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PARA WEEKLY
UPDATE For Users
I mproving T he Business of H ealthCare Since 1985 August 22, 2018
NEWS FOR HEALTHCARE DECISION MAKERS
IN THIS ISSUE QUESTIONS & ANSWERS - Low Dose CT Lung Cancer Screening - IV Infusion Denied--Revised - Trauma Activation - Nurse Practitioner Home Visits 99348 or 99349 OPPS PROPOSED RULE CUTS OFF-CAMPUS REIMBURSEMENT
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REPRINT: TECHNICAL CHANGE TO INPATIENT ORDERS RULE FOR 2019 IPPS RURAL HEALTHCARE GRANTS MLNCONNECTS REPRINT: MEDICARE PROPOSES TO CEASE THERAPY G-CODES IN 2019 PARA OUTMIGRATION REPORTS
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The number of new or revised Med Learn (MLN Matters) articles released this week. All new and previous Med Learn articles can be viewed under the type "Med Learn", in the Advisor tab of the PARA Dat a Edit or . Click here -------------------------------------------------------
The number of new or revised Transmittals released this week. All new and previous Transmittals can be viewed under the type "Transmittals" in the Advisor tab of the PARA Dat a Edit or . Click here.
Administration: Pages 1-31 HIM /Coding Staff: Pages 1-31 Imaging: Page 2 Oncology: Page 2 Trauma Services: Page 4 Providers: Pages 2-4,7,28-29 Home Health: Pages 7, 30
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Finance: Pages 20-21,23 Outpatient Services: Page 8 Diabetes Care: Page 18 Hospitalists: Page 11 Health Education: Page 25 EHR: Page 27 Rural Healthcare: Page 13
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PARA Weekly Update: August 22, 2018
LOW DOSE CT LUNG CANCER SCREENING
Now that we see Medicare will cover CT low dose lung screening, can we legally bill Medicare and state that the out of pocket will only be $25.00 for the patient no matter if Medicare applies to coinsurance or deductible? We would be doing this for all insurances for this particular scan. Answer: No, it is inappropriate to guarantee a fixed out-of-pocket for a service whether the health coverage adjudicates a higher amount. Hospitals may discount patient liability under a financial assistance program and/or for prompt payment, and hospitals may set the chargemaster price for procedures at their own discretion. However, it is inappropriate to charge a higher price to Medicare in order to receive a higher payment under CAH percent-of-charges reimbursement, and then to cap the patient liability at something less than the payor would adjudicate. However, your concern may be completely resolved by the fact that according to the Medicare Claims Processing Manual, the coinsurance and deductible for covered low-dose CT for lung cancer screenings is waived; this is the case for certain preventive services. Here?s an excerpt from the Medicare Claims Processing Manual, Chapter 18: https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/clm104c18.pdf Insurers design health insurance benefits to include a portion that is patient liability in order to curtail over-utilization. Contracts with commercial insurers usually include a provision that the provider will not waive the patient liability for services covered by the carrier. For Medicare beneficiaries receiving non-preventive services, the coinsurance for services provided at a Critical Access Hospital will be 20% of the billed charge.
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PARA Weekly Update: August 22, 2018
IV INFUSION DENIED
(Supersedes article published 8/15/18)
We have had some minor issues with payers denying infusion/injections, etc. Attached are two sample claims along with the remittance advice.
Answer: The denial of the line 96361 on a Critical Access Hospital claim appears to be a claim processing error; we find no errors in the IV therapy procedure coding on the face of the claim. Please contact Medicare customer service to question the denial. If the front-line Medicare representative does not recognize the error, you may want to speak to a supervisor. Here?s an excerpt from the Medicare Claims Processing Manual which supports the coding as presented: https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/clm104c04.pdf 230.2 - Coding and Payment for Drug Administration (Rev. 2141, Issued: 01-24-11, Effective: 01-01-11, Implementation: 01-03-11) ? B. Billing for Infusions and Injections ? ?Drug administration services are to be reported with a line item date of service on the day they are provided. In addition, only one initial drug administration service is to be reported per vascular access site per encounter, including during an encounter where observation services span more than 1 calendar day.? If the MAC does not recognize the claim processing error and requires the claim to be appealed, you may find the denial is upheld if your MAC reviews the record and finds that the flow rate was too low to justify the hydration charges. It is inappropriate to report 100 ml/hr to 200 ml/hr as IV hydration with CPT 96360 or 96361 on an outpatient claim. We recommend reporting hydration codes on an outpatient claim only if the flow rate exceeds 500 ml/hour. While this is not a rule in CPT Assistant, one of the national Medicare Administrative Contractors uses this flow rate in a Local Coverage Determination, and the argument is sound ? only a half a cup of fluid per hour does not rehydrate, it serves only to keep the line open. Here?s an excerpt from the claim (no PHI):
Here's an excerpt from the remittance:
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PARA Weekly Update: August 22, 2018
TRAUMA ACTIVATION
First Question: Can a hospital bill all patients involved in a trauma the trauma activation code regardless of their injury? Example: Car accident event involving two individuals caused trauma activation however only one had emergency (trauma) injuries. The other had minor injuries and was released from the ED. Can the trauma activation code be charged on the second patient with minor injuries? Second Question: Can a hospital bill for inhalation treatments administered by an RN in the ER? Answer regarding Trauma Activation: First of all, trauma activation charges are appropriate only for hospitals which are designated trauma centers. To bill the trauma activation fee, there must have been pre-hospital notification, meeting field triage criteria, or are delivered via inter-hospital transfer and are given the appropriate team response. There are two ways to report trauma activation ? with and without a HCPCS: 1. Without HCPCS G0390, (OPPS does not require HCPCS codes for revenue codes 0681-0684; if a charge is reported, reimbursement is packaged when no HCPCS codes are present. 2. With HCPCS G0390, which is appropriate only if the patient also received 30 minutes or more of critical care, as evidenced by CPT 99291 on the same encounter/DOS. Multiple patients involved in the same trauma incident who receive 30 minutes of critical care may each be charged the trauma activation fee with G0390. Medicare created HCPCS G0390 (Trauma response team associated with hospital critical care service) in 2012 to facilitate additional payment only when the fee is reported together with critical care (99291 on the same encounter. Therefore, we do not recommend reporting G0390 unless the hospital also reports critical care. If multiple patients in the same trauma incident (i.e. MVA) receive critical care and the trauma team was activated to respond to the needs of both patients, then each patient?s account should report G0390. G0390 does not alone generate any additional Medicare reimbursement unless the claim also reports 99291. Other payors may have different payment policies, of course, but Medicare created the code for very limited circumstances, and therefore we recommend abiding by the instructions Medicare provides. On the next page, you'll find an excerpt from the Medicare transmittal introducing G0390 and you can click this link for the full text: https://www.cms.gov/Outreach-and-Education/Medicare-Learning-NetworkMLN/MLNMattersArticles/downloads/mm5438.pdf
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PARA Weekly Update: August 22, 2018
TRAUMA ACTIVATION
Coding and Payment for Critical Care For CY 2007, Medicare will pay for critical care at 2 levels, depending on the presence or absence of trauma activation. Providers will receive one payment rate for critical care without trauma activation and will receive additional payment when critical care is associated with trauma activation. To determine whether trauma activation occurs, providers are to follow the National Uniform Billing Committee (NUBC) guidelines related to the reporting of the trauma revenue codes in the 68x series. The guidelines are listed in the Medicare Claims Processing Manual, Publication 100-04, Chapter 25, § 60.4. (That manual is available at http://www.cms.gov/Regulations-andGuidance/Guidance/Manuals/InternetOnly-Manuals-IOMs.html on the CMS site.) In summary, revenue code series 68x can be used only by trauma centers/hospitals as licensed or designated by the state or local government authority authorized to do so, or as verified by the American College of Surgeons. Different subcategory revenue codes are reported by designated Level 1-4 hospital trauma centers. Only patients for whom there has been pre-hospital notification based on triage information from pre-hospital caregivers, who meet either local, state or American College of Surgeons field triage criteria, or are delivered by inter-hospital transfers, and are given the appropriate team response can be billed a trauma activation charge. CMS created G0390, Trauma response team activation associated with hospital critical care service, effective January 1, 2007, which is assigned to APC 0618, Critical Care with Trauma Response. When at least 30 minutes of critical care is provided without trauma activation, the hospital will bill CPT® code 99291, Critical care evaluation and management of the critically ill or critically injured patient; first 30-74 minutes (and 99292, if appropriate) as usual, and receive payment for APC 0617, Critical Care. If trauma activation occurs under the circumstances described by the NUBC guidelines that would permit reporting a charge under 68x and the hospital provides at least 30 minutes of critical care so CPT®code 99291 is appropriately reported, the hospital may also bill one unit of HCPCS code G0390, reported with revenue code 68x on the same date of service as CPT® code 99291, and the hospital will receive an additional payment under APC 0618. The OCE will edit to ensure that G0390 appears with revenue code 68x on the same date of service as CPT® code 99291 and that only one unit of G0390 is billed. CMS believes that trauma activation is a one-time occurrence in association with critical care services, and therefore, will only pay for one 5
PARA Weekly Update: August 22, 2018
TRAUMA ACTIVATION
unit of G0390 per day. CMS will monitor usage of the CPT® codes for critical care services and the new G-code to ensure that their utilization remains at anticipated levels. CPT® code 99291 is defined by CPT® as the first 30-74 minutes of critical care. This 30 minute minimum has always applied under the OPPS and will continue to apply for CY 2007. CMS is continuing to provide packaged payment for CPT® code 99292, Critical care, evaluation and management of the critically ill or critically injured patient; each additional 30 minutes, for those periods of critical care services extending beyond 74 minutes, so hospitals do not have the ongoing administrative burden of reporting precisely the time for each critical service provided. As the CPT® guidelines indicate, hospitals that provide less than 30 minutes of critical care should bill for a visit, typically an emergency department visit, at a level consistent with their own internal guidelines. Hospitals that provide less than 30 minutes of critical care when trauma activation occurs under the circumstances described by the NUBC guidelines that would permit reporting a charge under revenue code 68x, may report a charge under 68x, but they may not report HCPCS code G0390. In this case, payment for the trauma response is packaged into payment for the other services provided to the patient in the encounter, including the visit that is reported. Under the OPPS, the time that can be reported as critical care is the time spent by a physician and/or hospital staff engaged in active face-to-face critical care of a critically ill or critically injured patient. If the physician or hospital staff or multiple hospital staff members are simultaneously engaged in this active face-to-face care, the time involved can only be counted once. The UB data specifications for revenue codes in the 068X range are available on the PARA Data Editor Calculator page: In response to your second question, we recommend considering respiratory care provided by nurses in the Emergency Department to be a component of the Emergency Department visit charge, 99281-99285. We do not recommend reporting the respiratory care services separately unless performed by a respiratory therapist. Attached our paper on Emergency Room Charge Process.
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PARA Weekly Update: August 22, 2018
NURSE PRACTITIONER HOME VISITS 99348 OR 99349
If one of our Nurse Practitioners performs a home visit 99348 or 99349, does the facility need to be credentialed as a Home Health Facility or Agency? Or can we bill a 1500 professional claim for the Nurse Practitioner with one of these codes?
Answer: There is no facility fee for professional services performed in the patient?s home. However, the medical group that serves as the billing entity for the nurse practitioners should make sure that their Medicare group enrollment indicates that services will be performed in patients homes. The enrollment is part of the Medicare 855B application, which of course corresponds with the electronic enrollment available under PECOS. Here?s an excerpt:
https://www.cms.gov/Medicare/CMS-Forms/CMS-Forms/Downloads/cms855b.pdf
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PARA Weekly Update: August 22, 2018
OPPS PROPOSED RULE CUTS OFF-CAMPUS REIMBURSEMENT
n the 2019 OPPS Proposed Rule, CMS proposes to reduce payment for all off-campus hospital outpatient clinic visits (HCPCS G0463) to 40% of the APC rate that would apply for an on-campus visit, regardless whether the clinic was ?excepted? (grandfathered) or non-excepted (non-grandfathered, i.e. established after November 2, 2015.) (This provision would apply only to OPPS APC reimbursed facilities, it does not appear to affect CM S pr oposes t o r edu ce paym en t f or all reimbursement paid to Critical Access of f -cam pu s h ospit al ou t pat ien t clin ic visit s Hospitals, although CAHs are not (HCPCS G0463) t o 40% of t h e APC r at e t h at specifically addressed.) w ou ld apply f or an on -cam pu s visit , r egar dless In other words, under OPPS, Medicare w h et h er t h e clin ic w as ?except ed?. reimbursement for HCPCS G0463 would be reduced to 40% of the on-campus APC rate when the visit is provided at an off-campus hospital department location, as indicated by either modifier PO or modifier PN appended to G0463. Modifier PO (Services,procedures and/or surgeries furnished off-campus provider-based outpatient departments) must be appended to HCPCS for services provided in an excepted/grandfathered clinic location, and modifier PN (Non-excepted items and services for provider-based department (PBD)) must be appended to HCPCS for services provided a non-excepted/non-grandfathered off-campus hospital location.
Outpatient visits billed with G0463 on the hospital campus and at dedicated emergency departments will apparently be paid at the full APC rate, however. HCPCS code G0463 is the most commonly reported service billed at off-campus locations which serve as physician office locations. Hospitals began acquiring physician clinics and establishing their location as provider-based departments in 2001, when CMS loosened the criteria for establishing a provider-based clinic. The idea of purchasing and converting physician offices to off-campus hospital locations caught great momentum as word spread that the same physician visit billed by a provider-based clinic could yield more than double the Medicare payment as compared to billing by a free-standing physician office location. Now that this practice has proliferated, the rate of reimbursement is unsustainable, and Medicare now seeks to reduce the financial burden that it previously unleashed by relaxing its regulations. CMS intends that this change would result in overall savings (between both the Medicare Program and beneficiary copayments) of $760 million for 2019.
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PARA Weekly Update: August 22, 2018
OPPS PROPOSED RULE CUTS OFF-CAMPUS REIMBURSEMENT
Additionally, on page 37050 of the 2019 OPPS Proposed Rule, CMS proposes to pay at the lower Medicare Physician Fee Schedule for any new services offered at off-campus locations. ?? if an excepted off-campus PBD furnishes a service from a clinical family of services for which it did not previously furnish a service (and subsequently bill for that service) during a baseline period, services from this new clinical family of services would not be covered OPD services. Instead, services in the new clinical family of services would be paid under the PFS.? Here are excerpts from the proposed rule pertinent to off-campus location reimbursement: ?? We believe that the higher payment that is made under the OPPS, as compared to payment under the PFS, is likely to be incentivizing providers to furnish care in the hospital outpatient setting rather than the physician office setting. In 2012, Medicare was paying approximately 80 percent more for a 15-minute office visit in a hospital outpatient department than in a [[Page 37142]] freestanding physician office. ? ?Therefore, given the unnecessary increases in the volume of clinic visits in hospital outpatient departments, for the CY 2019 OPPS, we are proposing to use our authority under section 1833(t)(2)(F) of the Act to apply an amount equal to the site-specific PFS payment rate for nonexcepted items and services furnished by a nonexcepted off-campus PBD (the PFS payment rate) for the clinic visit service, as described by HCPCS code G0463, when provided at an off-campus PBD excepted from section 1833(t)(21) of the Act (departments that bill the modifier ``PO'' on claim lines). Off-campus PBDs that are not excepted from section 603 (departments that bill the modifier ``PN'') already receive a PFS-equivalent payment rate for the clinic visit. In CY 2019, for an individual Medicare beneficiary, the standard unadjusted Medicare OPPS proposed payment for the clinic visit is approximately $116, with approximately $23 being the average copayment. The proposed PFS equivalent rate for Medicare payment for a clinic visit would be approximately $46 and the copayment would be approximately $9. This would save beneficiaries an average of $14 per visit. Under this proposal, an excepted off-campus PBD would continue to bill HCPCS code G0463 with the ``PO'' modifier in CY 2019, but the payment rate for services described by HCPCS code G0463 when billed with modifier ``PO'' would now be equivalent to the payment rate for services described by HCPCS code G0463 when billed with modifier ``PN''.? 9
PARA Weekly Update: August 22, 2018
OPPS PROPOSED RULE CUTS OFF-CAMPUS REIMBURSEMENT
And finally, in 2019, CMS intends to limit reimbursement of drugs purchased under the 340b drug discount program to the same rate paid in the on-campus setting (ASP ? 22%) when the drugs are dispensed at an non-excepted/non-grandfathered off-campus location. Non-excepted off-campus locations are not subject to the 340b reimbursement changes put in place as of 1/1/2018. Here is an excerpt in regard to the change in payment for drugs supplied under the 340b program at an off-campus location: ?? the difference in the payment amounts for 340B-acquired drugs furnished by hospital outpatient departments-- excepted off-campus PBDs versus nonexcepted off-campus PBDs--creates an incentive for hospitals to move drug administration services for 340B- acquired drugs to nonexcepted off-campus PBDs to receive a higher payment amount for these drugs, thereby undermining our goals of reducing beneficiary cost-sharing for these drugs and biologicals and moving towards site neutrality through the section 603 amendments to section 1833(t) of the Act. Therefore, for CY 2019, we are proposing changes to the Medicare Part B drug payment methodology for drugs and biologicals furnished and billed by nonexcepted off-campus departments of a hospital that were acquired under the 340B Program. Specifically, for CY 2019 and subsequent years, we are proposing to pay under the PFS the adjusted payment amount of ASP minus 22.5 percent for separately payable drugs and biologicals (other than drugs on pass-through payment status and vaccines) acquired under the 340B Program when they are furnished by nonexcepted off-campus PBDs of a hospital. Furthermore, in this CY 2019 OPPS/ASC proposed rule, we are proposing to except rural sole community hospitals, children's hospitals, and PPS-exempt cancer hospitals from this payment adjustment. We believe that our proposed payment policy would better reflect the resources and acquisition costs that nonexcepted off-campus PBDs incur for these drugs and biologicals.? The full text of the 2019 Medicare Physician Fee Schedule Proposed rule is available on the PARA Data Editor Advisor tab using the search phrase ?2019?:
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PARA Weekly Update: August 22, 2018
TECHNICAL CHANGE TO INPATIENT ORDERS RULE FOR 2019 IPPS
edicare published the 2019 Inpatient Prospective Payment System Final Rule at the link below: https://s3.amazonaws.com/public-inspection.federalregister.gov/2018-16766.pdf Among other changes in the Final Rule, Medicare provided new latitude for claim auditors in enforcing the IPPS requirement for signed and dated physician order to admit the patient to inpatient status by changing the language of regulations at 42 C.F.R. § 412.3(a). The language that Medicare will delete in the Code of Federal Regulations appears in strikethrough below: https://www.gpo.gov/fdsys/pkg/CFR-2013title42-vol2/pdf/CFR-2013-title42-vol2sec412-3.pdf § 412.3 Admissions. (a) For purposes of payment under Medicare Part A, an individual is considered an inpatient of a hospital, including a critical access hospital, if formally admitted as an inpatient pursuant to an order for inpatient admission by a physician or other qualified practitioner in accordance with this section and §§ 482.24(c), 482.12(c), and 485.638(a)(4)(iii) of this chapter for a critical access hospital. This physician order must be present in the medical record and be supported by the physician admission and progress notes, in order for the hospital to be paid for hospital inpatient services under Medicare Part A. In addition to these physician orders, inpatient rehabilitation facilities also must adhere to the admission requirements specified in § 412.622 of this chapter. Based on the proposal to change the regulatory language in the IPPS proposed rule for 2019, providers were optimistic that Medicare?s new regulation would permit hospitals to report services lacking an order to admit, but which otherwise qualify for inpatient status as inpatient admissions, and an inpatient encounter reimbursed under Part A. However, the final rule falls far short of providing the full extent of relief providers had hoped to gain. The responses provided by CMS to questions submitted by commenters indicate that the new language is intended primarily to allow medical review auditors more latitude in allowing payment under Part A if the physician order is incomplete in some technical respect, so long as the rest of the documentation in the medical record appears to support the physician?s intent to admit to inpatient status. In its responses to commenters on the proposed rule, CMS clearly does not invite hospitals to relax their current processes for obtaining a physician order as a condition of submitting a claim for inpatient reimbursement. Specifically, commenters asked if the new language allows for billing an inpatient-only procedure performed before the order to be an inpatient is placed as an inpatient claim, provided that the intent of the physician was to admit the patient; CMS did not fully understand this question, and therefore stated it would not address that comment.
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PARA Weekly Update: August 22, 2018
TECHNICAL CHANGE TO INPATIENT ORDERS RULE FOR 2019 IPPS
Commenters also questioned whether an outpatient stay could retroactively be deemed to be an inpatient stay (no); whether condition code 44 would continue to be required (CMS declined to address); and whether the new rule would be retroactive (no, it will not take effect until 10/1/18.) Here are excerpts from the section of the Final Rule which addresses this change, pages 1390 to 1407: ?? Common technical discrepancies consist of missing practitioner admission signatures, missing co-signatures or authentication signatures, and signatures occurring after discharge. We have become aware that, particularly during the case review process, these discrepancies have occasionally been the primary reason for denying Medicare payment of an individual claim. In looking to reduce unnecessary administrative burden on physicians and providers and having gained experience with the policy since it was implemented, we have concluded that if the hospital is operating in accordance with the hospital CoPs, medical reviews should primarily focus on whether the inpatient admission was medically reasonable and necessary rather than occasional inadvertent signature documentation issues unrelated to the Common technical discrepancies consist of missing practitioner medical necessity of admission signatures, missing co-signatures or authentication the inpatient stay. It signatures, and signatures occurring after discharge have become was not our intent when we finalized the occasionally been the primary reason for denying payment. admission order documentation requirements that they should by themselves lead to the denial of payment for medically reasonable and necessary inpatient stays, even if such denials occur infrequently. ?Therefore, in the FY 2019 IPPS/LTCH PPS proposed rule (83 FR 20447 and 20448), we proposed to revise the admission order documentation requirements by CMS-1694-F 1393 removing the requirement that written inpatient admission orders are a specific requirement for Medicare Part A payment. Specifically, we proposed to revise the inpatient admission order policy to no longer require a written inpatient admission order to be present in the medical record as a specific condition of Medicare Part A payment. Hospitals and physicians are still required to document relevant orders in the medical record to substantiate medical necessity requirements. If other available documentation, such as the physician certification statement when required, progress notes, or the medical record as a whole, supports that all the coverage criteria (including medical necessity) are met, and the hospital is operating in accordance with the hospital conditions of participation (CoPs), we stated that we believe it is no longer necessary to also require specific documentation requirements of inpatient admission orders as a condition of Medicare Part A payment. We stated that the proposal would not change the requirement that an individual is considered an inpatient if formally admitted as an inpatient under an order for inpatient admission. While this continues to be a requirement, as indicated earlier, technical discrepancies with the documentation of inpatient admission orders have led to the denial of otherwise medically necessary inpatient admission. To reduce this unnecessary administrative burden on physicians and providers, we proposed to no longer require that the specific documentation requirements of inpatient admission orders be present in the medical record as a condition of Medicare Part A payment. ?After consideration of the public comments we received, we are finalizing our proposal to revise the inpatient admission order policy to no longer require a written inpatient admission order to be present in the medical record as a specific condition of Medicare Part A payment. Specifically, we are finalizing our proposal to revise the regulation at 42 CFR 412.3(a) to remove the language stating that a physician order must be present in the medical record and be supported by the physician admission and progress notes, in order for the hospital to be paid for hospital inpatient services under Medicare Part A.? 12
PARA Weekly Update: August 22, 2018
RURAL HOSPITAL PROGRAM GRANTS AVAILABLE
Rural hospitals and clinics face their own set of unique and burdensome challenges when it comes to program development, cash management and maintaining volume. That's why it's great when they can get some assistance from external funding sources. At PARA, we've found an excellent source of funding opportunities for rural healthcare facilities. Here are some examples.
Healthy Tomorrows Partnership For Children Program - Supports community-based child health projects that improve the health status of mothers, infants, children, and adolescents in rural and other underserved communities by increasing their access to health services with funding of up to $50,000 for each of five years. - Application Deadline: October 1,2018
Montana Mental Health Trust Funding - Provide up to $500,000 of funding for programs, services, and resources for: - The prevention, treatment, and management of serious mental illness in Montana children and adults - Training and education for law enforcement personnel and more - Application Deadline: September 14, 2018
Service Area Funding For Health Center Programs - Provides $1,000,000 for Technologies for Improving Population Health and Eliminating Health Disparities to develop partnerships between innovative small business concerns and nonprofit research institutions resulting in improving minority health and the reduction of health disparities by commercializing innovative technologies. Rural populations are included in the listed health disparities priority populations. - Application Deadline: October 1, 2018
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PARA Weekly Update: August 22, 2018
MLN CONNECTS
PARA invites you to check out the mlnconnects page available from the Centers For Medicare and Medicaid (CMS). It's chock full of news and information, training opportunities, events and more! Each week PARA will bring you the latest news and links to available resources. Click each link or the PDF!
Thursday, August 16, 2018 News & Announcements · New Medicare Card: Order Handouts for Patients That Did Not Get Their New Cards · Proposed Pathways to Success for the Medicare Shared Savings Program · Quality Payment Program: Design Examples for CY 2019 Proposed Rule · Quality Payment Program: Participation Status Tool Includes 2018 Data Snapshot Provider Compliance · Cochlear Devices Replaced Without Cost: Bill Correctly ? Reminder Upcoming Events · Physician Fee Schedule Proposed Rule: Understanding 3 Key Topics Listening Session ? August 22 Medicare Learning Network® Publications & Multimedia · Inclusion of PMD Codes in DMEPOS Prior Authorization Program MLN Matters® Article ? New · Medicare Physician Fee Schedule Database: October 2018 Update MLN Matters Article ? New · Hospice Payment Rates, Cap, Wage Index, and Pricer: FY 2019 Update MLN Matters Article ? New · HCPCS Drug/Biological Code Changes: October 2018 Update MLN Matters Article ? New · 2018 DMEPOS Fee Schedule: October Update MLN Matters Article ? New · Advance Care Planning Fact Sheet ? Revised · PECOS for Physicians and NPPs Booklet ? Reminder · Medicare Enrollment for Institutional Providers Booklet ? Reminder · Medicare Part D Vaccines and Vaccine Administration Fact Sheet ? Reminder View this edition as a PDF [PDF, 298KB]
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PARA Weekly Update: August 22, 2018
MEDICARE PROPOSES TO CEASE THERAPY G-CODES IN 2019
In the 2019 Medicare Physician Fee Schedule Proposed Rule, Medicare announces its intention to cease requiring functional limitation G-code reporting for physical, occupational, and speech therapy services. Since OPPS facilities are paid for therapies under the MPFS, this change will apply to hospitals as well as independent therapy service locations. The full text of the 2019 Medicare Physician Fee Schedule Proposed rule is available on the PARA Data Editor Advisor tab using the search phrase ?2019?:
The following are pertinent excerpts from pages 390-395 of the rule: ?? we established our functional reporting claims-based data collection strategy effective January 1, 2013 in the CY 2013 PFS final rule (77 FR 689580 through 68978) and will have been collecting these functional reporting data for the last 5 years at the close of CY 2018. ? we reviewed and analyzed the data internally but did not find them particularly useful in considering how to reform payment for therapy services as an alternative to the therapy caps. ? ?? [The Middle Class Tax Relief and Jobs Creation Act (MCTRJCA) of 2012] did not specify how long the data collection strategy should last, we do not believe it was intended to last indefinitely. ? we do not believe that collecting additional years of functional reporting data in this reduced format would add utility to our data collection efforts. ?After consideration of these comments on the RFI along with a review of all of the requirements under section 3005(g) of MCTRJCA, and in light of the recent statutory amendments to section 1833(g) of the Act, we have concluded that continuing to collect more years of these functional reporting data, whether through the same or a reduced format, will not yield additional information that would be useful to inform future analyses, and that allowing the current functional reporting requirements to remain in place could result in unnecessary burden for providers of therapy services without providing further benefit to the Medicare program in the form of additional data. ?As a result, we are proposing to discontinue the functional reporting requirements for services furnished on or after January 1, 2019. ? ?If finalized, our proposal would end the requirements for the reporting and documentation of functional limitation G-codes (HCPCS codes G8978 through G8999 and G9158 through G9186) and severity modifiers (in the range CH through CN) for outpatient therapy claims with dates of service on and after January 1, 2019. Accordingly, with the conclusion of our functional reporting system for dates of service after December 31, 2018, we would delete the applicable non-payable HCPCS G-codes specifically developed to implement that system through the CY 2013 PFS final rule with comment period (77 FR 68598 through 68978). ?We are seeking comment on these proposals.? Comments on the Proposed Rule will be accepted by CMS prior to 5 PM EST on September 24, 2018. 15
PARA Weekly Update: August 22, 2018
PARA INTRODUCES NEW OUTPATIENT OUTMIGRATION REPORTS In their continuing expansion of product lines critical to streamlining hospital data collection and improving decision support tools for Chief Executive Officers, Chief Financial Officers and Business Development executives, PARA Analytics introduces the new Outpatient Migration Report. Among other items, PARA customers using this vital report will be able determine where patients in their primary and secondary service areas are going for outpatient services, total volumes of selected outpatient services and the value of these services. The Outpatient Migration Report provides information on Medicare Outpatient Visits and the patient?s county of residence. The source of this information is the Medicare Outpatient Limited Data Set. For the selected hospital, the top ten counties are identified based on the number of outpatient visits from those counties of residence. These counties are listed horizontally across an easy-to-read report. All facilities that had an outpatient visit from the selected hospital?s home county are listed vertically on the report and it then details how many outpatient visits to each facility originated from each of the ten corresponding counties. The Outpatient Migration Report includes ten tabs with this same format. The first tab includes statistics on all outpatient visits. The subsequent nine tabs include the visit counts that have been identified as specific visit types. These include: - Emergency, Mammography - CT - MRI - Therapy - GI - Diagnostic Radiology - Lab, and - Wound Care The final tab provides reference information on how outpatient visits are assigned to the preceding categories. If any of the listed codes appear on the claim, then the visit is assigned the corresponding label. PARA Analytics is the first national healthcare financial firm to develop such valuable reports in a more timely manner than data typically available from public sources. Using PARA?s proprietary algorithms in the PARA Data Editor, PARA can rapidly produce relevant and functional reports. For more information and a demonstration of these new reports, please contact PARA Account Executives: Violet Archuleta-Chiu, Senior Account Executive varchuleta@para-hcfs.com (800) 999-3332, ext. 219 Sandra LaPlace, Account Executive slaplace@para-hcfs.com (800) 999-3332, ext. 225 16
PARA Weekly Update: August 22, 2018
There were FOUR new or revised Med Learn (MLN Matters) articles released this week. To go to the full Med Learn document simply click on the screen shot or the link.
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FIND ALL THESE MED LEARNS IN THE ADVISOR TAB OF THE PDE
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PARA Weekly Update: August 22, 2018
The link to this Med Learn SE18011
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PARA Weekly Update: August 22, 2018
The link to this Med Learn M10863
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PARA Weekly Update: August 22, 2018
The link to this Med Learn MM10859
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PARA Weekly Update: August 22, 2018
The link to this Med Learn MM10542
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PARA Weekly Update: August 22, 2018
There were EIGHT new or revised Transmittals released this week. To go to the full Transmittal document simply click on the screen shot or the link.
8
FIND ALL THESE TRANSMITTALS IN THE ADVISOR TAB OF THE PDE
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PARA Weekly Update: August 22, 2018
The link to this Transmittal R2130OTN
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PARA Weekly Update: August 22, 2018
The link to this Transmittal R2132OTN
24
PARA Weekly Update: August 22, 2018
The link to this Transmittal R2133OTN
25
PARA Weekly Update: August 22, 2018
The link to this Transmittal R2131OTN
26
PARA Weekly Update: August 22, 2018
The link to this Transmittal R122MSP
27
PARA Weekly Update: August 22, 2018
The link to this Transmittal R123MSP
28
PARA Weekly Update: August 22, 2018
The link to this Transmittal R819PI
29
PARA Weekly Update: August 22, 2018
The link to this Transmittal R817PI
30
PARA Weekly Update: August 22, 2018
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