Medicare Compliance & Reimbursement

Tip: Expect HICNs to Reject Starting Jan. 1.

If you’re trying to keep your records straight on when to submit this or when to stop sending that, you’re not alone. We’ve compiled a short list of the most important dates impacting your 2019 and 2020 coding, billing, quality payments, and more.

The MBI Transition Is Coming to a Close

If you’re not using your patients’ Medicare Beneficiary Identifiers (MBIs), then you’re in the minority.

In a policy change that commenced in April 2018, the Centers for Medicare & Medicaid Services (CMS) moved from the easily usurped Social Security number-laden, Health Insurance Claim Numbers (HICNs) to the randomly-selected, 11-character MBIs, protecting beneficiaries and preventing identity theft.

“Safeguarding our beneficiaries’ personal information continues to be one of our top priorities,” said Seema Verma, CMS administrator in a release. “These new cards will not only be easier for beneficiaries, but also provide the Medicare program with essential protections due to the new unique identifier on the cards.”

That transition from HICNs to MBIs on Medicare cards ends on Dec. 31, 2019, with a few exceptions.

Reminder: Providers must have updated systems that accept the new MBIs. Plus, practices need to ensure they’re using MBIs for referrals, and that their vendors and business partners are also utilizing MBIs, too. 

See the most updated CMS guidance on MBIs and the exceptions to the rule at  www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/downloads/SE18006.pdf.

Know These QPP End Dates

The last 90-day performance period deadline in 2019 for the Merit-Based Incentive Payment System (MIPS) categories Promoting Interoperability (PI) and Improvement Activities (IA) has passed — it was Oct. 3. That being said, there are a plethora of other Quality Payment Plan (QPP) dates in the months ahead that are just as critical to your future Medicare incentive pay.

The dates you should mark on your calendar include:

QPP 2018: Targeted review is now closed for the Performance Year (PY) 2018, but providers should expect their payment adjustments to begin on Jan. 2, 2020.

QPP 2019: The PY 2019 ends on Dec. 31, and that’s the last day to submit hardship and exception applications. You can start sending your performance data on Jan. 2 with an end date of March 31, 2020. You can expect your PY 2019 measures and payment details to be available for review in July 2020.

QPP 2020: The application to start a MIPS 2020 virtual group is open and runs through Dec. 31, 2019. Though CMS has not finalized its proposals for PY 2020, eligible clinicians (ECs) should plan on the first performance snapshot opening on Jan. 1 and closing on March 31, 2020.

Review QPP guidelines, submit measures, check data, and more at  https://qpp.cms.gov.

See These ICD-10 and CPT^® Code Start Dates

ICD-10: Coders should be aware that the ICD-10-CM and ICD-10-PCS have already updated for 2020. The new codes, revisions, and changes went into effect on Oct. 1 and afford providers and hospitals with a plethora of new offerings.

Find Medicare-related information on ICD-10 2020 at  www.cms.gov/Medicare/Coding/ICD10/index.html.

CPT^® 2020: Additions, revisions, and deletions won’t go into effect until Jan, 1, 2020, but now is a good time to update your coding policies.

Here’s why: On Aug. 14, CMS published its CY 2020 Medicare Physician Fee Schedule (MPFS) proposed rule in the Federal Register, which included a very slight suggested increase in the conversion factor from $36.04 to $36.09. The proposed $0.05-bump per relative value unit (RVU) barely meets the rising costs of inflation, making correct coding in 2020 particularly important if you want to ensure you’re getting the pay you deserve.

Read the MPFS proposed rule at  www.federalregister.gov/documents/2019/08/14/2019-16041/medicare-program-cy-2020-revisions-to-payment-policies-under-the-physician-fee-schedule-and-other.