OMNIBUSBILL EXTENDS PHETELEHEALTH FLEXIBILITIES

The Omnibus Appropriations Bill (H R 26 passed on December 23, 2022, extended Medicare coverage of telehealth service flexibilities that were permitted during the Public Health Emergency through December 31, 2024.

https://www.appropriations.senate.gov/imo/media/doc/JRQ121922.PDF

Before publishing the 2023 Medicare Telehealth Services file, CMSreviewed telehealth services added during the Public Health Emergency. For each service, CMS determined each would be extended through the remainder of 2023, or the providers would be required to stop providing the service through telehealth five months after the PHEends

The Omnibus bill includes health provisions that extend those telehealth services through the end of the year 2024.

Included in Sec. 4113 of the Omnibus ? Advancing telehealth Beyond COVID-19, the 151-day period was replaced with the period beginning on the first day after the end of the PHEand ending on December 31, 2024

Extended Flexibilities include:

- The expansion of the telehealth originating site to include any site the patient is located, including the patient?s home, is extended through 2024

- The expansion of eligible practitioners who can furnish telehealth (including occupational therapists, physical therapists, speech-language pathologists and audiologists) will continue through 2024

- Rural health clinics (RHCs) and federally qualified health centers (FQHCs) may continue to furnish telehealth services through 2024

- The six-month in-person requirement for mental health services furnished through telehealth (including the in-person requirements for RHCs and FQHCs) is delayed until January 1, 2025

- Coverage and payment for telehealth furnished via audio-only during the PHEwill continue through 2024

- Telehealth to meet the face-to-face recertification requirement for hospice care is extended through 2024

HHScontinues to evaluate the fate of other clinician ?flexibilities?, as discussed in the following publication dated 2/1/2023: https://www cms gov/files/document/physicians-and-other-clinicians-cms-flexibilitiesfight-covid-19 pdf

Providers, billers, and coders who contend with National Correct Coding Initiative (NCCI) edits will be interested to learn that Medicare has acted to end its contract with the NCCI edit vendor, Capitol Bridge LLC, one year earlier than the performance period allowed in the original contract award.

In February, 2019, CMSawarded the contract for maintaining Correct Coding Inititiative edits, including Procedure-to-procedure (PTP) and Medically Unlikely Edits (MUE) to a small and disadvantaged business, Capitol Bridge, LLCThe contract was awarded for 60 months: https://www.fedhealthit.com/2019/02/cms-awards-15m-national-correct-coding-initiative/

In theory, the contract performance period could have continued until February of 2024; however, an automated reply to an email sent to the NCCI contractor?s contact address at NCCIPTPMUE@cms hhs gov informs the recipient that the contract ended on February 2, 2023:

Medicarecci Editcontractended

The HHScontract with Capitol Bridge, worth approximately $14.7 million dollars, is described on the Federal Procurement Data website as follows: https://www fpds gov/common/jsp/LaunchWebPage jsp?command=execute&requestid= 152090237&version=1 5

?National Correct Coding Initiative (NCCI): Promote program integrity and compliance through guidance, edits, and other methodologies that promote the consistent administration of CMS payment policies.?

The last entry regarding the contract on the Federal Procurement Data System website indicates that on October 17, 2022, the reason the contract was modified was ?Other Administrative Action ?

Medicarecci Editcontractended

Edits introduced by Capitol Bridge were sometimes inaccurate and disruptive.For example, in 2020, Capitol Bridge introduced several PTPedits that prevented hospitals and other providers from reporting together common and customary code pairs, such as:

-Nuclear medicine tests billed together with a radiopharmaceutical, (i e 78306 with A9503)

-Barium swallow testing (92611 with 74230);

-And PT/OT evaluations (97161-97163 and 97165-97168) billed on the same DOSas therapeutic activities (97530)

The edits were relaxed after an influx of complaints from providers and provider associations.

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Removal Ofncd And Expansion Ofcolorectal Cancerscreening

CMShas changed CMShas removed NCD and has expanded the coverage of colorectal cancer screening.

CMShas reduced the minimum age for coverage for the following CRCscreening tests (HCPCScodes G0104, G0106, G0120, G0327, G0328, 81528, and 82270) from 50 years to 45 years of age or older:

- Screening Flexible Sigmoidoscopy Test

- Screening Guaiac-based Fecal Occult Blood Test (gFOBT)

- Screening Immunoassay-based Fecal Occult Blood Test (iFOBT)

- Screening The Cologuard? ? Multi-target Stool DNA (sDNA) Test

- Screening Barium Enema Test - Screening Blood-based Biomarker Tests

A positive result from a non-invasive stool-based CRCscreening test no longer requires that the following colonoscopy be a diagnostic colonoscopy. CRCscreening tests now include a follow-on screening colonoscopy after a Medicare-covered, non-invasive, stool-based CRCscreening test returns a positive result

Screening colonoscopy continues to not have a minimum age limitation

Patient cost sharing won? t apply to the non-invasive, stool-based test and the follow-on screening colonoscopy in this scenario, because both are specified preventive screening services. The frequency limitations for screening colonoscopies in 42 CFR410.37(g) won? t apply to the follow-on screening colonoscopy that follows a positive result from a stool-based test

Attach the KXmodifier to a screening colonoscopy code to indicate such service was performed as a follow-on screening after a positive result from a stool-based test Our policy goal of not having frequency limitations to the follow-on screening colonoscopy after a non-invasive stool-based test returns a positive result is to remove barriers and encourage the patient to proceed to the colonoscopy procedure soon after the positive result from the stool-based test.

In Sum m ary: CMS has:

- Removed NCD 160 22 ? ambulatory electroencephalographic (EEG) monitoring

- Lowered the minimum age for colorectal cancer screening (CRC) from age 50 to 45 for certain tests

- Expanded the definition of CRCscreening tests and new billing instructions for colonoscopies under certain scenarios

- Updated three Medicare manuals

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, February 23, 2023

New s

-

Hospital Price Transparency: Progress & Commitment to Achieving Its Potential

- Home Infusion Therapy Services Monitoring Report

- Immunosuppressive Drugs: Comparative Billing Report in February

- Expanded Home Health Value-Based Purchasing Model Resources: Submit Feedback through March 31

Claim s, Pricers, & Codes

- HCPCSLevel II Coding: FAQs for Single Source Drugs & Biologicals

- National Correct Coding Initiative: No April Update

Publicat ions

- DMEPOSQuality Standards ? Revised

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!

Monday, February 27, 2023

New s

COVID-19 Public Health Emergency (PHE) New Overview Fact Sheet

As part of the Centers for Medicare & Medicaid Services?(CMS) ongoing efforts to provide up-to-date information to prepare for the end of the Public Health Emergency (PHE) for COVID-19, which is expected on May 11, 2023, we are providing a new overview fact sheet on CMSWaivers, Flexibilities, and the Transition Forward from the COVID-19 Public Health Emergency COVID-19 efforts have been a significant priority for the Biden-Harris Administration, and with the use of whole-of-government approach, the country is in a better place.

Over the next several months, CMSwill work to ensure a smooth transition back to normal operations.

The CMS Waivers, Flexibilit ies, and t he Transit ion Forw ard from t he COVID-19 Public Healt h Em ergency provides clarit y on several t opics including:

- COVID-19 vaccines, testing, and treatments;

- Telehealth services;

- Health Care Access

- In the coming weeks, CMSwill be hosting stakeholder calls and office hours to provide additional information. Please visit the CMSEmergencies Page for continuous updates regarding PHEsunsetting guidance as information becomes available to the public.