ParaRev Weekly eJournal, April 5, 2023

IV UNDERULTRASOUND

Quest ion: Can w e bill CPT® 36000 and add-on code +76937 for all IV st art ed w it h ult rasound? We are t rying t o det erm ine if t here w ould be added revenue from billing for t his service

Answ er: No, it is not appropriate to charge 36000 for all IVs started with ultrasound.

If the patient is receiving hydration therapy or infused medications, the IVstart is included in those services, so it should not be charged separately Please see the ParaRev paper linked below regarding billing for IVhydration and infusions:

Hydration, IVInfusions, Injections and Vaccine Charge Process

Additionally, the National Correct Coding Policy Manual (Chapter 1) states the following:

?Intravenous access (e g , CPT® codes 36000, 36400, 36410) is not separately reportable when performed with many types of procedures (e.g., surgical procedures, anesthesia procedures, radiological procedures requiring intravenous contrast, nuclear medicine procedures requiring intravenous radiopharmaceutical) ?

?CPT® code 36000 may be reported alone if t he only service provided is t he int roduct ion of a needle int o a vein ?

Under Medicare?s hospital outpatient reimbursement methodology, code 36000 is packaged and is not reimbursed separately (as seen in the Calculator tab of the PARA Dat a Edit or):

IV UNDERULTRASOUND

Code +76937 (ultrasound guidance for vascular access) requires:

- Documentation of evaluation of potential access sites

- Description of selected vessel patency

- Concurrent real-time ultrasound visualization of needle entry

- Acquisition and storage of a film or digital perm anent im age documenting the guidance procedure

This code should not be reported when a hand-held ultrasound device is used but the above documentation requirements are not met (e.g., no documentation of vessel patency, no permanent image).

Per the CPT® Manual:

?Ultrasound guidance procedures also requireperm anent ly recorded im ages of t he sit e t o be localized, as w ell as a docum ent ed descript ion of t he localizat ion process, either separately or within the report of the procedure for which the guidance is utilized Use of ult rasound, w it hout t horough evaluat ion of organ(s) or anat om ic region, im age docum ent at ion, and final, w rit t en report , is not separat ely report able.?

+76937 is an add-on code that must be reported in addition to a primary procedure code. If the 36000 is unable to be billed (as above), the +76937 would also not be able to be charged (even if the above documentation requirements are met) since there is no corresponding primary procedure.

Code +76937 does not carry additional reimbursement under HOPPS, but CAH may receive reimbursement for this service when performed and documented appropriately

For additional information regarding billing for ultrasound guidance in the hospital setting, please see the ParaRev paper linked below, which is also available in the Advisor tab of the PARA Dat a Edit or:

Ultrasound Guidance in the Hospital Setting

Theprecedingmaterialsare for instructional purposesonly. Theinformation ispresented "as-is"and to thebest of CorroHealth'sknowledgeisaccurateat the timeof distribution However, dueto the ever-changinglegal/regulatory landscape, thisinformation issubject to modification asstatutes, laws, regulations, and/or other updatesbecome available. Nothingherein constitutes, isintended to constitute, or should berelied on aslegal advice. CorroHealth expressly disclaimsanyresponsibilityfor anydirect or consequential damagesrelated in anywayto anythingcontained in the materials, which are provided on an "as-is"basisand should beindependentlyverified beforebeingapplied. You expressly accept and agreeto thisabsoluteand unqualified disclaimer of liability Theinformation in thisdocument isconfidential and proprietaryto CorroHealth and isintended onlyfor thenamed recipient. No part of thisdocument maybereproduced or distributed without expresspermission. Permission to reproduceor transmit in anyform or byanymeanselectronicor mechanical, includingpresenting, photocopying, recordingand broadcasting, or byanyinformation storageand retrieval system must beobtained in writingfrom CorroHealth. Request for permission should bedirected to Info@Corrohealth.com.

CPT® is a registered trademark of the American Medical Association

CMSRELEASESINITIAL GUIDANCEFORMEDICAREDRUGPRICENEGOTIATION

The Centers for Medicare & Medicaid Services (CMS) has released initial guidance detailing the requirements and parameters for the new Medicare Drug Price Negotiation Program. This program was established through President Biden's Inflation Reduction Act (IRA) to enable Medicare to negotiate lower prescription drug prices for the first time. The negotiation process will consider clinical benefit, unmet medical need, and impact on Medicare beneficiaries The program will result in lower prices for selected high-cost drugs, effective January 2026

CMSis seeking public comment on several key elements of the program, with a deadline of April 14, 2023 In addition, the Inflation Reduction Act has established the Medicare Prescription Drug Inflation Rebate Program, which will lower prescription drug costs for some Medicare beneficiaries starting April 1, 2023.

Inflation Reduction Act Tamps Down on Prescription Drug Price Increases Above Inflation | CMS

CMSRELEASESINITIAL GUIDANCEFORMEDICAREDRUGPRICENEGOTIATION

Medicare Drug Price Negotiation Program: Initial Memorandum, Implementation of Sections 1191 ? 1198 of the Social Security Act for Initial Price Applicability Year 2026, and Solicitation of Comments (cms.gov)

This guidance is the first part of several measures that CMShas outlined in the timeline for the Medicare Drug Price Negotiation Program's inaugural year of negotiation. The initial guidance for the program explains the prerequisites and processes for establishing the new Negotiation Program during the first round of negotiations These negotiations are scheduled for 2023 and 2024, and the resulting prices will take effect in 2026

Key dates for program implementation are as follows:

- By Sept em ber 1, 2023, CMSwill publish the first 10 Medicare Part D drugs selected for initial price applicability year 2026 under the Medicare Drug Price Negotiation Program

- The negotiated maximum fair prices for these drugs will be published by Sept em ber 1, 2024, and prices will go into effect January 1, 2026 Going forward, CMSwill select for negotiation up to 15 more Part D drugs for 2027, up to 15 more Part B or Part D drugs for 2028, and up to 20 more Part B or Part D drugs for each year after that, as outlined in the Inflation Reduction Act

CMSRELEASESINITIAL GUIDANCEFORMEDICAREDRUGPRICENEGOTIATION

- The negotiated maximum fair prices for these drugs will be published by Sept em ber 1, 2024, and prices will go into effect January 1, 2026.Going forward, CMSwill select for negotiation up to 15 more Part D drugs for 2027, up to 15 more Part B or Part D drugs for 2028, and up to 20 more Part B or Part D drugs for each year after that, as outlined in the Inflation Reduction Act

Medicare Drug Price Negotiation Program Timeline (cms.gov)

CMShas also published a Fact Sheet regarding Medicare Drug Price Negotiation Program Initial Guidance:

Additionally, CMShas released an MLN Connects article pertaining to this initial guidance:

https://www.cms.gov/outreach-and-education/outreach/ffsprovpartprog/ provider-partnership-email-archive/2023-03-15-oce

CMSRELEASESINITIAL GUIDANCEFORMEDICAREDRUGPRICENEGOTIATION

CMShas released information about the 27 Part B drugs and biological products with reduced coinsurance beginning April 1, 2023 under the Medicare Prescription Drug Inflation Rebate Program in the quarterly ASP public file:

Further information can also be found on the Medicare Part B Drug Average Sales Price webpage: Medicare Part B Drug Average Sales Price | CMS

CODINGFORCENTRAL VENOUSCATHETERPROCEDURES

Int roduct ion:

The experts at CorroHealth have developed a new and comprehensive coding practices booklet covering Central Venous Catheter procedures.

Just t ake a look at t he Table of Cont ent s!

On March 9, 2023, the U S Food and Drug Administration issued revised regulations for mammography. Effective September 10, 2024, mammography centers must inform patients about their breast density. The FDA has also enhanced its supervision and enforcement of these facilities and is assisting radiologists in accurately evaluating and categorizing mammograms. https://public-inspection.federalregister.gov/2023-04550.pdf

These regulations were issued under the Mammography Quality Standards Act (MQSA) of 1992 The MQSA oversees accreditation, certification, annual inspections, and enforcement of standards for mammography facilities

Dense breast tissue lowers the sensitivity of mammography studies Notifying patients of their breast density will offer additional information regarding the potential limitations of their mammogram results It will also allow patients and their healthcare providers to make informed decisions about ordering additional tests and discuss their individual risk for breast cancer.

The MQSA Final Rule outlines the specific requirements for reporting breast density and the standardized language which should be used The above amendments to MQSA must be implemented within 18 months (by September 10, 2024). According to the FDA, these new regulations will improve the examination of mammography practices and the exchange of information with patients and providers

According to an MLN Fact Sheet published in December, 2022, Medicare will require all 340(B) entities, including Critical Access Hospitals, which submit claims for separately payable Part B drugs and biologicals to report modifier ?JG?or ?TB?on claim lines for drugs acquired through the 340(B) discount program.

The MLN is available at the following website:

www cms gov/files/document/mln4800856-medicare-part-b-inflation-rebate-guidance-use340b-modifier pdf

ALL FACILITIESREQUIRED TO REPORT340B MODIFIERSIN 2024

This is a substantial change from the original 340B billing requirement Previously, Critical Access Hospitals and Maryland All-Payer or Total Cost of Care Model hospitals were not required to report a modifier on 340(B) drugs. CMSissued a companion ?FAQ?document which reiterates this point:

https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/HospitalOutpatientPPS/ Downloads/Billing-340B-Modifiers-under-Hospital-OPPS.pdf

ALL FACILITIESREQUIRED TO REPORT340B MODIFIERSIN 2024

The FAQ document provides a table summarizing the requirement for affected provider types:

The modifier requirement does not apply to all drugs purchased under 340(B), although hospitals may opt to report the modifier for all 340B drugs. The obligation to append a modifier applies to only Part B drugs and biologicals assigned OPPSStatus Indicator G or K(?separately payable?under OPPS.)

PARA Dat a Edit or users may identify the line items within the hospital charge master which are separately payable drugs by navigating to the ?Filters?tab, clicking the checkbox next to ?Status Indicator?, and clicking on both status G and status K, as illustrated below:

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, March 30, 2023

New s

-

COVID-19: Booster Dose for Children 6 months ? 4 years

- Identity & Access Management System: Easier for Surrogates

- Medicare Advantage Value-Based Insurance Design Model Extended

- Supplemental Security Income & Medicare Beneficiary Data: FY2021

-

DMEPOSfor Skilled Nursing Facility: Pre-Discharge Delivery for Fitting & Training

Claim s, Pricers, & Codes

-

COVID-19: Reporting CRModifier & DRCondition Code After Public Health Emergency

-

April 2023 Quarterly Pricing File Revisions

MLN Mat t ers® Art icles

- Medicare Part B Coverage of Pneumococcal Vaccinations

- Supervision Requirements for Diagnostic Tests: Manual Update

Publicat ions & Mult im edia

- Post-Acute Care Quality Reporting Program: Videos & Patient Cue Cards

t r ans mit t al s

Therew ereFOUR new or revised Transmittalsreleased thisw eek.

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

TRANSMITTAL R11912OTN

TRANSMITTAL R493PR1

TRANSMITTAL R126MCM

TRANSMITTAL R11937CP

1 m edl ear ns

Therew asONEnew or revised MedLearnsreleased thisw eek.

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

Theprecedingmaterialsare for instructional purposesonly. Theinformation ispresented "as-is"and to 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