Weekly eJournal grayscale version from PARA HealthCare Analytics, an HFRI Company

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PARA

Healthcare Analytics

WeeklyeJOURNAL NEWS FOR HEALTHCARE DECISION MAKERS

July 31, 2019

Durable Medical Equipment

IN THIS ISSUE

Wh ich NPI To Use?

QUESTIONS & ANSWERS - DME Billing NPI - Split/Shared EM For Inpatient - Albumin Without Paracentesis - Admit Source F And Discharge Status 9

OPPS and ASC Proposed Payment Rule Page 9

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2020 Physician Fee Schedule Proposed Rule Changes

BREAKING NEWS: NEW FEE SCHEDULE AND PAYMENT SCHEDULE PROPOSALS

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CODING ONE VACCINE OR MULTIPLE WITHIN THE SAME ENCOUNTER CCI EDIT COLUMN 1/COLUMN 2 MODIFIER

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The number of new or revised Med Learn articles released this week.

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The number of new or revised Transmittals released this week.

ACUPUNCTURE FOR LOW BACK PAIN HFRI WEBINAR: INTELLIGENT AUTOMATION TO IMPROVE CASH FLOW CALIFORNIA UPDATE: VACCINE CONSENT RURAL HOSPITAL PROGRAM GRANTS

CMS Proposes Covering Treat ment For Chronic Low Back Pain

PARA COMPANY NEWS

SERVICES

ABOUT PARA

CONTACT US

FAST LINKS

Acupunct ure

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Administration: Pages 1-36 HIM /Coding Staff: Pages 1-36 Providers: Pages 3,5,9,15,16,26 Inpatient Care: Page 3 Obstetrics: Page 5 Admitting Depts.: Page 6 Pharmacy: Pages 15,19

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Provider Offices: Page 16 Pain M anagement: Page 20 Staff Education: Page 22 California Providers: Page 23 Laboratory.: Page 25 Rural HealthCare: Page 27 Imaging: Page 32

© PARA Healt h Car e An alyt ics an HFRI Company CPT® is a r egist er ed t r adem ar k of t h e Am er ican M edical Associat ion


PARA Weekly eJournal: July 31, 2019

DME BILLING NPI

Would it make a difference if we bill for Durable Medical Equipment (DME) or supplies using the hospital's NPI, versus the DME Store NPI? The NPIs are different, but we bill with the same tax ID number. The DME Store is in the Hospital level. Do you see any problem if we use one over the other? Answer: Medicare requires that a DME provider be enrolled; the provider enrollment is accomplished at the NPI level. Therefore, if claiming reimbursement for DME which is not provided in association with a hospital service, and/or is not a prosthetic or orthotic, the claim must be submitted to the Medicare DME MAC under the NPI of the enrolled supplier. Hospitals may claim reimbursement for prosthetic or orthotic (PO) DME provided in conjunction with other medical services, for example, an orthotic wrist splint (L3908) provided at an emergency room visit to stabilize a sprain may be reported on a hospital claim to the regular A/B MAC without separate enrollment as a DME supplier. If the DME item is not a prosthetic/orthotic item, or if it is provided in the absence of other medically necessary facility services, the DME must be billed to the DME MAC by an enrolled DME supplier. Attached is our paper on billing DME.

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PARA Weekly eJournal: July 31, 2019

SPLIT/SHARED EM FOR INPATIENT

Can we bill two E/Ms for same date of service (same specialty and NP) if there is a direct admit from clinic with same diagnosis. E/M- H&P done by Nurse Practitioner and E/M by overseeing MD. Example- Sally NP does H&P on patient being admitted from clinic, Jody MD is the overseeing MD for the NP (Jody is physically going into patient's room to see patient). Is it true that whoever does the H&P gets the credit? Answer: We presume that your reference to the ?credit? for the service refers to a productivity measure used for calculating employed provider compensation; we can?t speak to the organization?s internal compensation policies. However, we can address how to report these services appropriately on professional fee claims submitted for payer reimbursement. Attached is a paper which explains how to report a second EM if two physicians are involved in the care of the same inpatient. This differs in that the arrangement described in the question may be described as a ?Split/Shared EM Service?, which is addressed in the Medicare Claims Processing Manual; here?s a link and the pertinent excerpt: https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/clm104c12.pdf Medicare Claims Processing Manual, Chapter 12 - Physicians/Nonphysician Practitioners 30.6.1 - Selection of Level of Evaluation and Management Service (Rev. 3315, Issued: 08-06-15, Effective: 01-01-16, Implementation: 01-04-16) SPLIT/SHARED E/M SERVICE ? Hospital Inpatient/Outpatient (On Campus or Off Campus)/Emergency Department Setting When a hospital inpatient/hospital outpatient (on campus-outpatient hospital or off campus outpatient hospital) or emergency department E/M is shared between a physician and an NPP from the same group practice and the physician provides any face-to-face portion of the E/M encounter with the patient, the service may be billed under either the physician's or the NPP's UPIN/PIN number. However, if there was no face-to-face encounter between the patient and the physician (e.g., even if the physician participated in the service by only reviewing the patient?s medical record) then the service may only be billed under the NPP's UPIN/PIN. Payment will be made at the appropriate physician fee schedule rate based on the UPIN/PIN entered on the claim.

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PARA Weekly eJournal: July 31, 2019

SPLIT/SHARED EM FOR INPATIENT

EXAMPLES OF SHARED VISITS: 1. If the NPP sees a hospital inpatient in the morning and the physician follows with a later face-to-face visit with the patient on the same day, the physician or the NPP may report the service. 2. In an office setting the NPP performs a portion of an E/M encounter and the physician completes the E/M service. If the "incident to" requirements are met, the physician reports the service. If the ?incident to? requirements are not met, the service must be reported using the NPP?s UPIN/PIN. In the rare circumstance when a physician (or NPP) provides a service that does not reflect a CPT速 code description, the service must be reported as an unlisted service with CPT速 code 99499. A description of the service provided must accompany the claim. The MAC has the discretion to value the service when the service does not meet the full terms of a CPT速 code description (e.g., only a history is performed). The MAC also determines the payment based on the applicable percentage of the physician fee schedule depending on whether the claim is paid at the physician rate or the non-physician practitioner rate. CPT速 modifier -52 (reduced services) must not be used with an evaluation and management service. Medicare does not recognize modifier -52 for this purpose. To summarize, if both the physician and the nurse practitioner are billed by the same medical group, and each performed face-to-face EM services for the same patient on the same day, the organization may combine the documentation from both services to establish the E/M level, and bill under the physician?s NPI for maximum reimbursement. Reimbursement for nurse practitioners is paid at a reduced rate by most payers

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PARA Weekly eJournal: July 31, 2019

ALBUMIN WITHOUT PARACENTESIS

Is it appropriate to bill infusion of albumin without paracentesis? In a recent case I uploaded documentation, but there was no procedure (paracentesis) done because the ultrasound demonstrated no ascites. We uploaded the ultrasound report that states that paracentesis was not performed, but albumin was administered to patient. How can we bill for this? An infusion of albumin is commonly, but not exclusively, performed with paracentesis. It is appropriate to report it as an independent service without paracentesis. According to the Physician?s Desk Reference https://www.pdr.net/drug-summary/Albutein-25--albumin--human--2222, albumin is a low-molecular-weight protein; it maintains intravascular oncotic pressure; it is responsible for transport of bilirubin, calcium, and many drugs; and it is indicated for urgent restoration of blood volume. Albumin is used to treat: - shock due to hypovolemia - severe burns - nephrosis in nephrotic syndrome - hypoproteinemia, and - adjunctive use with exchange transfusion in the treatment of hyperbilirubinemia and erythroblastosis etalis (hemolytic disease of the newborn). Albumin is administered as a therapeutic infusion, not as a transfusion, therefore the administration code is 96365 for an initial infusion up to one hour.

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PARA Weekly eJournal: July 31, 2019

ADMIT SOURCE F AND DISCHARGE STATUS 9

We are wanting to find clarification on the following: Admission Source & Discharge Status Codes -- Two changes will go into effect with eligibility processing for discharges that occur on or after October 1, 2019. - Admission Source: ?F ? Transfer from Hospice Facility? will be handled as a valid HCAHPS-eligible code. - Discharge Status: ?9 ? Admitted as an Inpatient to this Hospital? will be handled as a valid HCAHPS-eligible code. Do you have the information re: specifics on when to utilize this code? That is, does it have to be when we received a patient from an inpatient hospice? We don?t have many in our area. But if they just have to be in a MCR certified Hospice (as an outpatient) then we would utilize it more. Can you please clarify? Answer: The billing codes referenced are not new. The change you?ve identified is that patients whose hospital services were billed using these source and discharge codes should be included in the population of patients that are surveyed using the Hospital Consumer Assessment of Healthcare Providers and Systems program (HCAHPS). HCAHPS is a program under which hospitals collect surveys from patients regarding their experience during the hospital stay; the data from the surveys is then compiled for public reporting, and is used as a component of Medicare?s Value-Based Purchasing reimbursement incentive program. According the UB Committee, Source of Admission code F ?Transfer from Hospice Facility? should be reported if an inpatient is admitted to the hospital as a transfer from a hospice facility. We presume that if the transferred inpatient is not from a hospice facility, but a home hospice program, this code would not be appropriate. Discharge status 9 ?Admitted as an Inpatient to this Hospital? is for use on Medicare outpatient claims only. It applies only to Medicare outpatient services that begin greater than three days prior to admission ? in other words, this code would be used on charges that were incurred prior to the 72-hour rule. If a patient is admitted before midnight of the third day following the day of an outpatient diagnostic service or service related to the reason for admission, the outpatient services are bundled into the inpatient claim for Medicare. If outpatient services began prior to that 3-day window, the services could be reported on an outpatient bill type with discharge code 09. In my experience, this is not common. Here?s a link to more information about the HCAHPS program. https://www.cms.gov/ medicare/quality-initiatives -patient-assessment -instruments/ hospitalqualityinits/ hospitalhcahps.html

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PARA Weekly eJournal: July 31, 2019

ADMIT SOURCE F AND DISCHARGE STATUS 9

The details of patient services which should be included in surveys are found in the CAHPS Hospital Survey Quality Assurance Guidelines at the following link: https://hcahpsonline.org/globalassets/hcahps/quality-assurance/2019_qag_v14.0.pdf

Here?s an excerpt from a document which lists the changes between the prior version of the guidelines (13.0) and the new version that comes into effect 10/1/19: https://hcahpsonline.org/globalassets/ hcahps/quality-assurance/change -matrix-hcahps-qag-v14.0.pdf

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PARA Weekly eJournal: July 31, 2019

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PARA Weekly eJournal: July 31, 2019

PROPOSED 2020 OPPS AND ASC PROPOSED RULE: JUST RELEASED

On July 29, 2019, the Centers for Medicare (CMS) released the CY2020 proposed rule for review. The proposed policies are further advancing price transparency and encouraging site-neutral payment between certain Medicare sites of services. This article is only a summary. The fact sheet related to this article can be reached at the following link https://www.cms.gov/newsroom/fact-sheets/cy-2020-medicare-hospital-outpatient -prospective-payment-system-and-ambulatory-surgical-center

The full proposed rule is available for review on the CMS website. PARA has provided a link to the document on the PDE Advisory tab.

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PARA Weekly eJournal: July 31, 2019

PROPOSED 2020 OPPS AND ASC PROPOSED RULE: JUST RELEASED

Key points within the proposal: 1. Increasing Price Transparency of Hospital Standard Charges: In follow-up to a Presidential Executive Order on Improving Price and Quality Transparency in America, the proposed rule is seeking to implement Section 2719? of the Public Health Service Act. This will improve on prior agency guidance that required hospitals to make public their standard charges. There are four components targeted in the rule pertaining to this key point: - Definitions of ?hospital?, standard charges, and items and services - Requirements for making public a machine-readable file online that includes all standard charges for all hospital items and services - Requirements for making public payer-specific negotiated charges for a limited set of ?shoppable? services that are displayed and packaged in a consumer-friendly manner - Monitoring for hospital non-compliance and actions to address hospital non-compliance (including issuing a warning notice, requesting a corrective action plan and imposing civil monetary penalties) and a process for hospitals to appeal these penalties 2. Increasing Choices and Encouraging Site Neutrality: Within this rule, there are a number of policies that reduce payment differences between outpatient sites of service so patients can benefit from high-quality care at lower costs. There are five (5) components targeted in the rule pertaining to this key point: -

Method to control for un-necessary increases in utilization of Outpatient Services ? In following up with the Final Rule implantation regarding payments for clinic visits rendered in an off-campus setting, CMS is proposing changes that will result in lower co-payments for beneficiaries and savings for Medicare programs and taxpayers is estimated to be $810 million for CY2020

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Example given by CMS in proposed rule: ?for a clinic visit furnished in an excepted off-campus provider-based department, average beneficiary cost sharing is currently $16.00 in CY2019, but would be $23.00 absent this policy. With the completion of the two (2) year phase-in, that cost-sharing would reduce to $9.00, saving beneficiaries an average of $14.00 each time they visit an off-campus department for a clinic visit in CY2020

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Changes to the Inpatient-Only List ? CMS is proposing to remove Total Hip Arthroplasty from the Addendum C listing (Inpatient Only Listing). This would make the procedure reimbursable by Medicare in both the hospital inpatient and outpatient setting. A component of this change would include an additional one (1) year exemption from medical review activities for procedures removed from the IOP listing

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ASC Covered Procedures List ? For CY2020, CMS is seeking to add Total Knee Arthroplasty (TKA), Knee Mosaicplasty and 3 additional coronary intervention procedures to the ASC CPL. CMS is currently seeking comments on any additional limitations on the provision of TKA or other procedures in an ASC setting. High-Cost/Low-Cost Threshold for Packaged Skin Substitutes ? CMS is proposing to continue assigning skin substitutes to low-cost or high-cost group under the established policy of CY2018. CMS is seeking comments on ideas on how to improve the current 10


PARA Weekly eJournal: July 31, 2019

PROPOSED 2020 OPPS AND ASC PROPOSED RULE: JUST RELEASED

- ¡ Device Pass-through Applications ? There were seven (7) applications reviewed by CMS for this proposed rule. Currently, there are no proposals to approve or deny, CMS is soliciting comments prior to making final determinations on the applications in the Final Rule. CMS is seeking public comment which is targeted to ensuring beneficiaries timely access to new therapies, removing access obstacles 3. Rethinking Rural Health: There are two components targeted in this proposed rule pertaining to this key point: - Addressing Wage Index Disparities ? For CY 2020 CMS is proposing to use the FY2020 hospital Inpatient Prospective Payment System (IPPS) post-reclassified wage index for urban and rural areas as the wage index for OPPS to determine the wage adjustments for both the OPPS payment rate and the co-payment standardized amount. This change would be implemented as of January 01, 2020 - Changes in the Level of Supervision of Outpatient Therapeutic Services in Hospital and Critical Access Hospitals (CAH) ? In this proposal, CMS is attempting to align the standard minimum level of supervision for each hospital service furnished incident to a physician service 4. Unleashing Innovation: CMS is proposing an alternative pathway to qualifying for device-pass-through payment status, for which the substantial clinical improvement criteria would not apply. 5. Protecting Taxpayer Dollars: CMS is proposing to initiate a prior authorization requirement for the following services, which are commonly cosmetic and are only billed when medically necessary: - Blepharoplasty - Botulinum-Toxin Injections - Panniculectomy - Rhinoplasty - Vein Ablations 6. Meaningful Measures/Patients Over Paperwork: CMS is seeking comment on utilizing a set of patient safety measures for both programs: - Hospital Outpatient Quality Reporting (OQR) Program - Ambulatory Surgical Center Quality Reporting (ASCQR) Program 7. CY2020 OPPS Payment Methodology for 340B Purchased Drugs: For CY2020, CMS is proposing to reimburse at the current adjusted amount of the ASP, minus 22.5% for certain separately payable drugs or biologicals that are acquired through the 340B program.

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PARA Weekly eJournal: July 31, 2019

PROPOSED 2020 OPPS AND ASC PROPOSED RULE: JUST RELEASED

8. Proposed Updates to OPPS Payment Rates: CMS is proposing to update OPPS payment rates by 2.7%. This increase is based on the projected hospital market basket increase to 3.2% minus a 0.5% point adjust for multi-factor productivity (MFP). In addition, CMS is proposing to increase rates for: - Partial Hospitalization Program (PHP) Rate Setting - PHP Per Diem Rates 9. Proposed Updates to ASC Payment Rates: To promote site-neutrality between hospitals and ASCs, as well at encourage the migration of services from the hospital setting to the lower cost ASC, CMS is proposing to update ASC rates for CY2020 by 2.7% for meeting quality reporting requirements. 10. Revision to the Organ Procurement Organization Conditions for Certification: Under the current requirements OPOs are required to meet two out of three outcome measures. CMS is seeking to clarify the regulatory standard in place to enable proper enforcement of the second outcome measure, eliminate provider confusion, and to further support goals related to accurately measuring OPO performance 11. Potential Changes to the Organ Procurement Organization and Transplant Center Regulations: Request for Information: In this proposal, CMS is seeking public comment and assistance in making updates to the OPO Conditions of Coverage (CfCs), in addition to updating the Conditions of Participation (CoPs) for transplant centers.

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PARA Weekly eJournal: July 31, 2019

CMS RELEASES 2020 PHYSICAN FEE SCHEDULE PROPOSED RULE

On July 29, 2019, Medicare released the 2020 Medicare Physician Fee Schedule Proposed Rule. The fact sheet relating the changes to the rule is available at the following link: https://www.cms.gov/newsroom/fact-sheets/ proposed-policy -payment-and-quality-provisions-changes-medicarephysician-fee-schedule-calendar-year-2 The full proposed rule is available for review on the Medicare website. A link is provided on the PARA Data Editor Advisor tab.

Enter the year 2020 in the Summary field:

Key proposals concerning physician reimbursement are summarized below (this is not an all-inclusive list): - Set the CY 2020 PFS conversion factor at $36.09, a slight increase above the CY 2019 rate of $36.04 -

Align with changes laid out by the CPTÂŽ Editorial Panel for office/outpatient E/M visits which: - Retain 5 levels of coding for established patient office/outpatient EM visits, and - Reduce the number of levels to 4 for new patient office/outpatient E/M visits, and - Revise the code definitions in regard to the times and medical decision-making process for all of the codes, and to require performance of history and exam only as medically appropriate

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Provide a Medicare-specific add-on code for office/outpatient E/M visits for primary care and non-procedural specialty care into a single code describing the work associated with visits that are part of ongoing, comprehensive primary care and/or visits that are part of ongoing care related to a patient?s single, serious, or complex chronic condition. 13


PARA Weekly eJournal: July 31, 2019

CMS RELEASES 2020 PHYSICAN FEE SCHEDULE PROPOSED RULE

- Allow PAs greater flexibility to practice more broadly in the current health care system in accordance with state law and state scope of practice; in the absence of State law governing physician supervision of PA services, the physician supervision required by Medicare for PA services would be evidenced by documentation in the medical record of the PA?s approach to working with physicians in furnishing their services - Make broad modifications to the documentation policy so that physicians, physician assistants, nurse practitioners, clinical nurse specialists, and certified nurse-midwives could review and verify (sign and date), rather than re-documenting, notes made in the medical record by other physicians, residents, nurses, students, or other members of the medical team - Increase payment for Transitional Care Management (TCM), which is a care management service provided to beneficiaries after discharge from an inpatient stay or certain outpatient stays - Provide a set of Medicare-developed HCPCS G-codes for certain Chronic Care Management (CCM) services. CCM is a service for providing care coordination and management services to beneficiaries with multiple chronic conditions over a calendar month service period - Create new coding for Principal Care Management (PCM) services, which would pay clinicians for providing care management for patients with a single serious and high risk condition - Implement a new Medicare Part B benefit for opioid use disorder treatment programs, including enrollment, bundled payment methodology for full and partial weeks, service delivery via two-way interactive video communication, and zero beneficiary copays for a limited duration - Require the CO and CQ modifiers to identify services rendered by PT and OT Assistants

This paper serves as a summary of key provisions that will be of wide interest; it is not a complete list of all changes. Please refer to the full Medicare document for more complete information. Comments on the proposed rule will be accepted until 5 p.m. on September 27, 2019; the final rule is typically announced in October of each year.

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PARA Weekly eJournal: July 31, 2019

CODING ONE VACCINE OR MULTIPLE WITHIN THE SAME ENCOUNTER

hen it comes to reporting vaccines provided in an outpatient setting, the coding can be complicated. Frequently, patients require more than one (1) vaccine during a single encounter, and selecting the correct vaccine code is not always enough to ensure full reimbursement for the services rendered. There are several factors involving vaccines that need to be considered: - Patient age - Insurance - Route of Administration - Total number of vaccines given in the same encounter - Physician counseling - State vaccines program Vaccine codes are published on a semi-annual basis, normally July 01 and January 01 by the American Medical Association (AMA). In coding a vaccine for claims, the ranges are 90476 through 90749. In recent years, Medicare has created additional Q-codes to be utilized. These codes are reimbursed at reasonable costs to providers. Medicare deductible and co-insurance amounts do not apply when reporting these codes to Medicare. - Q2034 ? Agriflu - Q2035 ? Afluria - Q2036 ? FluLaval - Q2037 ? Fluvirin - Q2038 ? Fluzone - Q2039 ? Influenza product, unspecified - Providers use G0008 Administration of influenza virus vaccine when reporting Q-codes Age-restricted vaccines Certain vaccines have specific age requirements while others are unspecified (pediatric, adolescent or adult). When coding, providers need to ensure the vaccine administered to the patient meets appropriate age requirements and do not contradict one another. Age specific vaccines are identified at the conclusion of this article. Vaccines are normally reported with appropriate diagnosis code Z23 ? Encounter for immunization. Administration of code sets In most vaccine billing scenarios, practices will bill separately for the vaccine and the vaccine administration. These are represented on 2 separate claim lines. Vaccine administration codes are broken down into three (3) different categories: - CPTÂŽ range 90471 ? 90474 identify vaccines without Counseling - CPTÂŽ range 90460 ? 90461 identify vaccines with Counseling - HCPCS Codes G0008, G0009 and G0010 are specific to Medicare Beneficiaries Some practices participate in their State's Vaccines for Children (VFC) program in which the practice is provided with vaccines directly from the State. In this scenario, physicians may not charge the beneficiaries for the vaccines and physicians are not separately reimbursed by Medicaid or commercial carriers.

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PARA Weekly eJournal: July 31, 2019

CODING ONE VACCINE OR MULTIPLE WITHIN THE SAME ENCOUNTER

However, providers may charge patients for the administration fee associated with providing the vaccine. For vaccines provided as part of the VFC program, the CPTÂŽ code range is 90476 ? 90749 with modifier SL appended in the first reporting modifier field. Route of administration For coders, knowing the route of administration confirms the appropriate administration code. Most vaccines are given as injections and are reported using administration codes 90471 and 90472. There are however, a few oral and intra-nasal vaccines that are reported using administration codes 90473 and 90474. Initial Vaccines If one or more vaccines are performed during an encounter, specify an initial administration code first. The initial administration codes are: - 90471 ? Immunization administration for percutaneous, intra-dermal, subcutaneous or intramuscular injections, initial - 90473 ? Immunization administration for intranasal or oral route, initial There is only one initial administration code reported per encounter. When both injectable and oral/intranasal vaccines are performed during the same visit, providers should report 90471 as the initial administration code. Codes 90471 ? 90472 have a slightly higher reimbursement than oral/intranasal administration. Subsequent vaccines If more than one vaccine is administered on the same day, a second or third administration fee is required to document the additional vaccines. All subsequent vaccine codes (90472 and 90474) are classified as add-on codes and must be reported with an initial administration code. The definitions for subsequent administration codes are: - 90472 ? Immunization administration for percutaneous, intra-dermal, subcutaneous or intramuscular injections, each additional vaccine - 90474 ? Immunization administration for intranasal or oral route, each additional vaccine When there are three or more vaccines performed during an encounter, apply units to the subsequent administration code for each additional vaccine of the same type (injectable or oral). Examples: - 5 injectable vaccines: report 90471 X 1 unit (initial) and 90472 X 4 units (subsequent) - 1 Intranasal and 2 Oral vaccines: 90473 X 1 unit (initial) and 90474 X 2 units (subsequent) - 4 Injectable vaccines and 1 Oral vaccine: 90471 X 1 unit (initial) and 90472 X 3 units (subsequent) and 90474 X 1 unit (subsequent)

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PARA Weekly eJournal: July 31, 2019

CODING ONE VACCINE OR MULTIPLE WITHIN THE SAME ENCOUNTER

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PARA Weekly eJournal: July 31, 2019

CODING ONE VACCINE OR MULTIPLE WITHIN THE SAME ENCOUNTER

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PARA Weekly eJournal: July 31, 2019

CCI EDIT COLUMN 1/COLUMN 2 MODIFIER CHANGE

CMS issued a transmittal on February 15, 2019 which changes the requirement that a modifier be appended to the Column 2 code on Procedure-to-Procedure (PTP) Correct Coding Initiative (CCI) edits. Effective July 1, 2019, modifier (59, XU, XE, XP, or XS) may be appended (if appropriate) to either the column 1 or the column 2 code to resolve a PTP CCI edit. A link and an excerpt are provided: https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/ Downloads/MM11168.pdf

The PARA Data Editor Calculator tab offers a CCI lookup which identifies which code is a column 1 and which is a column 2 code in a PTP CCI edit:

Up until July 1, 2019, modifiers must be appended to only the column 2 code in a PTP edit to indicate that both procedures are eligible for reimbursement. 19


PARA Weekly eJournal: July 31, 2019

CMS PROPOSES COVERING ACUPUNCTURE TREATMENT FOR BACK PAIN

On Ju ly 15, 2019 CM S pr oposed cover age of acu pu n ct u r e f or M edicar e ben ef iciar ies en r olled as par t icipan t s in Nat ion al In st it u t es of Healt h (NIH) or CM S-appr oved clin ical t r ials f or ch r on ic low back pain . Medicare will be seeking evidence from the studies that acupuncture is an effective alternative to highly addictive opioid painkillers. https://www.cms.gov/newsroom/press-releases/ cms-proposes-cover-acupuncture-chronic -lowback-pain-medicare-beneficiaries -enrolled-approved CMS will require the studies to provide a minimum of 12 weeks treatment and document research answering the questions: 1) is acupuncture either reducing pain or increasing function for the patient? or 2) has there been a reduction of other services/treatments (e.g. opioids) for the patient?

https://www.cms.gov/medicare -coverage-database/ details/nca-proposeddecisionmemo.aspx?NCAId=295

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PARA Weekly eJournal: July 31, 2019

CMS PROPOSES COVERING ACUPUNCTURE TREATMENT FOR LOW BACK

Acupuncture, a traditional Chinese treatment where tiny needles are inserted into specific points of the body, has grown as an alternative treatment for not only reducing pain, but for improving other health conditions including depression, anxiety, and high blood pressure with little to no side effects. The treatment continues to be criticized because of conflicting and inconsistent results among patients. Medicare currently does not cover acupuncture procedures. PARA clients can review acupuncture codes in the calculator tab of the PARA Data Editor.

CMS acknowledges that there are questions regarding the effectiveness of acupuncture but providing options to patients with chronic pain is essential for tackling the opioid epidemic. The comment period for this proposal will remain open until August 14, 2019.

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PARA Weekly eJournal: July 31, 2019

HFRI WEBINAR: EFFECTS OF INTELLIGENT AUTOMATION ON CASH FLOW

Robotic process automation and Intelligent Automation (IA) can help hospitals reverse negative reimbursement trends and improve accounts receivable processes. Experts from Healthcare Financial Resources (HFRI) explained how in a March 5, 2019 webinar hosted by Becker's Hospital Review.

WATCH THE Webinar

Presenters

And register for a new, upcoming webinar by clicking the icon below.

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PARA Weekly eJournal: July 31, 2019

IMMUNIZATION AND VACCINE CONSENT INFORMATION FOR MINORS

California Update Currently, there are no Federal or State of California requirements for informed consent specifically related to general Immunization or Vaccine administration. There is, however, specific consent verbiage related to general medical care that healthcare providers must abide by. According to the Basic Principles of Consent, produced by the California Hospital Association, the Patient?s Right to Consent to, or Refuse Medical Treatment is stated as follows: The full text of the Minors and Health Care Law handbook can be found at the following link: https://www.calhospital.org/sites/ main/files/file-attachments/minors2017 _webpreview.pdf In 2012, California Law AB-499 was enacted to expand the legal authority of minors 12 years and older to consent to confidential medical services for the prevention of sexually transmitted diseases (STDs) without their parents? consent.

This law permits adolescents age 12 through 17 years to consent to the following: - Hepatitis B vaccination - Human papillomavirus (HPV) vaccination - HIV pre- and post- exposure medications - Additional STD prevention services that may become available in the future A full Frequently Asked Questions document regarding AB-499 can be found at the following link: http://www.immunizeca.org/wp-content/uploads/2011/06/AB_499_FAQ.pdf

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PARA Weekly eJournal: July 31, 2019

IMMUNIZATION AND VACCINE CONSENT INFORMATION FOR MINORS

A full Frequently Asked Questions (FAQ) document regarding AB-499 can be found at the following link:

http://www.immunizeca.org/wp-content/uploads/2011/06/AB_499_FAQ.pdf AB-499 does not exempt a medical provider from obtaining consent for all other vaccines from a parent or legal guardian. Federal law requires that healthcare staff provide a Vaccine Information Statement (VIS) to patients, a parent or legal representative before vaccine administration for all vaccines (those that fall under AB-499 protections included) and the following information needs to be documented in the Patients Medical Record: - Date the VIS is provided - Date the vaccine is administered - Name, office address, and title of the person who administers the vaccine - Vaccine manufacturer and lot number. Vaccines that are provided under the Vaccines for Children initiative are subjected to the same general consent rules and regulations for both general immunizations and vaccines and those that fall under the protected categories of AB-499. Specific information pertaining to the Vaccines for Children initiative can be found at the following link: https://www.cdc.gov/vaccines/programs/vfc/about/index.html

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PARA Weekly eJournal: July 31, 2019

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 for the PDF!

Thursday, July 25, 2019 New s

· New Medicare Card: Questions about Using the MBI? · 2020 QRDA III Implementation Guide, Schematron, and Sample Files · Antipsychotic Drug Use in Nursing Homes: Trend Update · Clinical Diagnostic Laboratories: Resources about the Private Payor Rate-Based CLFS · Medicare Diabetes Prevention Program: Become a Medicare Enrolled Supplier · World Hepatitis Day: Medicare Coverage for Viral Hepatitis Com plian ce

· Importance of Proper Documentation: Provider Minute Video Claim s, Pr icer s & Codes

· Medicare Diabetes Prevention Program: Valid Claims M LN M at t er s® Ar t icles

· Medicare Plans to Modernize Payment Grouping and Code Editor Software Pu blicat ion s

· Medicare DMEPOS Improper Inpatient Payments · Medicare Part D Vaccines ? Revised · Provider Compliance Tips for Enteral Nutrition Pumps ? Revised M u lt im edia

· Hospital Listening Session: Audio Recording and Transcript · Hospice Quality Reporting Program Web-Based Courses 25


PARA Weekly eJournal: July 31, 2019

WEEKLY IT UPDATE

PARA HealthCare Analytics has provided a list of enhancements and updates that our Information Technology (IT) team has made to the PARA Data Editor this past week. The following tables includes which version of the PDE was updated, the location within the PDE, and a description of the enhancement.

Week ly IT Updat e

T his Week 's Updates

Prev ious Updates

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PARA Weekly eJournal: July 31, 2019

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. Tribal Opioid Response Grants Provides up to $50,000 to develop a strategic plan to address opioid addiction in tribal nations. Application Deadline: August 6, 2019

Service Area Competition Funding For Health Center Programs Multi-year funding of up to $1.3 million dollars to provide comprehensive primary healthcare services to an underserved area or population. Areas with a March 1, 2020 project period start date are eligible to apply. Application Deadline: August 26, 2019

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PARA Weekly eJournal: July 31, 2019

There were TWO new or revised Med Learn (MLN Matters) article 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

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2


PARA Weekly eJournal: July 31, 2019

The link to this Med Learn MM11268

29


PARA Weekly eJournal: July 31, 2019

The link to this Med Learn MM11273

30


PARA Weekly eJournal: July 31, 2019

There were FOUR 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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4


PARA Weekly eJournal: July 31, 2019

The link to this Transmittal R2323OTN

32


PARA Weekly eJournal: July 31, 2019

The link to this Transmittal R2324OTN

33


PARA Weekly eJournal: July 31, 2019

The link to this Transmittal R2325OTN

34


PARA Weekly eJournal: July 31, 2019

The link to this Transmittal R4339CP

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PARA Weekly eJournal: July 31, 2019

Con t act Ou r Team

Peter Ripper

M onica Lelevich

Randi Brantner

President

Director Audit Services

Director Financial Analytics

m lelevich@para-hcfs.com

rbrantner@para-hcfs.com

pripper@para-hcfs.com

Violet Archuleta-Chiu Senior Account Executive

Sandra LaPlace

Steve M aldonado

Account Executive

Director Marketing

slaplace@para-hcfs.com

smaldonado@para-hcfs.com

varchuleta@para-hcfs.com

In t r odu cin g, ou r n ew par t n er .

Nikki Graves

Sonya Sestili

Deann M ay

Senior Revenue Cycle Consultant

Chargemaster Client Manager

hClaim f r i.n et Review

ngraves@para-hcfs.com

ssestili@para-hcfs.com

dmay@para-hcfs.com

Specialist

M ary M cDonnell

Patti Lew is

Director, PDE Training & Development

Director Business Operations

mmcdonnell@para-hcfs.com

plewis@para-hcfs.com

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