Medicare Compliance & Reimbursement

Note the MIPS 2018 submissions vary according to how you submit measures.

As the year comes to a close, it’s a great time to review new proposals, plans, and programs, heading into 2019. Put these three important dates on your calendar to avoid coding, compliance, and reimbursement snafus.

1. New CPT^® Code Options and Revaluations

As you prepare your billing systems for 2019, it’s a good time to review new payment values that commence on Jan. 1 as well as review new CPT^® code options and changes.

Conversion factor: On Nov. 23, CMS published its CY 2019 Medicare Physician Fee Schedule (MPFS) final rule in the Federal Register, which included 2,378 pages of material that confirm the policies that the agency has set for next year. In its guidance, the agency changed the final 2019 conversion factor to $36.04, a tiny bump from this year’s $35.99.

Tip: No one is going to call the MPFS rate increase substantial; if you’re only getting $0.06 more per relative value unit (RVU) on your coding, you’ll need to be extra vigilant about getting the correct code every time on your 2019 claims.

Remember that to calculate the fee for a Medicare service, you’ll multiply the conversion factor by the total relative value units (RVUs). For instance, code 99204 (Office or other outpatient visit for the evaluation and management of a new patient, which requires these 3 key components: A comprehensive history; A comprehensive examination; Medical decision making of moderate complexity…) currently has a total non-facility RVU of 4.65 for 2018, which comes out to a fee of approximately $167.35 when multiplied by the 2018 conversion factor of 35.99.

Start date: CPT^® 2019 additions, revisions, and deletions will go into effect on January 1, 2019 as will code revaluations.

Resource: Read the CY 2019 MPFS final rule published in the Federal Register at https://s3.amazonaws.com/public-inspection.federalregister.gov/2018-24170.pdf.

2. MIPS PY 2018 Submission and Web-Interface Submission Timeline

If you’re familiar with the phrase — “when one door closes, another opens” — then you should have no problem understanding the Merit-Based Incentive Payment System (MIPS) submission timeline for Performance Year (PY) 2018.

Overview: Right after the MIPS PY 2018 ends on Dec. 31, 2018, CMS opens up its submissions window on Jan. 2, 2019. “You may submit and update your [MIPSPY 2018] data any time while the submission window is open,” advised the Quality Payment Program(QPP) website. The submission window ends on April 2, 2019.

Web-Interface: For registered groups submitting their PY 2018 MIPS data, the timeline is a little different. CMS Web-Interface users can send group submissions over a nine-week period from Jan. 22, 2019 to April 22, 2019.

Review the QPP deadlines at https://qpp.cms.gov/about/deadlines.

3. Review and Dispute Open Payments

According to CMS, Open Payments are a good way for the public to see physicians and teaching hospitals’ financial interactions with “applicable manufacturers and [group purchasing organizations] GPOs,” suggested online guidance. So, if you haven’t taken a peek at your reported data, now is a good time to do so, especially if you think it might be wrong or questionable.

Reminder: Over the summer, CMS published the 2017 Open Payments details “along with updated and newly submitted data from previous program years (2013-2016),” said CMS.

Deadline: Program Year 2017 information and “newly submitted payment records” are now up and ready for “review and dispute,” the agency said. The deadline to check and/or fix your Open Payments issues is December 31, 2018.

Discover more about Open Payments at www.cms.gov/OpenPayments/About/Resources.html.