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April 2024 Compliance Education and Other Updates
Published on Apr 24, 2024
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Compliance Education Updates

March 2024: MLN8659122: MLN Fact Sheet Original Medicare vs. Medicare Advantage Updated

CMS updated the payment rules for patients enrolled in Medicare Advantage Organizations. https://www.cms.gov/files/document/mln8659122-original-medicare-vs-medicare-advantage.pdf

 

April 2024: MLN Educational Tool Medicare Preventive Services Revised

CMS has revised this tool to clarify social determinants of health information, add a link to the most current and comprehensive list of ICD-10 codes for bone mass measurement and colorectal cancer screening, add coding, coverage, and payment information for COVID-19 vaccine and administration, and replace Hepatis B information with a link to the Hepatitis B screening service. https://www.cms.gov/Medicare/Prevention/PrevntionGenInfo/medicare-preventive-services/MPS-QuickReferenceChart-1.html

 

Other Updates

March 26, 2024: GAO Improper Payments: Information on Agencies’ Fiscal Year 2023 Estimates

In this report the Government Accountability Office (GAO) indicates the importance of this information due to the fact that “improper payments – those that should not have been made or were made in the incorrect amount – have consistently been a government-wide issue. Since fiscal year 2003, cumulative improper payment estimated by executive branch agencies have totaled about $2.7 trillion. Reducing improper payments is critical to safeguarding federal funds.” With an estimated $51 billion in estimated improper payments HHC’s Medicare (Medicare Fee-for-Service (Parts A and B), Medicare Advantage (Part C), and Medicare Prescription Drug (Part D)) had the highest estimated improper payments across 14 government agencies.

https://www.gao.gov/assets/d24106927.pdf?emci=4185bdfa-36ed-ee11-aaf0-002248223794&emdi=645794fb-40ed-ee11-aaf0-002248223794&ceid=7931774

 

March 27, 2024: CMS Releases FY 2025 Inpatient Rehabilitation Facility Prospective Payment System Proposed Rule (CMS-1804-P)

CMS is proposing to update payment rates by 2.8 percent. This proposed rule includes annual updates to the prospective payment rates, the outlier threshold, the case-mix-group relative weights and average length of stay values, the wage index, associated impact analysis, and IRF Quality Reporting Program (QRP). Also included are two requests for information (RFIs) (1) Future Measure Concepts for the IRF QRP, and (2) Creating and IRF QRP Star Rating System.

 

CMS Fact Sheet: https://www.cms.gov/newsroom/fact-sheets/fiscal-year-2025-inpatient-rehabilitation-facility-prospective-payment-system-proposed-rule-cms-1804

 

CMS Proposed Rule: https://www.cms.gov/medicare/payment/prospective-payment-systems/inpatient-rehabilitation/rules-related-files/cms-1804-p

 

IRF QRP webpage: https://www.cms.gov/medicare/quality/inpatient-rehabilitation-facility

 

March 28, 2024: CMS Issues 3 FY 2025 Proposed Rules: SNF, Inpatient Psych and Hospice

FY 2025 Skilled Nursing Facility Prospective Payment System Proposed Rule (CMS 1802-P) CMS Fact Sheet: https://www.cms.gov/newsroom/fact-sheets/fy-25-skilled-nursing-facility-prospective-payment-system-proposed-rule-cms-1802-p

 

FY 2025 Medicare Inpatient Psychiatric Facilities Prospective Payment System (IPF PPS) and Quality Reporting (IPFQR) Updates Proposed Rule (CMS-1806-P) CMS Fact Sheet: https://www.cms.gov/newsroom/fact-sheets/fiscal-year-2025-medicare-inpatient-psychiatric-facilities-prospective-payment-system-ipf-pps-and

  • Of note, CMS has proposed to increase the per treatment amount for electroconvulsive therapy (ECT) from the current FY 2024 payment per treatment of $385.58 to $660.30. CMS believes this increase would help ensure that patients who need ECT are more able to access it. (ECT CPT 90870)

 

FY 2025 Hospice Payment Rate Update Proposed Rule (CMS-1810-P) CMS Fact Sheet: https://www.cms.gov/newsroom/fact-sheets/fiscal-year-fy-2025-hospice-payment-rate-update-proposed-rule-cms-1810-p

Beth Cobb

April 2024 MLN Article and Coverage Updates
Published on Apr 24, 2024
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Medicare MLN Articles

March 20, 2024: MLN MM11003: Electronic Medical Documentation Requests via the Electronic Submission of Medical Documentation System – Revised

This MLN was first released February 1, 2019. In the March 20, 2024 revision to this article, CMS has added information about the implementation of a new feature to accept review outcome letters during October 2023 release. https://www.cms.gov/outreach-and-education/medicare-learning-network-mln/mlnmattersarticles/downloads/mm11003.pdf

 

April 4, 2024: MLN MM13577: Ambulatory Surgical Center Payment Update – April 2024

Make sure your billing staff knows about new CPT and HCPCS codes, Device code changes, iDose TR (travoprost intracameral implant) for the treatment of glaucoma, Drug and biological code changes, and Skin code updates. https://www.cms.gov/files/document/mm13577-ambulatory-surgical-center-payment-update-april-2024.pdf

 

April 15, 2024: MLN MM13574: DMEPOS Fee Schedule: April 2024 Quarterly Update – Revised

This MLN article was revised on April 15th to show the addition of 4 HCPCS Level II codes to Common Working File category 58. CMS also revised the effective date and the web address of Change Request (CR) 13574). https://www.cms.gov/files/document/mm13574-dmepos-fee-schedule-april-2024-quarterly-update.pdf

 

April 15, 2024: MLN MM13587: Medicare Claims Processing Manual Update: Inpatient Rehabilitation Facility

CMS advised that you make sure your billing staff know that hospitals may open a new IRF unit at any time during the cost reporting year, and any IRF unit excluded during a cost reporting Year will stay excluded for the rest of the cost reporting year. https://www.cms.gov/files/document/mm13587-medicare-claims-processing-manual-update-inpatient-rehabilitation-facility.pdf

 

Coverage Updates

April 15, 2024: CMS Releases Fact Sheet for Potential NCD for Preexposure Prophylaxis (PrER) Using Antiretroviral Drugs to Prevent HIV

CMS is sharing this information to encourage pharmacies and other interested parties to prepare for a potential National Coverage Determination (NCD) for PrEP Using Antiretroviral Drugs to Prevent HIV.

 

April 16, 2024: MLN MM13512: National Coverage Determination 20.7: Percutaneous Transluminal Angioplasty

This article provides education about the changes in coverage for PTA of the carotid artery concurrent with stenting effective October 11, 2023:

  • Patients don’t have to enroll in a clinical trial.
  • Facilities don’t need CMS approval to perform this service.
  • You must engage in a formal shared decision-making (SDM) process with the patient. This must include documentation of four key elements outlined in this MLN article.
  • MACs can decide if this service is covered if it’s not addressed in this NCD.

Note, your MAC will adjust claims processed in error that you bring to their attention. https://www.cms.gov/files/document/mm13215-national-coverage-determination-207-percutaneous-transluminal-angioplasty.pdf

Beth Cobb

CMS Announces New ASC Prior Authorization Demonstration
Published on Apr 03, 2024
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Did You Know?

In mid-February CMS announced a new Prior Authorization Demonstration for certain Ambulatory Surgical Center (ASC) Services.

 

Why It Matters?

In their announcement, CMS references the nationwide prior authorization process for certain hospital outpatient department (OPD) services that was finalized in the Calendar Year 2020 OPPS Final Rule and implemented on July 1, 2020. The initial services subject to prior authorization in 2020 were blepharoplasty, botulinum toxin injections, panniculectomy, rhinoplasty, and vein ablation procedures.

 

This 5-year demonstration project design will include ASC providers that:

  • Submit claims with place of service 24 (Ambulatory Surgical Center) for one of the five previously mentioned services,
  • Are in one of the ten demonstration states (California, Florida, Texas, Arizona, Ohio, Tennessee, Pennsylvania, Maryland, Georgia, and New York), and
  • Submit claims to Medicare fee-for-service.

 

CMS plans to implement this demonstration for all ten states in one phase and they do not anticipate beginning the demonstration earlier than the fall of 2024.

 

Why now? CMS indicates that data from 2019 to 2021 shows there has been a significant increase in utilization in the ASC for the above five services and they were selected “for inclusion in this demonstration, based upon problematic events, data, trends, and potential billing behavior impacts of the OPD Prior Authorization Program which requires prior authorization as a condition of payment for these services.”

 

What Can You Do?

Take the time to read CMS Form CMS-10884 to learn about details of the demonstration design and justification for the need for this demonstration.

 

Since “the documentation requirements that MACs already have for the services in the OPD program, including local coverage determinations (LCDs), are applicable to these ASC services as well” visit your MACs website to find related resources. For example, Palmetto GBA Jurisdiction J (JJ), the MAC for Tennessee and Georgia has several resources available on their Medical Review / Outpatient Prior Department Prior Authorization (PA) webpage (i.e., Blepharoplasty and Medical Necessity Module).

 

Finally, if you are in one of the demonstration states, share this information with key stakeholders at your facility.

Beth Cobb

April 2024 MedCAT Minute: Hypoglossal Nerve Stimulation
Published on Mar 20, 2024
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MMP’s Medicare Compliance Assessment Tool (MedCAT) combines current Medicare Fee-for-Service (FFS) review targets (i.e., MAC, RAC, SMRC) with hospital specific Medicare FFS paid claims data made possible through a collaboration with RealTime Medicare Data (RTMD).

 

In general, MedCAT Minute articles spotlight current contractor review activities. The focus of this article is RAC Issue 0210: Hypoglossal Nerve Stimulation (HNS) for Obstructive Sleep Apnea (OSA).

 

Background

For patients with OSA who are unable to tolerate CPAP, HNS is one available alternative treatment strategy. The American Academy of Otolaryngology (AAO) (2016) position statement indicates that “The AAO considers upper airway stimulation (UAS) via the hypoglossal nerve for the treatment of adult obstructive sleep apnea syndrome to be an effective second-line treatment of moderate to severe obstructive sleep apnea in patients who are intolerant or unable to achieve benefit with positive pressure therapy (PAP). Not all adult patients are candidates for UAS therapy and appropriate polysomnographic, age, BMI and objective upper airway evaluation measures are required for proper patient selection.” ¹

 

Medicare Coverage Guidance

In 2020, each Medicare Administrative Contractor (MAC) published a Local Coverage Determination (LCD) and related Billing and Coding Article (LCA) for HNS. In general, coverage guidance in each of the LCD’s includes the following statements:

 

“Notice: It is not appropriate to bill Medicare for services that are not covered (as described by this entire LCD) as if they are covered. When billing for non-covered services, use the appropriate modifier.

 

Compliance with the provisions in this policy may be monitored and addressed through post payment data analysis and subsequent medical review audits.”

 

In several of the MAC’s Response to Comments Articles, commenters requested that CPAP refusal or non-acceptance should be included with CPAP failure or intolerance as criteria. The refusal/non-acceptance should be clearly documented along with conversations of the benefits of CPAP and the limitations of HNS.

 

In each instance, the MAC responded to this request by noting that failure of conservative therapy should be tried and failed and or not tolerated prior to a surgical approach and no change was made to the LCD.

 

RAC Issue 0210: Hypoglossal Nerve Stimulation for Obstructive Sleep Apnea: Medical Necessity and Documentation Requirements

RAC Issue 0210 was approved for review by CMS on June 7, 2022.

  • Review Type: Complex
  • Provider Type: Outpatient Hospital, Ambulatory Surgical Center, and Professional Services
  • Issue Description: Hypoglossal Nerve Stimulation (HNS) is reasonable and necessary for the treatment of moderate to severe OSA when coverage criteria are met. Documentation will be reviewed to determine if HNS meets Medicare coverage criteria, applicable coding guidelines, and/or are medically reasonable and necessary.
  • Affected Code: CPT 64582
    • Note: This CPT code was effective on January 1, 2022.
  • Applicable Policy References: The related National Coverage Determination (NCD) 2401.4.1 Sleep Testing for OSA and each of the MACs LCD and related Billing and Coding Articles are included in this section of the RAC Issue.

 

By July 1, 2022, all RACs had added this issue to their list of issues that they would review for all three listed provider types.

 

Meeting Medical Necessity and Documentation Gaps

Palmetto GBA, the Jurisdiction J MAC, has published an article highlighting requirements to meet criteria for HNS and indications when HNS would not be reasonable and necessary.

Beth Cobb

New March 2024 OIG Work Plan Item: Sepsis
Published on Mar 20, 2024
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On Friday, March 15, 2024, the Office of Inspector General (OIG) updated their Work Plan with eight new items. One item that hospitals will want to follow is related to hospital billing for sepsis.

 

OIG Work Plan Item (OEI-02-24-00230): Medicare Inpatient Hospital Billing for Sepsis

“Sepsis is the body’s extreme response to infection. It is a life-threatening, emergency medical issue that often progresses quickly and responds best to early intervention. The definition of and guidance for sepsis have changed over the years in attempts to identify it more accurately. The definition of sepsis was updated in 2016 by an international task force to better differentiate sepsis from a general infection. This narrower definition is widely recognized by groups such as the World Health Organization. However, CMS and CDC currently recognize an older, broader definition. Sepsis is a frequently billed diagnosis in Medicare. There are concerns that hospitals may be taking advantage of this broader definition, as they have a financial incentive to do so. This study will analyze Medicare claims to assess patterns in the inpatient hospital billing of sepsis in 2023 and describe how billing of sepsis varied among hospitals. We will also estimate the costs to Medicare associated with using the broader, rather than the narrower, definition of sepsis.” The OIG’s expected report issue date is in Fiscal Year (FY) 2025.

 

Sepsis, Not a New Target

 

OIG and Sepsis

This is not the first time that the OIG has had sepsis MS-DRG’s in their crosshairs. For example, sepsis was mentioned in the February 2021 OIG Report: Trend Toward More Expensive Inpatient Hospitals Stays Emerged Before COVID-19 and Warrant’s further Scrutiny.

 

In their report results, the OIG indicated that “the most frequently billed MS-DRG in FY 2019 was septicemia or severe sepsis with a major complication (MS-DRG 871). Hospitals billed for 581,000 of these stays, for which Medicare paid $7.4 billion.”

 

The following data compares Medicare Fee-for-Service paid claims data by calendar year from pre-COVID 2019 to after then end of the COVID-19 public health emergency (PHE) in May 2023.

 

MS-DRG 871 Medicare Fee-for-Service Paid Claims Data Trend

 

Calendar Year 2019

Claims Volume: 620,927

Claims Payment: $7.992,972,329

 

Calendar Year 2020

Claims Volume: 611,140

Claims Payment: $8,481,178,934

 

Calendar Year 2021

Claims Volume: 556,680

Claims Payment: $8,152,439,134

 

Calendar Year 2022

Claims Volume: 566,387

Claims Payment: $8,392,707,197

 

Calendar Year (January 1 – September 30, 2023) Annualized

Claims Volume: 546,496

Claims Payment: $8,238,024,702

 

The data shows that claims volume and payment has declined since the height of the COVID-19 pandemic in 2020. However, when you annualize calendar year 2023 claims data (January 1 through September 30, 2023), Medicare payment for sepsis continues to be immense at just over $8.2 billion for one MS-DRG. This data was provided by our sister company, RealTime Medicare Data (RTMD).

Beth Cobb

March 2024 National Colorectal Cancer Awareness Month
Published on Mar 06, 2024
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Did You Know?

According to the American Cancer Society, there has been a rise in colorectal diagnoses among people 50 and younger. “In the late 1990s, colorectal cancer was the fourth leading cause of cancer death in both men and women in this age group, and now, it is the first cause of cancer death in men younger than 50 and the second cause in women that age.”

 

In May 2021, the U.S. Preventive Services Task Force changed its colorectal cancer screening recommendation. They lowered the age at which adults at average risk of getting colorectal cancer begin screening from 50 to 45.

 

Why it Matters?

Effective January 1, 2023, CMS lowered the minimum age for colorectal screening (CRC) from age 50 to 45 for certain tests.

 

MLN Matters article MM13017, Removal of a National Coverage Determination and & Expansion of Coverage of Colorectal (CRC) Screening includes:

  • A list of the specific screening tests where the minimum age has decreased from 50 to 45 years and older, and
  • An expanded definition of CRC screening tests and new billing instructions for colonoscopies under certain scenarios.

 

Also, National Coverage Determination (NCD 210.3) Colorectal Cancer Screening Tests was revised to reflect the decrease in minimum age for each of the covered indications listed in this policy.

 

What Can You Do?

As a healthcare provider, be aware of the changes in Medicare’s colorectal screening coverage. Use the Colorectal Cancer Screening Tests information available in MLN Educational Tool Medicare Preventive Services to identify:

  • Applicable HCPCS, CPT and ICD-10 Codes,
  • The specific screening tests that Medicare Covers,
  • The frequency for performing these screening tests for patients not meeting high-risk criteria as well as patients at high-risk,
  • What the patient pays, and
  • Other notes (i.e., CMS pays for anesthesia services provided in conjunction with, and in support of, a screening colonoscopy reported with CPT code 00812.)

 

As a healthcare consumer, I encourage everyone to talk with your doctor about your risk(s) for colorectal cancer and the need for screening tests.

 

References

American Cancer Society article: 2024 – First Year the US Expects More than 2M New Cases of Cancer: https://www.cancer.org/research/acs-research-news/facts-and-figures-2024.html

 

U.S. Preventive Services Task Force May 18, 2021 Final Recommendation Statement for colorectal cancer screening: https://uspreventiveservicestaskforce.org/uspstf/recommendation/colorectal-cancer-screening

 

MLN MM13017: https://www.cms.gov/files/document/mm13017-removal-national-coverage-determination-expansion-coverage-colorectal-cancer-screening.pdf

 

MLN Educational tool Medicare Preventive Services: https://www.cms.gov/Medicare/Prevention/PrevntionGenInfo/medicare-preventive-services/MPS-QuickReferenceChart-1.html#COLO_CAN

Beth Cobb

February 2024 Medicare Coverage and Compliance Updates
Published on Feb 28, 2024
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Coverage Updates

 

February 6, 2024: FAQs Related to Coverage Criteria & Utilization Management Requirements for MA Plans

CMS sent a FAQ document to all Medicare Advantage Organizations and Medicare-Medicaid Plans related to Coverage Criteria and Utilization Management Requirements in the CMS Final Rule (CMS-4201-F) issued on April 5, 2023. They note since this rule has been issued, they have received questions regarding application of the rules. This document is meant to provide clarification about how CMS expects MA plans to comply with the new rules. https://www.aha.org/system/files/media/file/2024/02/faqs-related-to-coverage-criteria-and-utilization-management-requirements-in-cms-final-rule-cms-4201-f.pdf

 

Compliance Education Updates

 

January 2024: MLN Booklet: Health Equity Services in the 2024 Physician Fee Schedule Final Rule (MLN9201074)

CMS framework on health equity lists 5 priorities for reducing disparities in health. The 2024 Physician Fee Schedule Final Rule has 4 services to help address these priorities including:

  • Caregiver Training Services (CTS),
  • Social Determinants of Health Risk (SDOH) Assessment,
  • Community Health Integration (CHI), and
  • Principal Illness Navigation (PIN).

This MLN booklet reviews all four services including who can provide the service and documentation and billing guidance.

https://www.cms.gov/files/document/mln9201074-health-equity-services-2024-physician-fee-schedule-final-rule.pdf-0

 

January 2024: MLN Booklet: Federally Qualified Health Center (MLN006397)

CMS has added information about marriage and family therapists and mental health counselors or practitioners, added services, updates to mental health in-person visit rules, and COVID-19 and other vaccine billing instructions to this MLN booklet. https://www.cms.gov/files/document/mln006397-federally-qualified-health-center.pdf

 

February 2024: MLN Booklet: Information for Rural Health Clinics (MLN006398)

CMS has made additions to this booklet, for example information about marriage and family therapists and mental health counselors as practitioners and social determinants of health has been added. https://www.cms.gov/files/document/mln006398-information-rural-health-clinics.pdf

 

February 2024: MLN Fact Sheet: Telehealth Services (MLN901705)

Changes made to this MLN product includes adding new CPT and HCPCS codes for CY 2024, adding new and expanded telehealth services, information about extended use of modifier 95 and the CY 2024 originating site facility fee amount which is $29.96. https://www.cms.gov/files/document/mln901705-telehealth-services.pdf

 

February 2024: MLN Fact Sheet: Proper Use of Modifiers 59, XI, XP, XS, & XU (MLN1783722)

This CMS Fact Sheet has been updated to include information on the use of modifier 59 and a single Rural Health Clinic (RHC) or Federally Qualified Health Center (FQHC). https://www.cms.gov/files/document/mln1783722-proper-use-modifiers-59-xe-xp-xs-and-xu.pdf

Beth Cobb

February 2024 Medicare Potpourri
Published on Feb 28, 2024
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January 17, 2024: Acute Care Hospitals Required to join Joint Commission NHSN Group

Effective July 1, 2024, acute care hospitals with ORYX® performance measurement requirements and that are required through a CMS program to participate in the CDC National Healthcare Safety Network (NHSN) system will be required to join the Joint Commission NHSN Group.

 

The Joint Commission indicated in their announcement that “In April 2024 The Joint Commission will e-mail the primary accreditation contact on file for the organization to determine the appropriate contact person to correspond with regarding the Joint Commission NHSN Group. After the contract has been identified, detailed instructions for joining the Group will be provided, and onboarding will take place May through June 2024.”

 

February 1, 2024: April 1, 2024 ICD-10-CM Updates

CMS notes the ICD-10-CM April 1, 2024 update addresses typographical errors and there are no new diagnosis codes being implemented. You will find downloads for discharges on and after April 1, 2024 on the 2024 ICD-10-CM webpage including an update ICD-10-CM Official Guidelines for Coding and Reporting that includes a few updates, for example on page 29 of this document a new subsection (f) Screening for COVID-19 has been added which provides the following guidance “for screening for COVID-19, including preoperative testing, assign code Z11.52, Encounter for screening for COVID-19.”

 

February 7, 2024: New Steps to Transform the Organ Transplant System

HHS issued a Press Release announcing that the Health Resource and Services Administration (HRSA) “is taking historic steps as part of its Organ Procurement and Transplantation Network (OPTN) Modernization Initiative, leveraging new legal authority…signed into law as part of the Securing the U.S. Organ Procurement and Transplantation Network Act in September 2023.  HRSA actions include:  

  • Releasing a contract solicitation to break up the OPTN monopoly and create an independent OPTN Board of Directors,
  • Issuing a multi-vendor contract solicitation to support broad competition and best-in-class vendors for critical OPTN functions,
  • Launching the discovery and development phase of the transition to a modernized OPTN IT matching system, and
  • Taking action to address “pre-waitlist” inequities in the organ waitlist process and reduce variations in referrals to transplant and in organ procurement practices.

 

February 8, 2024: CMS Reminds Providers about the Jimmo Settlement Agreement

CMS reminded providers in the Thursday, February 8, 2024 edition MLN Connects that “Medicare covers skilled nursing care and skilled therapy services under skilled nursing facility, home health, and outpatient therapy benefits when a beneficiary needs skilled care to maintain function or to prevent or slow decline, as long as:

  • The beneficiary requires skilled care for the services to be provided safely and effectively.
  • An individualized assessment of the patient's condition demonstrates that the specialized judgment, knowledge, and skills of a qualified therapist are needed for a safe and effective maintenance program.

Note, on February 13, 2024, CMS sent a letter to all Medicare Advantage Organizations reminding them about the Jimmo Settlement Coverage and Training Policies. https://leadingage.org/wp-content/uploads/2024/02/HPMS-Memo_-Jimmo-Settlement_508.pdf

 

February 8, 2024: Accrediting Organization (AO) Proposed Rule

CMS published a proposed rule and related Fact Sheet noting that “CMS’s annual AO oversight Reports to Congress (RTCs) highlight the agency’s significant concerns regarding AO performance that need to be addressed.Comments can be submitted until April 15, 2024.

 

February 8, 2024: Texting of Patient Information and Orders for Hospitals and CAHs Memorandum

This memorandum updates CMS’ current policy for texting patient orders based on current practice and stakeholder feedback. Hospitals and Critical Access Hospitals (CAHs) will now have the flexibility to include text orders, via a secure platform, to be entered into the patient’s medical record or EHR in a manner compliant with the medical record Conditions of Participation (CoPs). https://www.cms.gov/files/document/qso-24-05-hospital-cah.pdf

Beth Cobb

February 2024 Medicare MLN Articles
Published on Feb 28, 2024
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February 5, 2024: MLN MM13507: ICD-10 & Other Coding Revisions to National Coverage Determinations: July 2024 Update

Make sure your staff knows about newly available codes, recent code changes, and NCD coding information. https://www.cms.gov/files/document/mm13507-icd-10-other-coding-revisions-national-coverage-determinations-july-2024-update.pdf

 

February 5, 2024: MLN SE19007: Activation of Validation Edits for Providers with Multiple Service Locations – Revised

This special edition MLN article was originally released March 26, 2019. With this latest revision, CMS clarified how to hand certain off-campus provider-based departments excepted from Section 603 payment policy. https://www.cms.gov/outreach-and-education/medicare-learning-network-mln/mlnmattersarticles/downloads/se19007.pdf

 

February 12, 2024: MLN MM13513: Pulmonary Rehabilitation, Cardiac Rehabilitation, & Intensive Cardiac Rehabilitation Expansion of Supervising Practitioners

Make sure your billing staff knows about updates to the above-mentioned rehabilitation services effective January 1, 2024, including expanding the types of practitioners who may supervise these services. https://www.cms.gov/files/document/mm13513-pulmonary-rehabilitation-cardiac-rehabilitation-intensive-cardiac-rehabilitation-expansion.pdf

 

February 15, 2024: Limitation on Recoupment of Medicare Overpayments

Limitation on recoupment of Medicare overpayments is during the first and second level of appeal only. Make sure your staff knows about this limit, when to request an extended repayment plan (ERS) or choose immediate recoupment, and how CMS pays interest on overpayments. https://www.cms.gov/files/document/mm11808-limitation-recoupment-medicare-overpayments.pdf

 

February 21, 2024: MLN MM13485: Appropriate Use Criteria (AUC) for Advanced Diagnostic Imaging: CY 2024 Update

Make sure your billing staff knows about CMS rescinding the AUC program regulations, the program has been paused for reevaluation, and elimination of AUC consultation information on Medicare Fee-for-Service claims. https://www.cms.gov/files/document/mm13485-appropriate-use-criteria-advanced-diagnostic-imaging-cy-2024-update.pdf

 

February 22, 2024: MLN MM13451: Clinical Laboratory Fee Schedule & Laboratory Services Reasonable Charge Payment: Quarterly Update

Make sure your billing staff knows when the next private payor data reporting period is and new and deleted HCPCS codes. https://www.cms.gov/files/document/mm13541-clinical-laboratory-fee-schedule-laboratory-services-reasonable-charge-payment-quarterly.pdf

 

Beth Cobb

Medicare Preventive Services Education Tool Revised
Published on Feb 21, 2024
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Did You Know?

Through the Medicare Learning Network (MLN), CMS has developed an interactive education tool titled Medicare Preventive Services (MLN006559 January 2024). This tool is meant to help providers properly provide and bill Medicare prevention services (i.e., bone mass measurement, colorectal screening, lung cancer screening).

 

For each Preventive Service listed in the tool, you will find the following information as applicable to the service:

  • National Coverage Determination (NCD),
  • HCPCS and CPT codes specific to the service provided,
  • ICD-10-CM diagnosis codes,
  • Telehealth eligibility,
  • Coverage requirements,
  • Frequency requirements, and
  • Medicare Beneficiary (patient) cost sharing.

     

    You will also find answers to the following questions:

  • How do I determine the last date a patient got a preventive service, so I know if they’re eligible to get the next service and it won’t deny due to frequency edits?
  • When can CMS add new Medicare preventive services?
  • My patients don’t follow up on routine preventive care. How can I help them remember when they’re due for their next preventive service?
    • CMS provides a link to a Preventive Services Checklist that you can give your patients.
    • Note, CMS also highlights preventive services with an apple in the official U.S. government Medicare Handbook, Medicare and You. You will find information about preventive services in the 2024 Edition of this handbook on pages 30-55.
  • What’s a primary care setting?

     

    Why It Matters?

    This tool was revised in January 2024. Following are two examples of what has been revised:  

     

    Annual Wellness Visit

    New HCPCS code G0136 (Administration of a standardized, evidence-based social determinants of health risk assessment tool, 5-15 minutes) has been added as well as the following “Other Notes:”

  • The implementation date for SDOH Risk Assessment claims is July 1, 2024,
  • The billing HCPCS code is G0136,
  • Add modifier 33 to an SDOH, G0136, performed on the same day as the Annual Wellness Visit to waive copayment and deductible,
  • G0136 is covered once a year with copayment and deductible waived, and
  • The AWV can be an optional community health integration (CHI) initiating visit when the provider identifies any unmet SDOH needs that prevent the patient from doing the recommended personalized prevention plan.

 

Flu Shot

Starting January 1, 2024, Medicare pays an additional payment for in-home flu shot administration under certain circumstances.

 

What Can You Do?

  • Read all the revisions made to this tool in January in the February 15, 2024 edition of MLN Connects,
  • Use this tool to identify service specific applicable coverage requirements (NCD), HCPCS/CPT codes, and ICD-10-CM diagnosis codes, and
  • Share this tool with key stakeholders at your facility.

Beth Cobb

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