CorroHealth Weekly eJournal, June 1, 2023

Are Your NSA Documents Compliant?

The NSA?s intent is to provide transparency in healthcare costs and prevent balance billing, and to meet those objectives NSA documents must communicate informative estimates and clearly explain the patient?s rights under the NSA Join us as we review the CMStemplates of required NSA documents and demonstrate how to properly utilize these documents for the patient?s greatest benefit.

CorroHealth?s ?No Surprises Act and Price Transparency, a New Monthly Series?was created to provide attendees with clarity around No Surprises Act, to answer questions, and get you on the best path for success. The series also clarifies payers?increased role in the process, the status of impactful legislation, and the processes providers should follow to comply

About Barbara Johnson, BSN, RN ?Senior Revenue Cycle Consultant

Leading the series is CorroHealth?s resident subject matter expert, Barbara Johnson, BSN, RN ?Senior Revenue Consultant

As a registered nurse Johnson worked in emergency medicine before transitioning into nursing administration She entered the specialty of Revenue Integrity as a nurse auditor where she expanded her knowledge of coding and revenue cycle compliance through membership in AAPCand HFMA Today, she is CorroHealth?s leading subject matter expert on NSA

Invalid HCPCS Code J0610

Quest ion:

We have a charge that is saying invalid HCPCScode. The invalid code is J0610. It says no new code has been created How would I create a charge code if I have to add an HCPCScode for that?

Answ er:

We have not yet updated the HCPCSreport in our system to crosswalk the recently deleted HCPCSJ0610 to the replacement codes J0612 and J0613, but that update will be added soon. In the meantime, we notified clients with J0610 in the chargemaster of the required update by email; the email we sent to you is attached.

Since we did not have an NDCfor this line item for the drug coded J0610 in the hospital chargemaster, we could not determine which of the two replacement HCPCSto recommend. Many other clients reported NDC63323-0360-19, which would map to J0612 ? but again, we recommend checking the NDCto verify the correct HCPCS

There is another way that PARA Dat a Edit or users can verify the correct HCPCSfor a drug or NDCusing the Calculator tab -- enter the NDCinto the Calculator field and selecting the ?NDCto J-Codes?report, then click ?Submit?

(SeeNext PageFor Example)

The report returned will advise whether the drug queried has an HCPCSassigned by Medicare

RVUs For Infusion Oversight

Quest ion:

We have been told by another facility in our area that their providers get paid for RVUs generated for infusion oversight in the infusion room We are unable to find any type of code for infusion oversight that would generate RVUs for our providers, as there are no professional charges being billed with infusions. Is there something we are missing?

Answ er:

There are no CPT®/HCPCSwhich describe supervising an IVinfusion The 2023 Medicare National Correct Coding Initiative Policy Manual provides the following guidance:

https://www cms gov/files/document/medicare-ncci-policy-manual-2023-chapter-11 pdf

Medicare reimburses physicians and non-physician practitioners for only those services they personally perform in the hospital setting

Glucose Test Denials

Quest ion:

We are having an issue with glucose test being denied. We are using CPT® code 82926. Our process: We use a glucose monitor, similar to an at-home monitor, using a finger-stick method. The monitor is larger than an at-home monitor and interfaces with Epic, which then drops a CPT® charge for each. Medicare and Medicare HMOs are denying anything over two being charged We are wondering if we are using the correct CPT® code and why we would be seeing this denial for anything over two. Can you help?

Answ er:

You likely meant to type CPT® 82962 ? which has been assigned a Medically Unlikely Unit value of 2 by Medicare This means that Medicare will deny more than two units of 82962 on an outpatient claim; the hospital may appeal the denial with medical records because Medicare has assigned an MUEAdjudication Indicator (MAI) of 3, which means that the MACwill automatically deny any excess units but consider payment on appeal.

We do not recommend reporting POCglucose testing for routine glucose level monitoring provided to hospital patients ? such testing is not diagnostic, but considered a standard of nursing care, and should not be separately charged.

Frequently Asked Questions About CMS Waivers & The End Of The PHE

Officially, the United States Department of Human Services ended the federal Public Health Emergency (PHE) on May 11, 2023.

CMShas published a Frequently Asked Questions document covering many of the issues related to healthcare providers following the end of the PHE An excerpt of some of those questions appears here

Many of t he flexibilit ies and w aivers in place are t ied t o em ergency declarat ions, legislat ive act ions by Congress, and regulat ory act ions across governm ent . Can t he Cent ers for Medicare & Medicaid Services (CMS) ext end Medicare, Medicaid, and Market place flexibilit ies beyond May 11, 2023, w hen t he Adm inist rat ion is planning t o end t he PHE?

Thanks to the Administration?s whole-of-government approach to combatting the virus, we are in a better place in our response than we were three years ago, and we can transition away from an emergency phase

The emergency declarations, legislative actions by Congress, and regulatory actions across government, including by CMS, allowed for changes to many aspects of health care delivery during the COVID-19 PHE. Health care providers received maximum flexibility to streamline delivery and allow access to care during the PHE

While some of these changes will be permanent or have been extended due to Congressional action, some waivers and flexibilities will expire, as they were intended to respond to the rapidly evolving pandemic, not to permanently replace standing rules.

CMShas released several documents that identify when waivers and flexibilities will end, as well as which waivers and flexibilities have been extended or will remain beyond the end of the PHE

To help individuals served by our programs know what to expect when the COVID-19 PHE ends, CMSreleased a fact sheet that highlights major impacts CMSalso released provider-specific fact sheets that will help the health care sector transition to non-emergency operations when the PHEends

In addition, CMSdeveloped a roadmap for the eventual end of the COVID-19 PHEand is sharing information on what health care facilities and providers can do to prepare for future emergencies

Additionally, CMSis offering technical assistance to States overseeing Medicaid and CHIP programs and engaging in public education about the necessary steps to prepare for the end of the PHE, including guidance on the end of the Medicaid continuous enrollment condition and the expiration of many other temporary authorities adopted by states during the COVID-19 PHE For additional information, visit CMSgov

When t he PHE ends, w ill people insured by Medicare pay for COVID-19 vaccines?

People with Medicare coverage will continue to have access to COVID-19 vaccinations without out-of-pocket costs after the end of the PHE. Once the federal government is no longer purchasing or distributing COVID-19 vaccines, people with Traditional Medicare pay nothing for a COVID-19 vaccination if their doctor or other qualified health care provider accepts assignment for giving the shot Those with Medicare Advantage (MA) plans should contact their plan for details about payment for COVID-19 vaccines, but MA beneficiaries will pay nothing for a COVID-19 vaccination if they receive their vaccinations from an in-network provider

How m uch w ill CMS pay healt h care providers t o adm inist er COVID-19 vaccines t hrough t he end of t he 2023 calendar year?

Under the Medicare Part B preventive vaccine benefit, CMSwill continue to pay approximately $40 per dose for administering COVID-19 vaccines through the end of the calendar year in which the Secretary ends the Emergency Use Authorization (EUA) declaration for drugs and biologicals with respect to COVID-19 The COVID-19 EUA declaration has not ended Note: The COVID-19 EUA declaration is distinct from, and not dependent on, the federal PHEfor COVID-19, expected to expire on May 11, 2023, or the COVID-19 National Emergency that ended April 10, 2023

Effective January 1 of the year following the year in which the EUA declaration ends, CMSwill set the payment rate for administering COVID-19 vaccines to align with the payment rate for administering other Part B preventive vaccines, which is currently approximately $30 per dose 5/5/2023 These payment rates do not apply in settings that are paid at reasonable cost for preventive vaccines and their administration (for example, Federally Qualified Health Centers and Rural Health Clinics).

If someone is enrolled in an MA plan, the provider should submit claims for vaccine administration to the MA plan, and the amount the provider is paid for the vaccine administration service is determined by the contract between the MA plan and the provider if there is a contract If there is no contract in place for COVID-19 vaccinations covered by the MA plan, the Medicare payment rate would apply.

After the PHE, will the additional payment for at-home COVID-19 vaccinations continue?

Medicare will continue to pay an additional amount of about $36 in addition to regular administration fees for the administration of COVID-19 vaccines at home This additional Medicare payment for at-home COVID-19 vaccinations will continue through the end of calendar year 2023

For individuals enrolled in a MA plan, provider payment rates are determined by the contract between the MA plan and the provider when such a contract is in place and may or may not include additional payments for at-home COVID-19 vaccinations. If there is no contract in place for vaccinations covered by the MA plan, the Medicare payment rate would apply

When w ill t he enforcem ent discret ion end t hat allow s m ass im m unizers t o bill direct ly t o Part B for vaccines furnished t o Skilled-Nursing Facilit y (SNF) pat ient s in a Medicare-covered st ay?

Anticipating the end of the COVID-19 PHEon May 11, 2023, the enforcement discretion associated with this policy would end on June 30, 2023. Beginning on July 1, 2023, SNFs will be responsible for billing for vaccines furnished to SNFpatients in a Part A stay. Third-party suppliers furnishing these vaccines under arrangement with the SNFwould be required to seek payment from the SNFfor their services, consistent with SNFConsolidated Billing regulations

Will Medicare cont inue t o cover t reat m ent (s) for pat ient s w it h

COVID-19?

Yes There is no change in Medicare coverage of treatments for those exposed to COVID-19 once the PHEends, and in cases where cost sharing and deductibles apply now, they will continue to apply Generally, the end of the COVID-19 PHEdoes not change access to oral antivirals, such as Paxlovid and Lagevrio For individuals enrolled in a MA plan, the plans must cover treatments that Traditional Medicare covers, but they may require the individual to see a provider who is in the MA plan?s network and may have different cost sharing than Traditional Medicare.

How w ill Medicare cover diagnost ic t est ing for COVID-19?

Those with Traditional Medicare can continue to receive COVID-19 PCRand antigen tests with no cost-sharing when the test is ordered by a physician or certain other health care providers, such as physician assistants and certain registered nurses, and performed by a laboratory.

People enrolled in MA plans can continue to receive COVID-19 PCRand antigen tests when the test is covered by Medicare, but their cost-sharing may change. Through the end of the COVID-19 PHE, Medicare covered and paid for over-the-counter (OTC) COVID-19 tests at no cost to people with Medicare Part B, including those with MA plans. The demonstration that allowed coverage and payment for OTCtests will ended when the PHEended on May 11th. Medicare Advantage plans may continue to cover the tests, so check with your plan for details.

Will t he w aiver of t he t hree-day hospit al st ay requirem ent prior t o a SNF st ay cont inue, or w ill it end w it h t he PHE?

Many flexibilities, including the waiver of the Medicare three-day qualifying hospital stay (QHS) requirement prior to a Medicare-covered SNFstay, are no longer be in effect for the Medicare fee-for-service program

For any Medicare Part A-covered SNFstay which begins on or prior to May 11, 2023, without a QHS, that stay can continue for as long as the beneficiary has Part A SNFbenefit days available and for as long as the beneficiary continues to meet the SNFlevel of care criteria (e g , requiring daily skilled care)

For any new Medicare Part A-covered SNFstay which begins after May 11, 2023, (including stays which experience a break in Part A coverage that exceeds three consecutive calendar days before resuming SNFcoverage), these stays will require a QHS. However, a doctor or other provider who is part of an Accountable Care Organization (ACO) may still be able to send their patients for a Medicare-covered SNFstay even if they have not stayed as an inpatient in a hospital for at least three consecutive days first.

For someone to qualify for this benefit, the doctor or other provider has to decide that SNF care is needed and certain other eligibility requirements are met. Additionally, MA plans may elect to furnish coverage of post-hospital SNFcare in the absence of the prior qualifying hospital stay as part of their Medicare-covered services. MA enrollees should check their Evidence of Coverage document for coverage requirements related to SNFcare

Aft er t he PHE, w hen can hospit als bill for:

1 The originat ing sit e facilit y fee (HCPCS code Q3014)?

2 The clinic visit (HCPCS code G0463)?

3. Rem ot e m ent al healt h services (HCPCS codes C7900 - C7902)?

Following the anticipated end of the PHE:

1 Hospitals cannot bill for this code after the PHEunless the beneficiary is located within a hospital and the beneficiary receives a Medicare telehealth service from an eligible distant site practitioner Only in these cases can the hospital would bill for the originating site facility fee (HCPCScode Q3014)

2 If the beneficiary is within a hospital and receives a hospital outpatient clinic visit (including a mental/behavioral health visit) from a practitioner in the same physical location, then the hospital would bill for the clinic visit (HCPCScode G0463)

3. If the beneficiary is in their home and receives a mental/behavioral health service from hospital staff through the use of telecommunications technology and no separate professional service can be billed, then the hospital would bill for the applicable HCPCS Ccode describing this service (HCPCScodes C7900 - C7902).

Aft er t he end of t he PHE, can hospit als bill for t he originat ing sit e facilit y fee (HCPCS code Q3014) w hen a beneficiary is not in t he hospit al but a hospit al-based out pat ient depart m ent physician furnishes a Medicare t elehealt h service and t he hospit al provides adm inist rat ive and clinical support ?

No Following the end of the PHE, hospitals will no longer be able to bill HCPCScode Q3014 to account for the resources associated with administrative support for a professional Medicare telehealth service.

Follow ing t he end of t he PHE, can hospit als bill for out pat ient physical/ occupat ional t herapy services provided t o beneficiaries in t heir hom es t hrough t elecom m unicat ion t echnology by hospit al em ployed physical t herapist s, occupat ional t herapist s, and speech language pat hologist s?

The waivers that currently allow for these flexibilities were under the CMSHospitals Without Walls Initiative expired at the end of the PHE.

During the PHE, under these waivers, a subset of counseling, therapy, and educational services have been eligible to be provided remotely by the hospital clinical staff, as long as they were are furnished to a patient in the hospital, which may have included the patient?s home, if the home was considered a provider-based department of to the hospital during the PHE.

In context of the anticipated end of the PHE, CMShas received a number of inquiries from interested parties regarding the expiration of this policy, including questions about whether policies other than the expiring waivers are relevant The questions are currently under review.

There are many more FAQs in the document You can download the complete 11-page document from CMSby clicking the icon below.

Click On The Document Below For An Important Notice

CorroHealt h invit es you t o check out t he m lnconnect s page available from t he Cent ers For Medicare and Medicaid (CMS). It 's chock full of new s and inform at ion, t raining opport unit ies, event s and m ore! Each w eek PARA w ill bring you t he lat est new s and links t o available resources. Click each link for t he PDF!

Thursday, May 24, 2023

New s

- DMEPOSCompetitive Bidding Program: Temporary Gap Period Starts January 1

- CMSRoundup (May 19, 2023)

- Medicare Providers: Deadlines for Joining an Accountable Care Organization

- ESRD-Related Services: Comparative Billing Report in May

Claim s, Pricers, & Codes

- COVID-19 Pfizer-BioNTech & Moderna Vaccines: Product & Administration Code Updates

MLN Mat t ers® Art icles

- Mental Health Visits via Telecommunications for Rural Health Clinics & Federally Qualified Health Centers ? Revised

Publicat ions

- Checking Medicare Claim Status

Mult im edia

- J0510?J0530 Pain Interview: Understanding How a Patient Communicates Pain Video

Inform at ion for Pat ient s

- States Are Restarting Medicaid & CHIPEligibility Reviews: Tell Your Patients to Prepare Now

t r ans mit t al s

Therew ereSEVEN new or revised Transmittalsreleased thisw eek.

To go to thefull Transmittal document simply click on thescreen shot or thelink.

TRANSMITTAL R11997MSP

TRANSMITTAL R12062CP

TRANSMITTAL R12060CP

TRANSMITTAL R12059CP

TRANSMITTAL R12056PI

1 m edl ear ns

Therew as1new or revised MedLearn released thisw eek.

To go to thefull Transmittal document simply click on thescreen shot or thelink.

Theprecedingmaterialsare for instructional purposesonly. Theinformation ispresented "as-is"and to thebest of CorroHealth'sknowledgeisaccurateat thetimeof distribution. However, due to the ever-changinglegal/regulatory landscape, thisinformation issubject to modification asstatutes, laws, regulations, and/or other updatesbecome available. Nothingherein constitutes, isintended to constitute, or should berelied on aslegal advice. CorroHealth expresslydisclaimsanyresponsibilityfor anydirect or consequential damagesrelated in anywayto anything contained in thematerials, which areprovided on an "as-is"basisand should beindependentlyverified before beingapplied. You expresslyaccept and agree to thisabsoluteand unqualified disclaimer of liability. The information in thisdocument isconfidential and proprietaryto CorroHealth and isintended onlyfor thenamed recipient. No part of thisdocument maybereproduced or distributed without expresspermission. Permission to reproduceor transmit in anyform or byanymeanselectronicor mechanical, includingpresenting, photocopying, recording, and broadcasting, or byanyinformation storageand retrieval system must beobtained in writingfrom CorroHealth. Request for permission should bedirected to Info@Corrohealth.com.