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The Health Information Portability and Accountability Act (HIPAA) and the Health Information Technology for Economic and Clinical Health Act (HITECH Act) require covered entities, such as hospitals, and their business associates to take actions to ensure that patients’ personal health information (PHI) is protected from inappropriate disclosure.  MMP, Inc. is committed to maintaining the privacy and security of all patient health information.  We would like to remind our clients of the following:

• PHI sent via e-mail without encryption or password protected files is at risk of discovery.  We encourage our clients not to send any PHI via regular e-mail without encryption or other means to protect the information.
• If PHI is sent in password protected files, the password should be sent in a separate e-mail or communicated via telephone.
• Patient information sent to MMP on CDs should be encrypted or password protected.  Passwords should be communicated in a separate correspondence.
• MMP encourages all of our clients to provide access to patient medical records via protected electronic means whenever possible.  The preferred method is direct access through a username and password directly into the facility’s medical record database.  Information on encrypted or password protected CDs are preferred over paper records.  We discourage the submission of medical records in a paper format due to the increased risk of inappropriate disclosure.
• Faxing PHI also poses an increased risk of inappropriate disclosure and MMP encourages our clients to use alternate, more secure delivery methods if possible.  If you must fax information containing PHI to MMP, please verify carefully that you are sending the information to the correct fax number and use a cover page that includes a confidentiality message.  You may also want to verify that the intended recipient received the fax.

If you have any suggestions or questions concerning the privacy and security of PHI communications with MMP, please contact us at info@mmplusinc.com

On March 23, 2010, President Obama signed into law the Patient Protection and Affordable Care Act (PPACA).  Several issues of interest to hospitals affected by the Act are discussed below.

• Section 3104 of this statute permits independent clinical laboratories to continue to bill for the technical component (TC) of physician pathology services for inpatients or outpatients of a hospital.  This is effective for dates of service January 1, 2010 through December 31, 2010.  For more information see CMS Transmittal 1945 or MLN Matters Article MM6813. 
• Section 6404 of the PPACA amended the timely filing requirements to reduce the maximum time period for submission of all Medicare FFS claims to one calendar year after the date of service.  Under the new law, claims for services furnished on or after January 1, 2010, must be filed within one calendar year after the date of service.  In addition, Section 6404 mandates that claims for services furnished before January 1, 2010, must be filed no later than December 31, 2010.  The following rules apply to claims with dates of service prior to January 1, 2010.  Claims with dates of service before October 1, 2009, must follow the pre-PPACA timely filing rules.  Claims with dates of service October 1, 2009, through December 31, 2009, must be submitted by December 31, 2010. 
• Section 3122 of the Patient Protection and Affordable Care Act re-institutes reasonable cost payment for clinical laboratory tests performed by hospitals with fewer than 50 beds in qualified rural areas as part of their outpatient services for cost reporting periods beginning on or after July 1, 2010 through June 30, 2011. For some hospitals this could affect services performed as late as June 30, 2012.  For more information see CMS Transmittal 1940 or MLN Matters Article MM6873.
• The act extends the Outpatient Hold Harmless provision, effective for dates of service on and after January 1, 2010, through December 31, 2010, to rural hospitals with 100 or fewer beds and to all sole community hospitals and Essential Access Community Hospitals regardless of bed size. 

Issues of interest to other provider types include:

• Section 3103 of the Act extends the exceptions process for outpatient therapy caps.  Providers may continue to submit claims with the KX modifier, when an exception is appropriate, for services furnished on or after January 1, 2010, through December 31, 2010.  Therapy caps do not apply to hospital outpatient therapy services.
• Section 3131(c) of this statute creates a 3% add-on to payments made for home health services to patients in rural areas.   The add-on applies to episodes ending on or after April 1, 2010, through December 31, 2016.  Similar to temporary rural add-on provisions in the past, claims that report a rural state code (code beginning with 999) as the Core Based Statistical Area (CBSA) code for the beneficiary’s residence will receive the additional 3% payment.   The CBSA code is reported associated with value code 61 on home health claims.  CMS is working to expeditiously implement the home health rural add-on provision.

 

As discussed in Transmittal 1935 and Transmittal 118, effective for dates of service on and after December 8, 2009, CMS will cover both standard and FDA-approved HIV rapid screening tests as described below.  The implementation date of these transmittals is July 6, 2010.

Coverage Requirements

1. A maximum of one, annual voluntary HIV screening of Medicare beneficiaries at increased risk for HIV infection per USPSTF guidelines as follows: 

•  Men who have had sex with men after 1975
• Men and women having unprotected sex with multiple [more than one] partners
• Past or present injection drug users
• Men and women who exchange sex for money or drugs, or have sex partners who do
• Individuals whose past or present sex partners were HIV-infected, bisexual or injection drug users
• Persons being treated for sexually transmitted diseases
• Persons with a history of blood transfusion between 1978 and 1985
• Persons who request an HIV test despite reporting no individual risk factors, since this group is likely to include individuals not willing to disclose high-risk behaviors; and,

2. A maximum of three, voluntary HIV screenings of pregnant Medicare beneficiaries: (1) when the diagnosis of pregnancy is known, (2) during the third trimester, and (3) at labor, if ordered by the woman’s clinician.

Procedure Codes

The following HCPCS codes are to be billed for HIV screening:

• G0432- Infectious agent antigen detection by enzyme immunoassay (EIA) technique, qualitative or semi-quantitative, multiple-step method, HIV-1 or HIV-2, screening,
• G0433 - Infectious agent antigen detection by enzyme-linked immunosorbent assay (ELISA) technique, antibody, HIV-1 or HIV-2, screening, and,
• G0435 - Infectious agent antigen detection by rapid antibody test of oral mucosa transudate, HIV-1 or HIV-2, screening.

Diagnosis Coding

Claims for HIV screening shall be submitted with one or more of the following diagnosis codes:

a. For claims where increased risk factors are reported: V73.89 as primary and V69.8 as secondary.
b. For claims where increased risk factors are NOT reported: V73.89 as primary only.
c. For claims for pregnant Medicare beneficiaries, the following diagnosis codes shall be submitted in addition to V73.89 to allow for more frequent screening than once per 12-month period:
 V22.0 – Supervision of normal first pregnancy, or,
 V22.1 – Supervision of other normal pregnancy, or,
 V23.9 - Supervision of unspecified high-risk pregnancy.

Other Information

Applicable Bill Types are 12X, 13X, 14X, 22X, 23X, and 85X. Use revenue code 030X (laboratory, clinical diagnostic).

HIV testing for diagnostic purposes continues to be covered under Section 190.14 of the National Coverage Determination manual.  The coverage indications for diagnostic HIV testing and a list of covered diagnosis codes can be found in the NCD Coding Policy Manual for Laboratory Services (see pages 52-59).

For more information, refer to MLN Matters Article MM6786.

CMS Transmittal 6530 released March 19, 2010, provides instructions for the proper use of the CPT and HCPCS codes for drug screening beginning with dates of service April 1, 2010 and after.  Previously released MLN Matters Article SE1001 contains information on drug screen billing for dates of services from January 1, 2010 through March 31, 2010.  The major changes in the latest transmittal are new codes for laboratories with a CLIA certificate of waiver and the deletion of Medicare coverage for CPT codes 80101 and 80101QW.

Effective April 1, 2010:

• When performing a qualitative drug screening test for multiple drug classes that uses chromatographic methods, CPT Code 80100 is the appropriate code to bill.
• When performing a qualitative drug screening test for multiple drug classes that does not use chromatographic methods, new test code G0430 is the appropriate code to use for labs that do not require a CLIA certificate of waiver.  Waiver labs would use code G0430QW.
• When performing a qualitative drug screening test for a single class of drugs, test code G0431 is the appropriate code to use for labs that do not require a CLIA certificate of waiver.  Waiver labs would use code G0431QW. 

New test code G0431 is a direct replacement of CPT code 80101.  Effective April 1, 2010, CPT Code 80101 will no longer be covered by Medicare, and CPT Code 80101QW will be deleted.

For additional information, see MLN Matters Article MM6852.

On March 5, 2010, CMS released Transmittal 6180 which announced that effective January 1, 2011 CMS is expanding the number of ICD-9 diagnosis and procedure codes it will accept and process on institutional claims.

The expansion will allow:

• Additional ICD-9 other (secondary) diagnosis codes (from 8 codes to 24 codes) as well as additional associated present on admission (POA) codes; and
• Additional ICD-9 other (secondary) procedure codes (from 5 codes to 24 codes).

Please review MLN Matters Article MM6851 for more information.

CMS rescinded Transmittal 1917 and replaced it with Transmittal 1929 on March 9, 2010.  The new transmittal changes the title of Code 2 to “Clinic or Physician’s Office.”  All other information described below remains the same.

In accordance with changes made by the National Uniform Billing Committee (NUBC), the following Point of Origin for Admission or Visit (formerly Source of Admission) codes will be discontinued for use by Medicare Systems effective July 1, 2010.

• 7 – Emergency Room (ER) – Inpatient: The patient was admitted to this facility after receiving services in this facility’s emergency room department. 
• B – Transfer from Another Home Health Agency
• C – Readmission to Same Home Health Agency
   * Codes B and C apply to home health agencies and these changes were addressed  in CMS Transmittal 1904.

Changes are also being made to the definition language of Point of Origin codes “1” and “2” although the processing of these codes is not being changed.  See the chart below for the old and new definitions and examples.

For more information, please refer to CMS Transmittal 1917 or the MLN Mattes Article MM6801.

Question:
If a patient is discharged from an acute care hospital and sent back to the nursing home, placed in a non-skilled bed, and the patient is a resident of the Medicare-certified nursing home, what would the discharge disposition be? Is there ever a time when the disposition would be “01-home”?

Answer:
Discharge disposition code 03 is used for Medicare Certified SNFs in anticipation of skilled care, so the discharge disposition would not be 03.  Under the current guidelines the disposition would be 04.  “There was a time when one of the FAQs (that has since been deleted -- FAQ #41 effective 10/1/09) indicated that if a NF was the permanent residence that 01 could be appropriate.   Now, no discharge to any facility is 01.”

Resource:  Email communication between MMP, Inc. and the AMA/NUBC.

Question:
Can a Medicare patient come to a hospital to receive a blood transfusion and get their dialysis?  Does the hospital have to be an accredited dialysis center to perform this procedure?

Answer:
When you bill HCPCS code G0257, that code tells Medicare that you provided dialysis in a hospital outpatient department that is not certified as an ESRD facility.

And one of the criteria for coverage of G0257 is when dialysis is done in conjunction with blood transfusion. 

Remember, when you bill G0257 you cannot separately bill injections, infusions, or the blood transfusion provided during that dialysis session.

Here is the link to the July 2008 OPPS update where this was last discussed, and also pasted below is the excerpted paragraph from that transmittal.

http://www.cms.hhs.gov/transmittals/downloads/R1536CP.pdf

"8. Hospital Services for Patients with End Stage Renal Disease

CMS is revising the Medicare Claims Processing Manual, Pub. 100-04, Chapter 4, §200.2 to expand the circumstances under which payment may be made to a hospital for unscheduled outpatient dialysis provided to an ESRD patient. The first circumstance listed is "dialysis performed following or in connection with a vascular access procedure". We are expanding this to include any dialysis related procedure such as vascular access procedures or blood transfusions."

Effective December 23, 2009, CMS determined that services comprising an Outpatient Intravenous Insulin Therapy (OIVIT) regimen are nationally non-covered under Medicare when furnished pursuant to an OIVIT regimen as described below.

The term outpatient intravenous (IV) insulin therapy (OIVIT) refers to an outpatient regimen that integrates pulsatile or continuous intravenous infusion of insulin via any means, guided by the results of measurement of: 

• respiratory quotient; and/or 
• urine urea nitrogen (UUN); and/or 
• arterial, venous, or capillary glucose; and/or 
• potassium concentration; and

performed in scheduled recurring periodic intermittent episodes. The insulin administration is adjunctive to the patient’s routine diabetic management regimen (oral agent or insulin-based) or other disease management regimen, typically performed on an intermittent basis (often weekly), and frequently performed chronically without duration limits.

This regimen is also sometimes termed Cellular Activation Therapy (CAT), Chronic Intermittent Intravenous Insulin Therapy (CIIT), Hepatic Activation Therapy (HAT), Intercellular Activation Therapy (iCAT), Metabolic Activation Therapy (MAT), Pulsatile Intravenous Insulin Treatment (PIVIT), Pulse Insulin Therapy (PIT), and Pulsatile Therapy (PT).

Effective April 5, 2010 new HCPCS code

• G9147 – Outpatient Intravenous Insulin Treatment (OIVIT) either pulsatile or continuous, by any means, guided by the results of measurements for: respiratory quotient; and/or, urine urea nitrogen (UUN); and/or, arterial, venous or capillary glucose; and/or potassium concentration

should be used to bill for non-covered OIVIT and any services comprising an OIVIT regimen.  Effective April 5, 2010, HCPCS codes 99199 (unlisted special service, procedure, or report) or 94681 (exhaled air analysis CO2) are no longer appropriate codes for OIVIT and should not be used in conjunction with OIVIT or diabetes-related conditions (250.00-250.93).  Claims billed with 99199 or 94681 will be returned to providers.

Two CMS transmittals regarding the non-coverage of OIVIT were released February 5, 2010.  The effective date of the transmittals is December 23, 2009 and the implementation date is March 8, 2010.  For more information, please view the complete transmittals at the following links.

CMS Transmittal 112 NCD for OIVIT
CMS Transmittal 1913 Claims Processing OIVIT

CMS recently published MLN Matters Article SE1001 to clarify the descriptions and billing of CPT/HCPCS codes G0430, G0431, 80100, and 80101 for qualitative drug screen services for the period of January 1, 2010 through March 31, 2010. 

The current definitions of all test codes addressed in this article are:

• CPT Code 80100 – Drug screen, qualitative; multiple drug classes chromatographic method, each procedure
• G0430 – Drug screen, qualitative; multiple drug classes other than chromatographic method, each procedure
• CPT Code 80101 – Drug screen, qualitative; single drug class method (e.g., immunoassay, enzyme assay), each drug class
• CPT Code 80101QW – Drug screen, qualitative; single drug class method (e.g., immunoassay, enzyme assay), each drug class
• G0431 – Drug screen, qualitative; single drug class method (e.g., immunoassay, enzyme assay), each drug class

From January 1, 2010 through March 31, 2010, when performing a qualitative drug screening test for multiple drug classes using chromatographic methods, CPT Code 80100 is the appropriate code to bill.  If the qualitative drug screening test for multiple drug classes uses methods other than chromatographic, new HCPCS code G0430 is the appropriate code to bill.

For the same time frame, if a qualitative drug screening test for a single class of drugs is performed, regardless of the testing methodology, clinical laboratories that do not require a CLIA certificate of waiver should bill new test code G0431.  CLIA certificate of waiver laboratories should continue to bill CPT code 80101QW.

CMS will provide further direction on this issue by April 1, 2010.

It is important to note that CPT Codes 80100 and 80101 are assigned a status indicator of ‘E’ in the OPPS Addendum B indicating these codes are not covered by Medicare.  Discussion at the January CMS Hospital Open Door Forum indicated this would be corrected in the April OCE update and would apply retroactively.  There was no indication in the MLN Matters article of how Medicare will handle payment of these codes at this time.