1 august 17,2022 j our nale What It MeansFor HealthCare T he E d uc at ion E d it ion TheInflation Reduction Act CDI InSimpleTerms Clinical Documentation TheExplanationAndTheSolution PARA'sNSA App
2 PARA Weekly eJournal: August 17, 2022 Q. Please advise if regular E&M codes (99202, 99213) can be used for behavioral health telehealth visits in the RHCsetting. A. No, the E/M codes 99202-99215 are not appropriate reporting RHCmental health services provided by telemedicine RHC?s should report one of the mental health service codes from the RHCQualifying Visit List with modifier CG, as well as modifier 95 or FQ, in keeping with CMS instructions on mental health visits provided over telehealth in MLN Matters Number SE22001: https://www cms gov/files/document/se22001 mental health visits telecommunications rural health clinics federally qualified health pdfa RHCMENTAL HEALTH TELEHEALTH SERVICESBILLING
3 PARA Weekly eJournal: August 17, 2022 A link and an excerpt from the list of RHC?Qualifying Visits?is provided below: https://www cms gov/Medicare/Medicare-Fee-for-Service-Payment/FQHCPPS/ Downloads/RHC-Qualifying-Visit-List.pdf RHCMENTAL HEALTH TELEHEALTH SERVICESBILLING
4 PARA Weekly eJournal: August 17, 2022 Here?s an excerpt from the CMSRural Health Clinics Center web page describing the change in policy that became effective 1/1/2022 ? please note the ?in-person?visit requirements: https://www.cms.gov/Center/Provider Type/Rural Health Clinics Center Only mental health services may be reported with an RHCqualifying visit HCPCSwhen provided over telemedicine; all other telemedicine services provided by an RHCpractitioner should be reported with HCPCSG2025 Additional information regarding RHCtelehealth services is available on MLN Matters article SE20016 (Revised 1/13/2022): www.cms.gov/files/document/se20016 new expanded flexibilities rhcs fqhcs during covid 19 phe pdf RHCMENTAL HEALTH TELEHEALTH SERVICESBILLING
5 PARA Weekly eJournal: August 17, 2022 Over the next few weeks your ParaRev team will begin sending communications via a new email address. As a CorroHealth company, ParaRev team members are moving to a CorroHealth email address. To avoid breaks in communication, any emails sent to existing @ParaRevenue.com will still be delivered directly to the team. However, you will see replies to your emails coming from this new @CorroHealth com email address What do you need t o do now ? You need only ask your IT department to add CorroHealth.com to your safe list for email. This helps ensure communications are not relegated to a junk folder in your inbox. What do you need t o do lat er? As you receive emails from the team?s new @CorroHealth.com email address, please update any contact information within your system. The email nomenclature will follow the use of FirstName LastName@CorroHealth com What ot her changes are expect ed w it h ParaRev joining CorroHealt h? You will continue to work with the same, trusted team and solutions you have today. However, in October 2022, you will see the addition of ParaRev solutions to the CorroHealth website at www.CorroHealth.com. These solutions will be housed within a larger set of Revenue Cycle offerings Client logins and necessary contact information for the organization will be available on both the updated CorroHealth site and the ParaRev site Where can w e find out m ore det ails on t he acquisit ion? More information on the acquisition can be found in this most recent press release: https://www businesswire com/news/home/20220518005047/en/ParaRev Joins CorroHealth Please do not hesitate to reach out to us if you have any questions or need additional assistance. CorroHealth info@CorroHealth com www CorroHealth com ANNOUNCINGA NEW ACQUISITION: STRENGTHENINGPARTNERSHIPS +
ASseen in Beckers Hospital Review Molly Gamble (Twitter) yesterday
6 PARA Weekly eJournal: August 17, 2022
THEINFLATION REDUCTION ACT: SEVEN HEALTHCARETAKEAWAYS
4 Effective in 2024, the IRA eliminates the 5 percent cost sharing in the catastrophic phase of Medicare Part D, which kicks in after enrollees reach $7,050 in out-of-pocket costs for covered drugs. Effective in 2025, the law caps patients' out of pocket costs in Part D at $2,000.
. Under the IRA, Medicare Parts B and D gain negotiation powers that will apply to the price of a limited number of drugs with no generic or biosimilar competition. Starting in 2026, 10 drugs will be eligible for negotiations Eligibility expands to 20 drugs by 2029
6 The law includes a cap in Part D premium cost growth at 6 percent from 2024 to 2029 to prevent large premium increases.
7 Premium subsidies in the ACA marketplaces that were increased by the 2021 American Rescue Plan Act were set to expire at the end of 2022. The IRA extends the subsidies through 2025, which will prevent millions of people from losing coverage and seeing increases to their premiums
1
2 The law ends a 19 year old ban on Medicare from negotiating the price of prescription medicines with manufacturers The government was prohibited from directly negotiating drug prices in Medicare Part D, the prescription drug coverage program created in 2003.
Thesweeping$739bil l ionr econcil iat ionpackagecontainsanumber of significant healt hcar epr ovisions. During the signing ceremony in the State Dining Room, the president described the IRA as "one of the most significant laws in our history" and with its enactment "the American people won and special interests lost." Here are seven healthcare takeaways from the IRA:
3. Starting in 2023, the IRA limits out-of-pocket spending on insulin products in Medicare Part D to $35 per month It also eliminates cost sharing for adult vaccines under Medicare Part D and under Medicaid
Pr esident JoeBidensignedt heInfl at ionReduct ionAct int ol awAug 16
5. The IRA institutes inflation caps in Medicare Part D that limit price increases for drugs year over year Drugmakers face tax penalties if their price increases to prescription drugs in Medicare outpace the rate of inflation
- Current requirements for providers to deliver a Notice and Consent (NAC) form for insured patients who choose to continue with out of network care in an out of network facility
NAVIGATINGTHENO SURPRISESACTMAZE
- Current requirements for providers to produce a Good Faith Estimate for uninsured patients
These included: - The Trump Administration first introduced legislation requiring hospitals to publish their pricing effective January 1, 2021 The No Surprises Act of January 1, 2022 protecting insured patients from balanced billing in cases of emergency or when required to use out of network care at an in network facility
7 PARA Weekly eJournal: August 17, 2022
Hist ory of t he No Surprises Act Effective January 1 of 2023, the latest installment of No Surprises Act stipulates that affiliated co-providers will become responsible for producing their own Good Faith Estimates (GFEs). These affiliated co providers, such as anesthesiologists and pathologists, practice in hospitals but handle their own billing. In 2023, the convening provider who schedules the surgery or appointment must take the GFEs produced by affiliated co providers and their own GFEand combine them into a consolidated Good Faith Estimate These Good Faith Estimates will be required for both uninsured and insured patients. These upcoming changes will mark the most recent phase of a series of regulations designed to increase transparency in the healthcare industry
Even for providers familiar with GFEand NACproduction, the pure increase in quantity of GFEs and NACs needing to be produced is sure to overwhelm their systems
The Solut ion ParaRev offers software seamlessly that creates customized GFEs, and an application for convening and affiliated co providers to collectively produce a consolidated Good Faith Estimate By providing a central location for the upload of these documents, PARA?s application manages and simplifies the logistics and communication between busy and understaffed healthcare providers, helping all parties to comply with 2023 NSA regulations and avoid fines
What does t his m ean? Come January 1, 2023, all the responsibilities required of convening providers will be extended to affiliated co providers, making them equal partners in compliance 2023 regulations stipulate that GFEs must be produced for all patients, regardless of insurance status
8 PARA Weekly eJournal: August 17, 2022
Regulations call for the creation of NACs and GFEs for all patients, both insured and uninsured
Like all group projects, the shared creation of consolidated GFEs (and NACs) between convening providers and affiliated co providers will require extensive communication, cooperation, and flexibility.Without an established and shared document management system that records a paper trail of requests and fulfillments, providers face the logistical nightmare of trying to coordinate and produce an already complex and now consolidated regulatory document.
CMSis incredibly particular about not just what information providers must supply, but how it is presented The complex and convoluted regulations are constantly changing and evolving as interpretations differ and legal questions arise Healthcare providers truly require a dedicated team with the regulatory expertise to ensure that they remain in compliance Unfortunately, many providers lack the bandwidth and resources to dedicate a team solely to CMScompliance Combined with years of disregard to impending NSA regulations, affiliated co providers risk finding themselves swamped by compliance catch up work
Affiliated Co-ProvidersareUnaware
NAVIGATINGTHENO SURPRISESACTMAZE
TheRegulation RequiresFocusand Expertise
The Issue of addressing t he 2023 No Surprises Act
Since the inception of pricing transparency regulations in 2020, affiliated co-providers have faced no regulatory scrutiny. All compliance responsibilities have fallen upon convening providers. As a result, the legal requirements of the No Surprises Act are not even on the radar of most affiliated co-providers.
TheQuantityof Workisa LogisticNightmare
For the few who are aware, a series of delays and leniency from CMShas given the impression that enforcement will never come This attitude leaves affiliated providers inexperienced and unprepared to face impending 2023 regulations
WHATISCDI?AN
Int heCDIpr ofession,acommonquest
9 PARA Weekly eJournal: August 17, 2022
CorroHealth Director of CDI, Autumn Reiter, has always answered this question with a metaphor that tends to work well ?CDISare editors to each chapter in the book that is the patient?s story?, according to Autumn These edits are essential!
ionfr omt hosenot in t hehealt hcar eindust ryis, ?What doCDIpr ofessional s do andwhyar et hey important ??
Regardless of insurance payer or the statistics being analyzed, each patient has a story that needs to be told accurately With each story, like any you hear in life, you want the correct version recounted The story needs to be told with precise detail and accuracy Consider the patient journey like a biography; the author is the physician, the patient is the life account being written about, and CDI serves as the editor. ARTICULATEAPPROACH
#1 Resource Ut ilizat ion
#2 Qualit y Mat rix When we see something in the record that does not make sense, just like an editor altering a story, the CDI specialist should ask ?why?? Let us use Pneumonia for instance What risk factors does the patient have?Was it present on admission, or did it develop after admission?What antibiotics are being used to treat it? At times, these are the additional types of questions that would need to be asked With the questions comes clarity in the patient?s story
WHATISCDI?AN ARTICULATEAPPROACH
10 PARA Weekly eJournal: August 17, 2022
#3 Appropriat e St at us and Lengt h of St ay Documentation can determine whether a patient?s admission status is appropriate Should the patient be registered as inpatient or outpatient?The detail of the records can help determine and justify the choice, or how the choice could have been different if additional documentation was present We have one chance to be as accurate as possible The assistance of CDI specialists can place significance on those details where they might otherwise be missed.
While most of the examples above are circumstantial, the bottom line is the importance of CDI programs in our facilities will always remain. In many cases, the lack of a CDI program can mean missed opportunity to appropriately evaluate the severity of illness, risk of mortality, and quality data that is essential to our healthcare success. We want to make sure appropriate resource utilization takes place, and that quality of care is documented. This is not to say that there is an underlying ?issue?that needs to be found in every CDI department; but there are always instances where we can work together to better document the patient?s story
Making sure that the diagnosis is clearly stated in turn helps justify treatment that is given to a patient Here is an example: Shortness of breath alone does not seem to reflect the need for BiPAP(or BPAP, Bilevel Positive Airway Pressure) use. There is likely a more specific diagnosis present that is causing the shortness of breath if that level of treatment is needed.
Being an editor, a CDIS?role is to question the cause and help define what the etiology of the shortness of breath in this situation truly is CDIScan match clinical experience, with documentation and coding knowledge, to clarify the medical necessity of the treatment and support the severity of the patient.
11 PARA Weekly eJournal: August 17, 2022 This is it .Par aRev hascompl et ely updat edit s Compr ehensive COVID-19Guide.TheGuidecontains detail edinfor mat ionabout bil l ingandcoding,t est ingandot her guidancer el at edt oCOVID-19. It's online. You can download it by clicking the image to the right, or by clicking the URL here: https://apps.parahcfs.com/para/ Documents/ 2022%20Comprehensive% 20Covid-19%20Guide pdf COMPLETELY UPDATED: COMPREHENSIVECOVID 19 GUIDE
12 PARA Weekly eJournal: August 17, 2022 MLN CONNECTS PARA invit es you t o check out t he m lnconnect s page available from t he Cent ers For Medicare and Medicaid (CMS) It 's chock full of new s and inform at ion, t raining opport unit ies, event s and m ore! Each w eek PARA w ill bring you t he lat est new s and links t o available resources Click each link for t he PDF! Thursday, August 11, 2022 New s Monkeypox & Smallpox Vaccines: New Product Codes - Payment Allowance Update for COVID-19 Monoclonal Antibody Therapy Q0222 Injection, Bebtelovimab, 175 mg CMSAnnounces Resources & Flexibilities to Assist Kentucky Due to Recent Storms - Hospice Quality Reporting Program: Measure Change Com pliance What?s the Comprehensive Error Rate Testing Program? Claim s, Pricers, & Codes Quarterly Update to the Medicare Physician Fee Schedule Database (MPFSDB) October 2022 Integrated Outpatient Code Editor: Java Beta File Release MLN Mat t ers® Art icles - Inpatient Psychiatric Facilities Prospective Payment System (IPFPPS) Updates for Fiscal Year (FY) 2023 Inpatient Rehabilitation Facility (IRF) Annual Update: Prospective Payment System (PPS) Pricer Changes for FY2023 New Waived Tests - Implementation of the Capital Related Assets (CRA) Adjustment for the Transitional Add-on Payment Adjustment for New and Innovative Equipment and Supplies (TPNIES) Under the End Stage Renal Disease Prospective Payment System (ESRD PPS) ? Revised
13 PARA Weekly eJournal: August 17, 2022 Therew ereFIVEnew or revised Transmittalsreleased thisw eek. To go to thefull Transmittal document simply click on thescreen shot or thelink. 5 t r ans mit t al s
14 PARA Weekly eJournal: August 17, 2022 TRANSMITTAL R11550MSP
15 PARA Weekly eJournal: August 17, 2022 TRANSMITTAL R11551CP
16 PARA Weekly eJournal: August 17, 2022 TRANSMITTAL R11553DEMO
17 PARA Weekly eJournal: August 17, 2022 TRANSMITTAL R11552CP
18 PARA Weekly eJournal: August 17, 2022 TRANSMITTAL R11549CP
19 PARA Weekly eJournal: August 17, 2022 3 m edl ear ns Therew ereTHREEnew or revised MedLearn released thisw eek. To go to thefull Transmittal document simply click on thescreen shot or thelink.
20 PARA Weekly eJournal: August 17, 2022 MEDLEARN MM12765
21 PARA Weekly eJournal: August 17, 2022 MEDLEARN MM12870
22 PARA Weekly eJournal: August 17, 2022 MEDLEARN MM12274
Theprecedingmaterialsare for instructional purposesonly. Theinformation ispresented "as-is"and to the best of ParaRev?s knowledgeisaccurate at thetime of distribution. However, dueto theever changing legal/regulatorylandscapethisinformation issubject to modification, asstatutes/laws/regulationsor other updatesbecomeavailable. Nothingherein constitutes, isintended to constitute, or should berelied on as, legal advice ParaRev expressly disclaimsanyresponsibilityfor anydirect or consequential damagesrelated in anywayto anythingcontained in thematerials, which areprovided on an ?as-is?basisand should beindependentlyverified beforebeing applied. You expresslyaccept and agree to thisabsoluteand unqualified disclaimer of liability.Theinformation in this document isconfidential and proprietaryto ParaRev and isintended onlyfor thenamed recipient. No part of thisdocument maybereproduced or distributed without expresspermission. Permission to reproduce or transmit in anyform or byanymeanselectronicor mechanical, includingpresenting, photocopying, recording and broadcasting, or byanyinformation storageand retrieval system must be obtained in writingfrom ParaRev. Request for permission should be directed to sales@pararevenue.com. ParaRev is excited to announce we have joined industry leader CorroHealt h to enhance the reach of our offerings! ParaRev services lines are additive in nature strengthening CorroHealt h?s impact to clients?revenue cycle. In addition, you now have access to a robust set of mid cycle tools and solutions from CorroHealt h that complement ParaRev offerings In terms of the impact you?ll see, there will be no change to the management or services we provide The shared passion, philosophy and cultures of our organizations makes this exciting news for our team and you, our clients While you can review the CorroHealt h site HERE, we can coordinate a deeper dive into any of these solutions Simply let us know and we?ll set up a meeting to connect. As always, we are available to answer any questions you may have regarding this news We thank you for your continued partnership
FORYOURINFORMATION
23 PARA Weekly eJournal: August 17, 2022
