERS RULE FOR 2019 IPPS

Commenters also questioned whether an outpatient stay could retroactively be deemed to be an inpatient stay (no); whether condition code 44 would continue to be required (CMS declined to address); and whether the new rule would be retroactive (no, it will not take effect until 10/1/18.) Here are excerpts from the section of the Final Rule which addresses this change, pages 1390 to 1407: ?? Common technical discrepancies consist of missing practitioner admission signatures, missing co-signatures or authentication signatures, and signatures occurring after discharge. We have become aware that, particularly during the case review process, these discrepancies have occasionally been the primary reason for denying Medicare payment of an individual claim. In looking to reduce unnecessary administrative burden on physicians and providers and having gained experience with the policy since it was implemented, we have concluded that if the hospital is operating in accordance with the hospital CoPs, medical reviews should primarily focus on whether the inpatient admission was medically reasonable and necessary rather than occasional inadvertent signature documentation issues unrelated to the Common technical discrepancies consist of missing practitioner medical necessity of admission signatures, missing co-signatures or authentication the inpatient stay. It signatures, and signatures occurring after discharge have become was not our intent when we finalized the occasionally been the primary reason for denying payment. admission order documentation requirements that they should by themselves lead to the denial of payment for medically reasonable and necessary inpatient stays, even if such denials occur infrequently. ?Therefore, in the FY 2019 IPPS/LTCH PPS proposed rule (83 FR 20447 and 20448), we proposed to revise the admission order documentation requirements by CMS-1694-F 1393 removing the requirement that written inpatient admission orders are a specific requirement for Medicare Part A payment. Specifically, we proposed to revise the inpatient admission order policy to no longer require a written inpatient admission order to be present in the medical record as a specific condition of Medicare Part A payment. Hospitals and physicians are still required to document relevant orders in the medical record to substantiate medical necessity requirements. If other available documentation, such as the physician certification statement when required, progress notes, or the medical record as a whole, supports that all the coverage criteria (including medical necessity) are met, and the hospital is operating in accordance with the hospital conditions of participation (CoPs), we stated that we believe it is no longer necessary to also require specific documentation requirements of inpatient admission orders as a condition of Medicare Part A payment. We stated that the proposal would not change the requirement that an individual is considered an inpatient if formally admitted as an inpatient under an order for inpatient admission. While this continues to be a requirement, as indicated earlier, technical discrepancies with the documentation of inpatient admission orders have led to the denial of otherwise medically necessary inpatient admission. To reduce this unnecessary administrative burden on physicians and providers, we proposed to no longer require that the specific documentation requirements of inpatient admission orders be present in the medical record as a condition of Medicare Part A payment. ?After consideration of the public comments we received, we are finalizing our proposal to revise the inpatient admission order policy to no longer require a written inpatient admission order to be present in the medical record as a specific condition of Medicare Part A payment. Specifically, we are finalizing our proposal to revise the regulation at 42 CFR 412.3(a) to remove the language stating that a physician order must be present in the medical record and be supported by the physician admission and progress notes, in order for the hospital to be paid for hospital inpatient services under Medicare Part A.? 11

PARA Weekly Update: August 15, 2018

RURAL HOSPITAL PROGRAM GRANTS AVAILABLE

Rural hospitals and clinics face their own set of unique and burdensome challenges when it comes to program development, cash management and maintaining volume. That's why it's great when they can get some assistance from external funding sources. At PARA, we've found an excellent source of funding opportunities for rural healthcare facilities. Here are some examples.

Rural Residency Planning And Development Program Technical Assistance - Provides $800,000 for three years to promote the process of rural residencies-to-rural pipeline by assisting with the development of new rural family medicine, internal medicine, or psychiatry residency programs. - Application Deadline: August 22,2018

Montana Mental Health Trust Funding - Provide up to $500,000 of funding for programs, services, and resources for: - The prevention, treatment, and management of serious mental illness in Montana children and adults - Training and education for law enforcement personnel and more - Application Deadline: September 14, 2018

Service Area Funding For Health Center Programs - Provides $1,000,000 for Technologies for Improving Population Health and Eliminating Health Disparities to develop partnerships between innovative small business concerns and nonprofit research institutions resulting in improving minority health and the reduction of health disparities by commercializing innovative technologies. Rural populations are included in the listed health disparities priority populations.

- Application Deadline: October 1, 2018 12

PARA Weekly Update: August 15, 2018

MLN CONNECTS

PARA invites you to check out the mlnconnects page available from the Centers For Medicare and Medicaid (CMS). It's chock full of news and information, training opportunities, events and more! Each week PARA will bring you the latest news and links to available resources. Click each link or the PDF!

Thursday, August 2, 2018 News & Announcements · Help Your Medicare Patients Avoid and Report Scams · SNF VBP FY 2019 Annual Performance Score Report: Submit Correction Requests by August 31 · Quality Payment Program Exception Applications Due by December 31 · Quality Payment Program: 2017 MIPS Performance Feedback and Payment Adjustment · Quality Payment Program Performance Feedback and Targeted Review Videos · Medicare Diabetes Prevention Program Suppliers: Separate Medicare Enrollment · Vaccines are Not Just for Kids Provider Compliance · Reporting Changes in Ownership ? Reminder Upcoming Events · ESRD Quality Incentive Program: CY 2019 ESRD PPS Proposed Rule Call ? August 14 · Physician Fee Schedule Proposed Rule: Understanding 3 Key Topics Listening Session ? August 22 · Comparative Billing Report on Licensed Clinical Social Workers Webinar ? September 12 Medicare Learning Network® Publications & Multimedia · Quarterly Influenza Virus Vaccine Code Update: January 2019 MLN Matters Article ? New · Update to Medicare Claims Processing Manual, Chapter 24 MLN Matters Article ? New · IRF Annual Update: PPS Pricer Changes for FY 2019 MLN Matters Article ? New · Implementing Epoetin Alfa Biosimilar, Retacrit for ESRD/AKI Claims MLN Matters Article ? New · Medicare Claims Processing Manual, Chapter 24 Update: Form Letters ? New · IPF PPS Updates for FY 2019 MLN Matters Article ? New · ASP Medicare Part B Drug Pricing Files and Revisions: October 2018 MLN Matters Article ? New · August 2018 Catalog ? Revised · Medicare Preventive Services Educational Tool ? Revised · Medicare Enrollment for Providers Who Solely Order, Certify, or Prescribe Booklet ? Revised · Quality Payment Program Year 2 Overview Web-Based Training Course ? Revised · Quality Payment Program: MIPS Promoting Interoperability Performance Category Year 2 Web-Based Training Course ? Revised · Quality Payment Program MIPS Quality Performance Category Year 2 Web-Based Training Course ? Revised

PARA Weekly Update: August 15, 2018

MEDICARE PROPOSES TO CEASE THERAPY G-CODES IN 2019

In the 2019 Medicare Physician Fee Schedule Proposed Rule, Medicare announces its intention to cease requiring functional limitation G-code reporting for physical, occupational, and speech therapy services. Since OPPS facilities are paid for therapies under the MPFS, this change will apply to hospitals as well as independent therapy service locations. The full text of the 2019 Medicare Physician Fee Schedule Proposed rule is available on the PARA Data Editor Advisor tab using the search phrase ?2019?:

The following are pertinent excerpts from pages 390-395 of the rule: ?? we established our functional reporting claims-based data collection strategy effective January 1, 2013 in the CY 2013 PFS final rule (77 FR 689580 through 68978) and will have been collecting these functional reporting data for the last 5 years at the close of CY 2018. ? we reviewed and analyzed the data internally but did not find them particularly useful in considering how to reform payment for therapy services as an alternative to the therapy caps. ? ?? [The Middle Class Tax Relief and Jobs Creation Act (MCTRJCA) of 2012] did not specify how long the data collection strategy should last, we do not believe it was intended to last indefinitely. ? we do not believe that collecting additional years of functional reporting data in this reduced format would add utility to our data collection efforts. ?After consideration of these comments on the RFI along with a review of all of the requirements under section 3005(g) of MCTRJCA, and in light of the recent statutory amendments to section 1833(g) of the Act, we have concluded that continuing to collect more years of these functional reporting data, whether through the same or a reduced format, will not yield additional information that would be useful to inform future analyses, and that allowing the current functional reporting requirements to remain in place could result in unnecessary burden for providers of therapy services without providing further benefit to the Medicare program in the form of additional data. ?As a result, we are proposing to discontinue the functional reporting requirements for services furnished on or after January 1, 2019. ? ?If finalized, our proposal would end the requirements for the reporting and documentation of functional limitation G-codes (HCPCS codes G8978 through G8999 and G9158 through G9186) and severity modifiers (in the range CH through CN) for outpatient therapy claims with dates of service on and after January 1, 2019. Accordingly, with the conclusion of our functional reporting system for dates of service after December 31, 2018, we would delete the applicable non-payable HCPCS G-codes specifically developed to implement that system through the CY 2013 PFS final rule with comment period (77 FR 68598 through 68978). ?We are seeking comment on these proposals.? Comments on the Proposed Rule will be accepted by CMS prior to 5 PM EST on September 24, 2018. 14

PARA Weekly Update: August 15, 2018

PARA INTRODUCES NEW OUTPATIENT OUTMIGRATION REPORTS In their continuing expansion of product lines critical to streamlining hospital data collection and improving decision support tools for Chief Executive Officers, Chief Financial Officers and Business Development executives, PARA Analytics introduces the new Outpatient Migration Report. Among other items, PARA customers using this vital report will be able determine where patients in their primary and secondary service areas are going for outpatient services, total volumes of selected outpatient services and the value of these services. The Outpatient Migration Report provides information on Medicare Outpatient Visits and the patient?s county of residence. The source of this information is the Medicare Outpatient Limited Data Set. For the selected hospital, the top ten counties are identified based on the number of outpatient visits from those counties of residence. These counties are listed horizontally across an easy-to-read report. All facilities that had an outpatient visit from the selected hospital?s home county are listed vertically on the report and it then details how many outpatient visits to each facility originated from each of the ten corresponding counties. The Outpatient Migration Report includes ten tabs with this same format. The first tab includes statistics on all outpatient visits. The subsequent nine tabs include the visit counts that have been identified as specific visit types. These include: - Emergency, Mammography - CT - MRI - Therapy - GI - Diagnostic Radiology - Lab, and - Wound Care The final tab provides reference information on how outpatient visits are assigned to the preceding categories. If any of the listed codes appear on the claim, then the visit is assigned the corresponding label. PARA Analytics is the first national healthcare financial firm to develop such valuable reports in a more timely manner than data typically available from public sources. Using PARA?s proprietary algorithms in the PARA Data Editor, PARA can rapidly produce relevant and functional reports. For more information and a demonstration of these new reports, please contact PARA Account Executives: Violet Archuleta-Chiu, Senior Account Executive varchuleta@para-hcfs.com (800) 999-3332, ext. 219 Sandra LaPlace, Account Executive slaplace@para-hcfs.com (800) 999-3332, ext. 225 15

PARA Weekly Update: August 15, 2018

There were FOUR new or revised Med Learn (MLN Matters) articles released this week. To go to the full Med Learn document simply click on the screen shot or the link.

FIND ALL THESE MED LEARNS IN THE ADVISOR TAB OF THE PDE

PARA Weekly Update: August 15, 2018

The link to this Med Learn MM18010

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The link to this Med Learn MM10631

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The link to this Med Learn MM10834

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The link to this Med Learn MM10881

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The link to this Med Learn MM10898

PARA Weekly Update: August 15, 2018

There were ELEVEN new or revised Transmittals released this week. To go to the full Transmittal document simply click on the screen shot or the link.

FIND ALL THESE TRANSMITTALS IN THE ADVISOR TAB OF THE PDE

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