PARA HealthCare Analytics Weekly eJournal March 4, 2020 by CorroHealth

M arch 4, 2020

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WeeklyeJOURNAL NEWS FOR HEALTHCARE DECISION MAKERS

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LCSW TeleM edicin e Wellness Coach Repeat Colon oscopy Transforming Bad Debt Into Revenue M LNCon n ect s New slet t er For Febr u ar y 27, 2020 Locum Tenens And Reciprocal Billing Key Oppor t u n it ies For Hospit als To Boost M ar gin s Billing Device-Intensive HCPCS Without A Device

Administration: Pages 1-49 HIM /Coding Staff: Pages 1-49 Providers: Pages 5,8,12,16,32 Telemedicine: Page 2 Cardiac Rehab: Page 5 Outpatient Svcs: Pages 8,32

Cr it ical Updat es For U.S. Cor on avir u s Codin g -

Nuclear M edicine: Page 9 Finance: Pages 20,25,35,42 M edical Offices: Pages 20,42 PDE Users: Page 36 Compliance: Page 37 Infectious Diseases: Page 16

PARA Weekly eJournal: March 4, 2020

LCSW TELEMEDICINE

How do we bill for LCSWs providing therapy services at our Hospital Counseling Center via telemedicine? The Therapist would be licensed in the state of IN but living in another state. Patients would come into our Counseling Center to be seen but the provider would be in another state. Are these services billable? And reimbursable? We have an LCSW that is moving out of state. We have 100 people wanting new therapy appointments a month. We are out of space at ourCounseling Center. We have to start thinking outside of the box. Somebody providing therapy from afar does help with my space limitations. Answer: First of all, we presume that the clinic has the telemedicine equipment available to serve as the originating site (patient end.) LCSWs are allowed to perform services via telemedicine, according to the CMS Telemedicine publication for 2020. So long as the LCSW is licensed in your state, and is not outside of the USA, s/he may perform services via telemedicine. Here?s an excerpt from the CMS publication linked in this article. https://www.cms.gov/Outreach-and-Education/MedicareLearning-Network-MLN/MLNProducts/Downloads/ TelehealthSrvcsfctsht.pdf The list of services which an LCSW may perform via telemedicine is limited to 1) those services Medicare permits to be performed via telemedicine, and 2) the scope of services allowed by the state laws applicable to LCSWs. The full list of codes which Medicare permits via telemedicine is attached; below I have listed the services that may be within the LCSW?s scope (note that the Medicare reimbursement rates displayed are for a physician, however):

PARA Weekly eJournal: March 4, 2020

LCSW TELEMEDICINE

To be able to bill for LCSW services via telemedicine, the organization must first enroll the LCSW with Medicare (and other payors, i.e. Medicaid and commercial payors) under the medical group NPI that it currently uses for billing other professional fees. Once enrolled, the LCSW?s telehealth services are billed on a 1500/837p claim form with Place of Service 02 (telehealth.) For Medicare, the rate of reimbursement will be 80% of the rate an LCSW would receive if performing the services in person. It is important to report the accurate place of service on the professional fee claim, as Medicare will pay according to the locality where the provider is, not where the patient is. On the paper CMS1500 claim form, the location of the LCSW must be entered in box 32 ? here?s a snapshot of the bottom of a CMS1500 form:

PARA Weekly eJournal: March 4, 2020

LCSW TELEMEDICINE

We should also mention that the originating location (your clinic where the patient is located) would bill Q3014 for the originating site fee; currently, the rate of reimbursement for Q3014 is $26.65. Medicare offers additional information on telemedicine at the link below. You?ll need to scroll down about half way to find the section snipped below: https://www.cms.gov/outreach-and-educationoutreachffsprovpartprogprovider-partnershipemail-archive/2020-02-20#_Toc32923427

Finally, if the telemedicine service location is part of the hospital organization, then the hospital medical staff should ?credential? all providers performing telemedicine services. The organization is responsible for ensuring that the credentials and background of the provider meet the organization?s requirements.

PARA Weekly eJournal: March 4, 2020

WELLNESS COACH

This follows up on your questions about whether it was compliant for a board certified wellness coach to provide some of the program care within the cardiac rehab and pulmonary rehab programs at the hospital, and whether the time spent by the wellness coach in rendering that care would support billing the cardiac rehab codes 93797 and 93798, or pulmonary rehab code G0424:

Answer: Medicare?s original National Decision Memo on cardiac rehab programs offers the following guidance on staff:

https://www.cms.gov/medicare-coverage-database/details/nca-decision-memo.aspx?NCAId =164&NcaName=Cardiac+Rehabilitation+Programs&DocID=CAG-00089R ? d. Staff The program must be staffed by personnel necessary to conduct the program safely and effectively, who are trained in both basic and advanced life support techniques and in exercise therapy for coronary disease. The program must be under the direct supervision of a physician, as defined in 42 CFR ยง 410.26(a)(2) (defined through cross reference to 42 CFR ยง 410.32(b)(3)(ii), or 42 CFR ยง 410.27(f)). The most conservative interpretation of this could exclude anyone who is not trained as specified in this provision as a member of the cardiac rehab team. However, there is no further elaboration from Medicare on this point. It is a matter of interpretation, in other words. Medicare does not specify the range of professional qualifications that are acceptable for every caregiver in the hospital setting. Medicare Conditions of Participation require that the hospital ?have appropriate professional and nonprofessional personnel?; the CoPs also require that the organization provide for adequate supervision, often in the form of a program medical director. Generally, we look to state licensing regulations to verify that the service delivered by a healthcare professional is consistent with state scope of practice laws corresponding to licensure or certification. Wellness coaches are not regulated by state law in Wisconsin. 5

PARA Weekly eJournal: March 4, 2020

WELLNESS COACH

If the program wishes to utilize highly trained wellness coaches in the CR and PR programs, we recommend that the department establish a written policy approved by the medical director of each program which deems the qualifications of the wellness coach to provide safe and effective care which meets specific programmatic needs, and also outlines the services that a wellness coach may provide as part of the program. The wellness coach(es) should be asked to read and acknowledge the memorandum as a condition of their participation in the cardiac rehab or pulmonary rehab team. You may want to check in with the Human Resources department to establish this document as part of the Wellness Coach job description. The policy (again, approved by the medical director) for the cardiac rehab program would identify the role/scope of services provided by a wellness coach. That role may be limited to general health education on topics such as dietary choices, heart function, stress reduction and identifying personal cardiac risk factors. It might specifically exclude the Wellness Coach from supervising exercise, if their training does not include current certification/competency in both basic and advanced life support techniques. Similarly, in the pulmonary rehab program, we suggest the policy establish that the wellness coach may not supervise exercise therapy, and define the scope by quoting the regulations at 42 CFR 410.49: (i)Education or training closely and clearly related to the individual's care and treatment which is tailored to the individual's needs. (ii)Education includes information on respiratory problem management and, if appropriate, brief smoking cessation counseling. (iii)Any education or training prescribed must assist in achievement of individual goals towards independence in activities of daily living, adaptation to limitations and improved quality of life. Please let me know if you need additional information or assistance. For your reference, the Medicare hospital CoPs are found at 42 CFR Part 482 ? I have provided a link and some excerpts below: https://ecfr.io/Title-42/pt42.5.482#se42.5.482_154 ยง482.54 Condition of participation: Outpatient services. If the hospital provides outpatient services, the services must meet the needs of the patients in accordance with acceptable standards of practice. (a) Standard: Organization. Outpatient services must be appropriately organized and integrated with inpatient services (b) Standard: Personnel. The hospital must? (1) Assign one or more individuals to be responsible for outpatient services (2) Have appropriate professional and nonprofessional personnel available at each location where outpatient services are offered, based on the scope and complexity of outpatient services. (c) Standard: Orders for outpatient services. Outpatient services must be ordered by a practitioner who meets the following conditions: (1) Is responsible for the care of the patient. (2) Is licensed in the State where he or she provides care to the patient. (3) Is acting within his or her scope of practice under State law. (4) Is authorized in accordance with State law and policies adopted by the medical staff, and approved by the governing body, to order the applicable outpatient services. 6

PARA Weekly eJournal: March 4, 2020

WELLNESS COACH

This applies to the following: (i) All practitioners who are appointed to the hospital's medical staff and who have been granted privileges to order the applicable outpatient services. (ii) All practitioners not appointed to the medical staff, but who satisfy the above criteria for authorization by the medical staff and the hospital for ordering the applicable outpatient services for their patients. [51 FR 22042, June 17, 1986, as amended at 77 FR 29075, May 16, 2012; 79 FR 27154, May 12, 2014] ยง482.57 Condition of participation: Respiratory care services. The hospital must meet the needs of the patients in accordance with acceptable standards of practice. The following requirements apply if the hospital provides respiratory care service. (a) Standard: Organization and Staffing. The organization of the respiratory care services must be appropriate to the scope and complexity of the services offered. 1)There must be a director of respiratory care services who is a doctor of medicine or osteopathy with the knowledge, experience, and capabilities to supervise and administer the service properly. The director may serve on either a full-time or part-time basis. 2)There must be adequate numbers of respiratory therapists, respiratory therapy technicians, and other personnel who meet the qualifications specified by the medical staff, consistent with State law. (b) Standard: Delivery of Services. Services must be delivered in accordance with medical staff directives. (1)Personnel qualified to perform specific procedures and the amount of supervision required for personnel to carry out specific procedures must be designated in writing. (2)If blood gases or other laboratory tests are performed in the respiratory care unit, the unit must meet the applicable requirements for laboratory services specified in ยง482.27. (3)Services must only be provided under the orders of a qualified and licensed practitioner who is responsible for the care of the patient, acting within his or her scope of practice under State law, and who is authorized by the hospital's medical staff to order the services in accordance with hospital policies and procedures and State laws. (4)All respiratory care services orders must be documented in the patient's medical record in accordance with the requirements at ยง482.24.[51 FR 22042, June 17, 1986; 51 FR 27848, Aug. 4, 1986, as amended at 57 FR 7136, Feb. 28, 1992; 75 FR 50418, Aug. 16, 2010].

PARA Weekly eJournal: March 4, 2020

REPEAT COLONOSCOPY

We coded an operative report with this account with 45378 with no modifier as per the instruction in the CPT® book with the scope reaching the cecum. The physician billed with modifier 52. The patient had a poor prep and the physician wanted to perform another colonoscopy and modifier 52 is the advice he was given per the insurance company. The insurance company is now asking the surgical center for a refund due to miss matched claims. Our coders do not have access to patient files and we code from op report alone. I feel the documentation supports our code of 45378 with no modifier. Can you help? Answer: Report CPT® code 45378 for the screening colonoscopy performed. The documentation states follow-up colonoscopy after two day prep recommended. The documentation does not support reduced services (modifier 52), as the scope did advance to the cecum. However, the procedure is discontinued and requires a repeat colonoscopy. When a repeat colonoscopy is required due to poor prep and limited visualization, it would be appropriate to append a modifier for discontinued services to the CPT® code. AMA CPT® Assistant 2014 instructs coders to append modifier 53 to the CPT® code even when the scope reaches the cecum for a repeat colonoscopy due to poor prep. This advice is for the physician billing. Modifier 74 would be reportable for the facility billing. Please refer to the PARA Data Editor modifier descriptions and the PARA Data Editor reference AMA CPT® Assistant February 2014, Volume 24, page 11 provided below.

PARA Weekly eJournal: March 4, 2020

REVISED CCI EDIT FILES POSTED

In lat e Febr u ar y 2020, CM S post ed n ew CCI edit f iles on t h e NCCI edit page w it h an ef f ect ive dat e of Jan u ar y 1, 2020, in an u n con ven t ion al m an n er . Th e n ew f iles om it a n u m ber of pr oblem at ic edit s pr eviou sly r epor t ed by PARA ? in clu din g: - 97530 Th er apeu t ic act ivit ies w it h a ph ysical or occu pat ion al t h er apy evalu at ion - 92611 bar iu m sw allow st u dy w it h 74230 videor adiogr aph y (n ow per m it s a m odif ier ) - Nu clear m edicin e codes w it h com m on r adioph ar m aceu t ical codes, e.g., 78306 w it h A9503 https://www.cms.gov/Medicare/Coding/NationalCorrectCodInitEd

PARA Weekly eJournal: March 4, 2020

REVISED CCI EDIT FILES POSTED

In the past, Medicare acknowledged changes to previously published edits in its listing in the next quarter?s ?CCI Edit Changes? file. However, in this case, the deleted edits are not mentioned in the ?changes? file, apparently because the new January 1, 2020 files make it appear as though the edits never existed. The MACs, however, have not yet matched the claim edit files to permit processing the code pairs that had previously been excluded from being reported together. The NCCI Edit Contractor, Capitol Bridge, LLC, suggests that ?Providers may choose to delay submission of claims for deleted edits until after the implementation of the replacement edit file with retroactive date of January 1, 2020. Providers may also choose to appeal claims denied due to the PTP edits to the appropriate MAC including supporting documentation or resubmit claims denied due to the PTP edits after the implementation of the replacement edit file with January 1, 2020 retroactive date, as permitted by the MAC.? The complete text of an email sent by the NCCI edit contractor, Capitol Bridge, LLC, in reply to a PARA client who had inquired about the problematic new edits is provided below: ?Thank you for your inquiry regarding the National Correct Coding Initiative (NCCI) program. The Centers for Medicare & Medicaid Services (CMS) owns the NCCI program and is responsible for all decisions regarding its contents. ?In your correspondence, you inquired about the recent implementation of certain Procedure-to-Procedure (PTP) edits related to Nuclear Medicine and Diagnostic Radiology.?After reviewing this issue more closely, CMS has made the decision to delete the following January 1, 2020 PTP edits:

PARA Weekly eJournal: March 4, 2020

REVISED CCI EDIT FILES POSTED

?CMS will change the Practitioner (PRA) and Outpatient Hospital (OPH) Modifier indicator for the following January 1, 2020 PTP edit:

?Both of these changes will be retroactive to January 1, 2020 and will be implemented as soon as technically possible in a future edit update. The update will be available at the following websites: ?Medicare: https://www.cms.gov/Medicare/Coding/NationalCorrectCodInitEd/Version_Update_Changes.html

?Medicaid: https://www.medicaid.gov/medicaid/ program-integrity/ncci/edit-files/index.html ?Providers may choose to delay submission of claims for deleted edits until after the implementation of the replacement edit file with retroactive date of January 1, 2020. Providers may also choose to appeal claims denied due to the PTP edits to the appropriate MAC including supporting documentation or resubmit claims denied due to the PTP edits after the implementation of the replacement edit file with January 1, 2020 retroactive date, as permitted by the MAC. ?CMS and the NCCI Program appreciate your time in making this inquiry. ?Sincerely, Capitol Bridge, LLC National Correct Coding Initiative Contractor Email:NCCIPTPMUE@cms.hhs.gov P.O. Box 368 Pittsboro, IN 46167SBA Certified 8(a) Small Disadvantaged Business 11

PARA Weekly eJournal: March 4, 2020

OIG CRITICIZES LABORATORY TRAVEL ALLOWANCE PAYMENTS

In December of 2019, the Office of the Inspector General published a report critical of one MAC?s performance in paying for travel allowances for phlebotomy services. The report alleged that the MAC did not sufficiently monitor provider use of the reimbursement codes. As a result, providers nationwide can expect MACs to be more aggressive in auditing claims which report P9603 or P9604 in the future. A link and an excerpt from the OIG report ?NOVITAS SOLUTIONS, INC. NEEDS ENHANCED GUIDANCE AND PROVIDER EDUCATION RELATED TO PHLEBOTOMY TRAVEL ALLOWANCE? is provided: https://oig.hhs.gov/oas/reports/region6/61704002.pdf NO DOCUMENTATION TO SUPPORT SPECIMEN COLLECTION Payments to Medicare providers should not be made unless the provider has furnished information necessary to the MAC to determine the amount owed to the provider. The Manual states that the travel allowance should be prorated by dividing the mileage by the total number of patients from whom specimen draws or pickups were made in the same trip. Each January, CMS publishes the national rate of payment for laboratory specimen collection services. The per-mile rate for P9603 is based on the IRS standard mileage rate for business plus an allowance to cover technician labor expense. However, Medicare Administrative Contractors may pay more than the minimum rate if local conditions warrant it.

PARA Weekly eJournal: March 4, 2020

OIG CRITICIZES LABORATORY TRAVEL ALLOWANCE PAYMENTS

MACs have the option of establishing a higher per mile rate in excess of the minimum set forth by CMS each year if local conditions warrant it. Medicare may review and update the minimum mileage rate throughout the year, as well as in conjunction with the Clinical Laboratory Fee Schedule (CLFS), as needed. The CMS transmittal announcing 2020 rates was released on January 17, 2020, with rates retroactive to January 1, 2020. Here is a link: https://www.cms.gov/files/document/mm11641.pdf Each MAC may, at its discretion, choose to pay either a mileage basis or a flat rate per trip. Many MACs have established local policy to pay only on a flat-rate basis, because audits have shown that some laboratories abused the per mileage fee basis by claiming travel mileage in excess of the minimum distance necessary for a laboratory technician to travel for specimen collection,. Another MAC, WPS, published the following tips for documentation in support of travel allowances: Laboratory Services - Clear indication of patient name, date of birth, and date of service - Lab results for date(s) of service billed - Signed and dated physician order or progress/clinic/visit notes that clearly document the specific service(s) to be performed - Documentation to support the medical necessity of ordered test(s) - Medical diagnosis - Signs and symptoms (rationale for lab performed) - If travel allowance for specimen collection is billed: - Number of collections performed per trip (for both Medicare and non-Medicare patients) to compute the Medicare prorated fee - Documentation of miles actually traveled - Documentation supporting that patient is homebound or nursing home bound 13

PARA Weekly eJournal: March 4, 2020

OIG CRITICIZES LABORATORY TRAVEL ALLOWANCE PAYMENTS

The Medicare Claims Processing Manual offers the following guidance on claiming reimbursement for travel. Excerpts from Chapter 16 of the Manual are provided here: https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/clm104c16.pdf# 60.2 - Travel Allowance The Medicare Claims Processing Manual provides the following direction on calculating the mileage for lab specimen collection: Per Mile Travel Allowance (P9603) - The minimum ?per mile travel allowance? is $0.99. The per mile travel allowance is to be used in situations where the average trip to patients?homes is longer than 20 miles round trip, and is to be pro-rated in situations where specimens are drawn or picked up from non-Medicare patients in the same trip, one way, in connection with medically necessary laboratory specimen collection drawn from home bound or nursing home bound patient; prorated miles actually traveled (A/B MAC (B) allowance on per mile basis); or - The per mile allowance was computed using the Federal mileage rate plus an additional 45 cents a mile to cover the technician?s time and travel costs. A/B MACs (B) have the option of establishing a higher per mile rate in excess of the minimum ($0.99 a mile in CY 2016) if local conditions warrant it. The minimum mileage rate will be reviewed and updated in conjunction with the clinical lab fee schedule as needed. At no time will the laboratory be allowed to bill for more miles than are reasonable or for miles not actually traveled by the laboratory technician. Example 1: In CY 2016, a laboratory technician travels 60 miles round trip from a lab in a city to a remote rural location, and back to the lab to draw a single Medicare patient?s blood. The total reimbursement would be $59.40 (60 miles x $0.99 cents a mile), plus the specimen collection fee. Example 2: In CY 2016, a laboratory technician travels 40 miles from the lab to a Medicare patient?s home to draw blood, and then travels an additional 10 miles to a non-Medicare patient?s home and then travels 30 miles to return to the lab. The total miles traveled would be 80 miles. The claim submitted would be for one half of the miles traveled or $39.60 (40 x $0.99), plus the specimen collection fee. Flat Rate (P9604) The CMS will pay a minimum of $10.30 (based on CY 2019) one way flat rate travel allowance. The flat rate travel allowance is to be used in areas where average trips are less than 20 miles round trip. The flat rate travel fee is to be pro-rated for more than one blood drawn at the same address, and for stops at the homes of Medicare and non-Medicare patients. The laboratory does the pro-ration when the claim is submitted based on the number of patients seen on that trip. The specimen collection fee will be paid for each patient encounter.

PARA Weekly eJournal: March 4, 2020

OIG CRITICIZES LABORATORY TRAVEL ALLOWANCE PAYMENTS

This rate is based on an assumption that a trip is an average of 15 minutes and up to 10 miles one way. It uses the Federal mileage rate and a laboratory technician?s time of $17.66 an hour, including overhead. A/B MACs (B) have the option of establishing a flat rate in excess of the minimum of $9.90, if local conditions warrant it. The minimum national flat rate will be reviewed and updated in conjunction with the clinical laboratory fee schedule, as necessitated by adjustments in the Federal travel allowance and salaries. The claimant identifies round trip travel by use of the LR modifier. Example 3: A laboratory technician travels from the laboratory to a single Medicare patient?s home and returns to the laboratory without making any other stops. The flat rate would be calculated as follows: 2 x $9.90 for a total trip reimbursement of $19.80, plus the specimen collection fee. Example 4: A laboratory technician travels from the laboratory to the homes of five patients to draw blood, four of the patients are Medicare patients and one is not. An additional flat rate would be charged to cover the 5 stops and the return trip to the lab (6 x $9.90 = $59.40). Each of the claims submitted would be for $11.88 ($59.40/5 = $11.88). Since one of the patients is non-Medicare, four claims would be submitted for $11.88 each, plus the specimen collection fee for each. Example 5: A laboratory technician travels from a laboratory to a nursing home and draws blood from 5 patients and returns to the laboratory. Four of the patients are on Medicare and one is not. The $9.90 flat rate is multiplied by two to cover the return trip to the laboratory (2 x $9.90 = $19.80) and then divided by five (1/5 of $19.80 = $3.96). Since one of the patients is non-Medicare, four claims would be submitted for $3.96 each, plus the specimen collection fee. If an A/B MAC (B) determines that it results in equitable payment, the A/B MAC (B) may extend the former payment allowances for additional travel (such as to a distant rural nursing home) to all circumstances where travel is required. This might be appropriate, for example, if the A/B MAC (B)?s former payment allowance was on a per mile basis. Otherwise, it should establish an appropriate allowance and inform the suppliers in its service area. If an A/B MAC (B) decides to establish a new allowance, one method is to consider developing a travel allowance consisting of: - - The current Federal mileage allowance for operating personal automobiles, plus a personnel allowance per mile to cover personnel costs based upon an estimate of average hourly wages and average driving speed A/B MACs (B) must prorate travel allowance amounts claimed by suppliers by the number of patients (including Medicare and non-Medicare patients) from whom specimens were drawn on a given trip. The A/B MAC (B) may determine that payment in addition to the routine travel allowance determined under this section is appropriate if: - The patient from whom the specimen must be collected is in a nursing home or is homebound; and - The clinical laboratory tests are needed on an emergency basis outside the general business hours of the laboratory making the collection - Subsequent updated travel allowance amounts will be issued by CMS via Recurring Update Notification (RUN) on an annual basis.

PARA Weekly eJournal: March 4, 2020

CORONAVIRUS UPDATE 2-28-2020

Coronaviruses

are classified as a

large family of viruses that cause infection in the sinuses, nose and upper throat. Some coronaviruses cause illness in people and others circulate among animals, including camels, cats and bats. The 2019 Novel Coronavirus is a new form of coronavirus first identified in Wuhan, Hubei Province, China. This virus has been officially named ?SARS-CoV2? which is a betacoronavirus.The disease it causes is now referred to as COVID-19 (previously referred to as 2019-nCoV). The COVID-19 outbreak has been detected in 50 locations internationally, including multiple confirmed cases in the United States.The Centers for Disease Control (CDC) confirmed that the disease has caused illness including illness resulting in death and sustained person to person spread.Individual risk is dependent on exposure. Symptoms of the COVID-19 can include fever, cough and shortness of breath.However, some patients with confirmed COVID-19 have developed little to no symptoms depending on the incubation period.The CDC reported, ?Symptoms may appear in as few as 2 days or as long as 14 after exposure ?. The CDC has developed a real time Reverse Transcription-Polymerase Chain Reaction (rRT-PCR) test that can diagnose COVID-19 in respiratory samples from clinical specimens.

Codin g COVID-19 As new clinical information becomes available, detail in coding selection may be revised.The ICD-10-CM codes provided in this reference are intended to provide information on the coding of encounters related to coronavirus. All coding selections should be supported by documentation. 16

PARA Weekly eJournal: March 4, 2020

CORONAVIRUS UPDATE 2-28-2020

Confirmed Cases When a one of the following conditions is confirmed as due to the COVID-19, both the respiratory condition and ICD-10CM code B97.29 should be coded. Refer to the PARA Data Editor code selection below: - Pneumonia confirmed as due to the COVID-19, assign codes J12.89; Other viral pneumonia, and B97.29; Other coronavirus as the cause of diseases classified elsewhere

- Acute bronchitis confirmed as due to COVID-19, assign codes J20.8, Acute bronchitis due to other specified organisms, and B97.29, Other coronavirus as the cause of diseases classified elsewhere

- Bronchitis Not Otherwise Specified (NOS) due to the COVID-19, assign codes J40, Bronchitis, not specified as acute or chronic; and B97.29, Other coronavirus as the cause of diseases classified elsewhere

- Acute respiratory infection, NOS or Lower respiratory infection NOS, assign ICD-10 CM codes code J22, Unspecified acute lower respiratory infection, with code B97.29, Other coronavirus as the cause of diseases classified elsewhere

PARA Weekly eJournal: March 4, 2020

CORONAVIRUS UPDATE 2-28-2020

- Respiratory infection, NOS, assign ICD-10 CM code J98.8, Other specified respiratory disorders, with code B97.29, Other coronavirus as the cause of diseases classified elsewhere

- Acute respiratory distress syndrome (ARDS), assign ICD-10 CM codesJ80, Acute respiratory distress syndrome, and B97.29, Other coronavirus as the cause of diseases classified elsewhere

Concern for or Exposure to COVID-19 In some cases, the patient may be evaluated for exposure or possible exposure to the COVID-19, however, after evaluation the condition may be ruled out.In those cases, it would not be appropriate to report a code for the actual virus. Please refer to the PARA Data Editor code descriptions for exposure without symptoms. - Actual Exposure to COVID-19 without symptoms, assign ICD-10 CM code Z20.828, contact with and (suspected) exposure to other viral communicable diseases - Concern of possible exposure without symptoms, assign ICD-10 CM code Z03.818, Encounter of observation for suspected exposure of other biological agents ruled out

When signs and symptoms are documented, the coder should report that symptom rather than a code for exposure or possible exposure. Please refer to the PARA Data Editor for symptom code descriptions.

PARA Weekly eJournal: March 4, 2020

CORONAVIRUS UPDATE 2-28-2020

Risk Assessment Please refer to the Risk Assessment reference from the CDC.The CDC continues to monitor and provide updates of the virus. https://www.cdc.gov/coronavirus/2019-ncov/downloads/public-health-management-decision-making.pdf

The CDC reported that the COVID-19 is likely spread person to person via respiratory droplets when the infected person coughs or sneezes.There is much more to learn about the transmissibility, severity, and other features associated with COVID-19 and investigations are ongoing. https://www.cdc.gov/coronavirus/2019-ncov/index.html The best way to prevent infection is to avoid being exposed to this virus. However, as a reminder, CDC always recommends everyday preventive actions to help prevent the spread of respiratory viruses, including: - Wash your hands often with soap and water for at least 20 seconds - Use an alcohol-basedhand sanitizer that contains at least 60% alcohol if soap and water are not available - Avoid touching your eyes, nose, and mouth with unwashed hands - Avoid close contact with people who are sick - Stay home when you are sick - Cover your cough or sneeze with a tissue, then throw the tissue in the trash - Clean and disinfect frequently touched objects and surfaces 19

PARA Weekly eJournal: March 4, 2020

GUIDELINES FOR LOCUM TENENS AND RECIPROCAL BILLING

Locum Tenensis a Latin phrase that means ?holding a place.?In the medical field, locum tenen is a term used for a physician who temporarily substitutes for another physician. A locum tenen, or fee-for-time physician, may provide temporary services for the physician who is out due to illness, vacation, pregnancy, continuing education or military service. Commonly, locum tenens do not have practices of their own and instead work under a staffing agency. We will discuss how to use the modifiers Q5 and Q6 to report substitute physicians. A locum tenen physician does not have to enroll in Medicare, nor does he/she have to be the same specialty as the physician for whom he/she is substituting. The locum tenen must have an NPI and an unrestricted license in the state that he or she is practicing. Per the Social Security Act, Section 1842(b) (6) (D), Medicare pays a physician for physician?s services. Therefore, services furnished by non-physician practitioners (i.e., nurse practitioners and physician assistants) may not be billed using the locum tenen provision.The physician must be an MD, DO, or podiatrist (see page 4 for discussion of special circumstances that apply to physical therapists.) https://www.ssa.gov/OP_Home/ssact/title18/1842.htm ?(D) payment may be made to a physician for physicians?services (and services furnished incident to such services) furnished by a second physician to patients of the first physician if (i) the first physician is unavailable to provide the services; (ii) the services are furnished pursuant to an arrangement between the two physicians that (I) is informal and reciprocal, or (II) involves per diem or other fee-for-time compensation for such services; (iii) the services are not provided by the second physician over a continuous period of more than 60 days or are provided over a longer continuous period during all of which the first physician has been called or ordered to active duty as a member of a reserve component of the Armed Forces; and (iv) the claim form submitted to the carrier for such services includes the second physician?s unique identifier (provided under the system established under subsection (r)) and indicates that the claim meets the requirements of this subparagraph for payment to the first physician. No payment which under the preceding sentence may be made directly to the physician or other person providing the service involved (pursuant to an assignment described in subparagraph (B)(ii) of paragraph (3)) shall be made to anyone else under a reassignment or power of attorney (except to an employer or entity as described in subparagraph (A) of such sentence); but nothing in this subsection shall be construed (i) to prevent the making of such a payment in accordance with an assignment from the individual to whom the service was provided or a reassignment from the physician or other person providing such service if such assignment or 20

PARA Weekly eJournal: March 4, 2020

GUIDELINES FOR LOCUM TENENS AND RECIPROCAL BILLING

agent does so pursuant to an agency agreement under which the compensation to be paid to the agent for his services for or in connection with the billing or collection of payments due such physician or other person under this title is unrelated (directly or indirectly) to the amount of such payments or the billings therefor, and is not dependent upon the actual collection of any such payment.? Medicare Rules for billing under Fee-For-Time (formerly referred to as Locum Tenen) arrangements: - Before the physician may bill for services provided by the locum tenen, the physician must ensure he/she has the following documents on file in his/her office and available upon request: - A copy of the locum tenen?s license and NPI - Documentation indicating the reason the physician is unavailable - An agreement or contract that describes the fee-for-time or per diem payment arrangements with the locum tenen as an independent contractor - The regular physician may submit a claim, using his or her NPI, for services furnished by the locum tenen while the regular physician was out due to illness, pregnancy, continuing education, vacation, or military service. Medicare requires claims for locum tenen services clearly indicate that a substitute physician provided the services listed on the claim by using modifier Q6 after the procedure code in box 24D of the CMS billing form. The Q6 modifier attests that documentation for the locum tenen is on file with the regular physician and that the services billed comply with the correct use of the locum tenen provision. Falsely certifying the requirements is subject to civil and/or criminal penalties of fraud

- The Locum Tenens physician must be paid using a per diem or a fee-for-time (hourly) method - The locum tenen may provide coverage for no longer than a 60-day continuous period. The time begins on the first day the locum tenen started and must end 60 days after initiation. If the physician returns, even for one day, the 60-day limit resets - The only exception to the 60-day limitation, according to Section 116 of Medicare, Medicaid, and SCHIP Extension Act of 2007, is if the regular physician is called to active duty military service. dhttps://www.congress.gov/110/plaws/publ173/PLAW-110publ173.pdf 21

PARA Weekly eJournal: March 4, 2020

GUIDELINES FOR LOCUM TENENS AND RECIPROCAL BILLING

- A physician may employ more than one locum tenen during the same 60-day consecutive period.However, only one locum tenen may work for the physician per day - The locum tenen: - May not cover on-call or part-time work for physicians - May not provide services for a deceased physician - May not be contracted to offer extended hours or to address high volume for the practice - May not provide service while a new physician is waiting for the completion of credentialing or enrollment - May not bill postop services with a Q6 modifier if the services are included in the global surgery fee - May provide up to 60 continuous days after a physician retires or resigns. If necessary, another locum tenen, with a different 60-day period, may extend coverage.However, the retiring or resigning physician must notify Medicare provider enrollment of his/her departure within 90 days. Once Medicare is notified, the locum tenen may no longer bill using that physician?s NPI - May be employed by a group practice for up to 60 days after a physician leaves the group The CMS Claims Manual, 30.2.11 discusses claim submission Fee-For-Time Arrangements: https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/clm104c01.pdf

Report the Q6 modifier for the first 60-day continuous period of the locum tenen. Should a locum tenen services extend beyond day 60, he/she must bill under his/her own NPI. Locum Tenen physicians will affect the quality payment program and MIPs score of the absent physician or physician group. Reciprocal Billing Arrangements Physicians may often provide coverage for each other?s covered services using a reciprocal billing arrangement. When accepted for Medicare assignment, a physician may bill under his/her NPI for services provided by a substitute physician who has agreed to occasional reciprocal agreements. The physician may not provide services to patients longer than a 60-day continuous period. Reciprocal billing arrangements may include multiple physicians, and the arrangement doesn?t need to be formalized in writing. Also, as long a Medicare payment is not reassigned to a medical group (through a CMS 855-R), a medical group may submit claims using modifier Q5 with the regular physician NPI when he/she is unavailable.When the regular physician is unavailable to provide the service, he/she may submit a claim for services provided by the substitute physician by using modifier Q5 with the procedure code. If the substitute physician is providing only postop services that are covered by the global fee, the modifier Q5 is not required. 22

PARA Weekly eJournal: March 4, 2020

GUIDELINES FOR LOCUM TENENS AND RECIPROCAL BILLING

The Medicare Claims Processing Manual, 30.2.10 discusses claim submission under Reciprocal Billing Arrangements: https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/clm104c01.pdf

Following the 21st Century Cures Act (Public Law 114-255, Section 16006), reciprocal billing and locum tenens also apply to physical therapists who provide services in certain health professional shortage areas. https://www.congress.gov/114/plaws/publ255/PLAW-114publ255.pdf

PARA Weekly eJournal: March 4, 2020

GUIDELINES FOR LOCUM TENENS AND RECIPROCAL BILLING

The NPI and services provided by a substitute physician must on file and available upon request. Medicare contractors offer additional information on billing for locum tenens and reciprocal billing. Noridian: https://med.noridianmedicare.com/web/jfb/specialties/locum-tenens-and-reciprocal-billing

Novitas: https://www.novitas-solutions.com/webcenter/portal/MedicareJL/pagebyid?contentId=00105762

CGS: https://www.cgsmedicare.com/partb/ pubs/news/2013/0313/cope21500.pdf

PARA Weekly eJournal: March 4, 2020

Dow n load t h e PDF ver sion by click in g t h e im age above.

PARA Weekly eJournal: March 4, 2020

BILLING DEVICE-INTENSIVE HCPCS WITHOUT A DEVICE

IN THE 2020 OPPS UPDATE M LN ARTICLE Medicare repeated little-known news about modifier CG that was quietly introduced in the October, 2019 Integrated Outpatient Code Editor update file.The guidance instructs hospitals to append modifier CG ? ?Policy criteria applied? ? when reporting a device-dependent outpatient procedure which did not require a device. The OPPS guidance is retroactive to January 1, 2019, although it was first included in the October 2019 update of the Integrated Outpatient Code Editor. Many hospitals were advised by their MAC to report a device code at a nominal value to resolve the edit preventing claim submission without the device reported.Hospitals which may have reported a device-intensive procedure in 2019 which did not require a device should consider submitting a corrected claim with modifier CG, rather than device codes with a nominal value. Here?s an excerpt from Medicare?s January 2020 Update of the Hospital Outpatient Prospective Payment System (OPPS): https://apps.para-hcfs.com/PDE_V2/CDMEditor_New.aspx

The edit to be bypassed is IOCE edit 92:

PARA Weekly eJournal: March 4, 2020

BILLING DEVICE-INTENSIVE HCPCS WITHOUT A DEVICE

Background In the January 2019 OPPS update, Medicare nearly doubled the number of HCPCS on OPPS Addendum P ? ?Device Intensive Procedures? -- procedures for which CMS has determined at least 30% of the APC payment is attributed to a packaged device code. Addendum P lists the percentage by which CMS will reduce payment -- an ?offset percentage? ? to the OPPS hospital if the hospital does not incur the expected cost of an implant. While CMS has long provided instructions for reporting a reduced-cost implant, it had not provided instructions for situations in which no implant at all was needed. Billers were unable to resolve edit 92 without including an implant on the claim, even if no implant at all was used for the procedure. OPPS Addendum P, which is available on the PARA Data Editor Advisor tab ? bear in mind that CMS may publish changes to this addendum quarterly:

Since some of the HCPCS listed on the OPPS Addendum P ?Device-Intensive Procedures? do not always require a device, hospitals previously had no appropriate mechanism to report such procedures. Some hospitals were verbally advised by their MAC to report a device anyway, at a very nominal price (e.g., $1.00.) However, this billing method could result in full payment of the APC, when reduced payment should have been paid. Modifier CG is not a new modifier. It is also used by dialysis providers and Rural Health Clinics for completely different purposes. Now, modifier CG has a third application. It may also be reported by OPPS hospitals when billing certain device-dependent procedures (which required no device) on an outpatient claim. For example, HCPCS 27443 (ARTHROPLASTY, FEMORAL CONDYLES OR TIBIAL PLATEAU(S), KNEE; WITH DEBRIDEMENT AND PARTIAL SYNOVECTOMY) may involve either realigning the joint or replacing it with a prosthetic one. Therefore, this HCPCS may be reported either a procedure which requires an implant or one which does not.Since 27443 appears on the OPPS list of ?device-dependent procedures in Addendum P, claims in 2019 were not accepted unless a device was also reported on the claim.

PARA Weekly eJournal: March 4, 2020

BILLING DEVICE-INTENSIVE HCPCS WITHOUT A DEVICE

If the hospital used no implant, or a significantly reduced cost implant, a lower APC reimbursement rate should be paid, according to the ?Device Offset Amount? indicated in Addendum P. Here is an excerpt from Addendum P which indicates that the APC reimbursement for HCPCS 27443 will be reduced by $4,972.76 (unadjusted national average) when reported with modifier CG appended, or when the implant is reported at a significantly reduced cost to the hospital.

For more information on claims submission requirements for reduced cost implants, see PARA?s paper at https://apps.para-hcfs.com/para/Documents/Reporting_Manufacturer_Credit_for_Devices_edited.pdf 34

PARA Weekly eJournal: March 4, 2020

SIX STEPS FOR DEPLOYING AI SOLUTIONS IN DENIAL MANAGEMENT

Resolu t ion | Recover y | M an agem en t HFRI is altering the hospital AR landscape by delivering unparalleled speed, scalability and accuracy to the insurance AR management process. Through our proprietary, intelligent automation and powerful process engineering, we?re able to resolve all claims, regardless of size or age. That means you?re able to recover collections from insurance claims that otherwise would have been written off. Our AR management services are easily integrated into your hospital?s existing workflow to seamlessly function as an extension to your existing billing office. HFRI specialists collaborate with your team not only to assist with your denial management initiatives but to identify root causes that will help prevent denials from occurring in the first place.

Specialized Services to Improve AR Performance HFRI?s scalable, client-specific solutions allow hospitals to systematically address problem claims across the full AR spectrum, from government and commercial payers to managed care, worker?s compensation and personal injury claims. Our capabilities include: - Primary AR recovery and resolution We pursue aging, small-balance claims identified by your staff as problematic. If a claim has previously been worked internally, referring it to HFRI?s dedicated, specialized teams can help ensure quicker cash conversion and a reduction of bad debt reserves. - Pre write-off AR recovery and resolution In addition to primary AR recovery and management services, HFRI also offers pre write-off (often known as secondary) insurance AR recovery to help you collect highly-aged claims and minimize write-offs. - Legacy system conversions Transitioning to a new system can slow down the claims process and create problems for hospital personnel who must work between two billing platforms. HFRI can provide interim solutions to help you accelerate pre-conversion cash and assist with post-conversion AR resolution. AR recovery projects: HFRI is available to assist you on a temporary project basis to address AR backlogs that can?t be worked by your existing staff. 35

PARA Weekly eJournal: March 4, 2020

NEW YEAR'S RESOLUTION #1: GET PDE FIT

New PDE training opportunities available.

In an effort to streamline the PARA Dat a Edit or (PDE) training process, PARA will begin hosting weekly Overviews of the PDE. These sessions will be open to any client or user who wishes to join, and will consist of a high-level review of the functionality available within the PDE. If you are new to the PDE, or would like a refresher on its capabilities, please join us at whichever session is most convenient for you. Beginning January 8, 2020 Overview sessions will be held: Wedn esdays at 11:00 am Pacif ic t im e (12:00 pm M ou n t ain , 1:00 pm Cen t r al, 2:00 pm East er n ) Fr idays 8:00 am Pacif ic t im e (9:00 am M ou n t ain , 10:00 am Cen t r al, 11:00 am East er n ) Please note, focused training for your staff on the modules of the PDE that you choose to utilize will still be available. If you are interested in attending one of the sessions, please email Mary McDonnell, Director of PDE Training and Development at mmcdonnell@para-hcfs.com . An invitation to the session of your choice will be emailed to you. If you have any questions, please email us at the address above or call (800) 999-3332 ext. 216. 36

PARA Weekly eJournal: March 4, 2020

KEY OPPORTUNITIES FOR HOSPITALS TO BOOST MARGINS

In Th e Er a Of Pr ice Tr an spar en cy About 60 million Americans live in rural areas and depend on local hospitals for care. In 2019, a record 18 rural hospitals closed, bringing the total closures since 2010 to 124, according to the Cecil G. Sheps Center for Health Services Research. With almost 700 more rural hospitals at risk of shutting, the need for strategies to boost margins at these facilities has never been greater. During a February 26, 2020 webinar sponsored by Healthcare Financial Resources and hosted by Becker's Hospital Review, three representatives from HFRI discussed ways hospital leaders can help their organizations achieve financial sustainability. Participants included: - Jon Giuliani, Vice President of Operations - Randi Brantner, Vice President of Analytics - Daniel Low, Director of Operations Factors contributing to rural hospital closures include increasing costs and declining revenues, complex patient populations and difficulties attracting and retaining providers. Solving these issues can not only help these hospitals stay open, but really thrive in their communities, according to Mr. Giuliani. "The best way to ensure we can offer the highest quality of care to as many people as possible is to ensure our providers are healthy financially," Mr. Giuliani said. "Those margins help drive growth, research and continuous improvement in care." Preparing for price transparency To achieve thicker margins, today's hospital leaders must help their organizations meet the demands of changing regulatory requirements and rising consumerism within the industry. In 2015, CMS began introducing price transparency guidelines, requiring hospitals to provide a standard list of charges upon patient request. Beginning in 2021, CMS' final rule will require hospitals to publish standard charges online in a machine-readable file and to disclose negotiated payer rates. "We foresee a continued legal battle but are proactively looking to prepare our hospitals for a consumer-centric approach to pricing transparency," Ms. Brantner said. "We recommend an intuitive user-friendly solution that incorporates the complete list of charges, the base CDM price and a list of common procedures in a consumer-friendly language." HFRI also suggests initiating the functionality to allow patients to enter copay and deductible information for a more complete estimate. By inputting the patient's insurance details and accessing the facility's historical data, hospitals can gauge a truer estimate of services and patient obligation, according to Ms. Brantner. "We've found that this strategy improves collections, reduces bad debt and is great customer service that improves the customer experience," Ms. Brantner said. 37

PARA Weekly eJournal: March 4, 2020

KEY OPPORTUNITIES FOR HOSPITALS TO BOOST MARGINS Designing pricing strategies Before hospitals publish their charges ? which are intended to represent the statistical basis of costs for hospitals? a prudent pricing strategy should be implemented. Thus, HFRI recommends hospitals price a chargemaster in line with Medicare fee schedules, costs or comparative peer-pricing data. All hospitals are reimbursed differently, depending on their outpatient prospective payment system, critical access status or other third party payer contracts, but most charges are typically divided into five basic revenue streams: room rates/observations, emergency room/clinic visits, diagnostic and therapeutic services, operating room services and drugs and supplies. "Cost-based mark-ups are recommended for drugs/supplies so that full transparency can be achieved," Ms. Brantner said. "We also recommend identifying [diagnostic and therapeutic] items with negative patient satisfaction and pricing those items competitively for outpatients against other data sources, such as a freestanding facility or actual clinic data." Before new price transparency regulations take effect, it's important for hospitals to establish rational pricing strategies that can stand up to the test of consumerism. Implementing effective pricing methods improve hospitals' contract management capabilities? as they have prices that are relative to the peer market? and enable them to better articulate pricing strategies to payers. Opportunities to boost hospital efficiencies Identifying payer issues upfront can help hospitals improve back-end efficiency and reduce cash loss. Additionally, improved efficiency and well-organized teams will ultimately lead to an improved patient experience. "A well-tuned insurance accounts receivable team will help ensure patients' claims are paid appropriately and that patients are billed correctly and timely," Mr. Low said. "Identifying [payer] issues and building payer relationships is also critical to reducing current and future rejections." Challenges with new EHR systems have been well-documented, with one survey finding 65 percent of respondents who implemented new software experiencing financial losses in their practice. To ensure EHR systems don't negatively impact efficiency, productivity and cost, complete and proper implementation should be top of mind for hospitals. During new implementations, facilities often see days in accounts receivable and denials increase while cash flow decreases, which can be a year or more until stabilization, according to Mr. Low. "Building, reporting and assessing the data with the EHR system is a challenging and always evolving task," Mr. Low said. "Communication between the clearinghouse and EHR should be a main focus to ensure staff have the ability to stop account issues prior to billing." Conclusion Preparing for price transparency and developing effective pricing strategies for hospital charges is paramount for all healthcare facilities this year. Meeting this challenge will be especially important for rural hospitals and other organizations facing fiscal challenges. Healthcare leaders should look to arm their teams with the appropriate tools and processes for improving revenue cycle efficiency and reimbursement. To learn more about Healthcare Financial Resources click here, and view the full webinar here or the icon above. 38

PARA Weekly eJournal: March 4, 2020

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!

Th u r sday, Febr u ar y 27, 2020 New s

·Quality Payment Program: MIPS 2019 Data Submission Period Open through March 31 ·Anesthesia Modifiers: Comparative Billing Report in March Com plian ce

·Inpatient Rehabilitation Facility Services: Follow Medicare Billing Requirements Claim s, Pr icer s & Codes

·COVID-19: New ICD-10-CM Code and Interim Coding Guidance ·SNF PDPM Claims Issue ·FQHC: Mass Adjustment of Claims Even t s

·Dementia Care: CMS Toolkits Call ? March 3 ·Part A Providers: QIC Appeals Demonstration Call ? March 5 ·Ground Ambulance Organizations: Data Collection for Public Safety-Based Organizations Call ? March 12 ·Open Payments: Your Role in Health Care Transparency Call ? March 19 M LN M at t er s® Ar t icles

·Quarterly Update to the Medicare Physician Fee Schedule Database (MPFSDB) - April 2020 Update ·Implementation of the Long Term Care Hospital (LTCH) Discharge Payment Percentage (DPP) Payment Adjustment ·Appropriate Use Criteria (AUC) for Advanced Diagnostic Imaging- Approval of Using the K3 Segment for Institutional Claims ? Revised ·Accepting Payment from Patients with a Medicare Set-Aside Arrangement ? Revised ·January 2020 Integrated Outpatient Code Editor (I/OCE) Specifications Version 21.0 ? Revised Pu blicat ion s

·Medicare Quarterly Provider Compliance Newsletter, Volume 10, Issue 2

PARA Weekly eJournal: March 4, 2020

There were TWO new or revised MedLearns 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

PARA Weekly eJournal: March 4, 2020

The link to this MedLearn MM11638

PARA Weekly eJournal: March 4, 2020

The link to this MedLearn MM11661

PARA Weekly eJournal: March 4, 2020

There were FIVE 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

PARA Weekly eJournal: March 4, 2020

The link to this Transmittal R4540CP

PARA Weekly eJournal: March 4, 2020

The link to this Transmittal R2438OTN

PARA Weekly eJournal: March 4, 2020

The link to this Transmittal R4534CP

PARA Weekly eJournal: March 4, 2020

The link to this Transmittal R9431PI

PARA Weekly eJournal: March 4, 2020

The link to this Transmittal R4536CP

PARA Weekly eJournal: March 4, 2020

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

h f r Review i.n et Claim Specialist

ngraves@para-hcfs.com

ssestili@para-hcfs.com

dmay@para-hcfs.com

M ary M cDonnell

Patti Lew is

Director, PDE Training & Development

Director Business Operations

mmcdonnell@para-hcfs.com

plewis@para-hcfs.com