Medicare Compliance & Reimbursement

1. Send the patient a copy of the requirement. Patients who think they know more about Medicare rules than you do might be surprised to see in writing that the HRA is actually a required part of the AWV. Translation? If you don't have an HRA included, you may not get paid for the service.

Patients who fit into this category might benefit from seeing the rules in writing. Rather than sending them an entire Federal Register link, you might find it easier to show them CMS's document, "Interim Guidance for Health Risk Assessments and their Modes of Provision for Medicare Beneficiaries" from the CMS Web site. They'll not only see that the HRA is required, but will also find insight into what should be on the form.

2. Assign a staff member to assist the patient in completing the HRA. According to the 2012 Physician Fee Schedule Final Rule, "CMS acknowledged that the addition of the HRA might increase physician or other practitioner time... Furnishing a meaningful HRA to Medicare beneficiaries will require accommodation and that those beneficiaries may need assistance from physician office staff when completing the HRA."

To accommodate your staff members' time helping the patient complete the HRA, CMS raised the RVUs for G0438 (Annual wellness visit, including a personalized prevention plan of service, first visit) from 4.74 to 4.89, and raised the RVUs for G0439 (...subsequent visit) from 3.16 to 3.26 for 2012.

Time suggestion: CMS estimates that physician office staff time for helping beneficiaries complete an HRA should be 10 minutes for the first AWV and five minutes for subsequent AWVs.

3. Send it to the patient the day she makes her appointment. If you'd like to offer your patient extra time in completing the HRA, you can send the forms to her on the date that she schedules her visit with you. Then she will have ample time to work on the form at home or with family members prior to the visit.

4. If all else fails, have the physician go over it with the patient during the visit. According to CMS, the HRA "is intended to be a self-reported assessment completed before or during the annual wellness visit." Therefore, if it is performed during the visit with the patient's input, it appears that CMS will still consider it as "counting" toward the HRA requirement if the physician discusses all of the factors with the patient.

5. Explain to the patient that without the HRA, you'll be forced to bill a preventive medicine visit -- which is non-covered by Medicare. Without the HRA, you won't be able to complete all required aspects of the AWV, and you'll therefore have to turn to one of the preventive medicine codes (99381-99387). Because Medicare does not reimburse for these codes, you'll have to explain to the patient that she will be responsible for the charge. If the patient agrees to pay for the service, ask her to sign an advance beneficiary notice (ABN) with the expected amount of the charge, and keep a copy of the ABN on file. You'll append modifier GX (Notice of liability issued, voluntary under payer policy) to the preventive medicine code.