Medicare Compliance & Reimbursement

• As most practices know, E/M services are included in the global packages of most major surgeries. But what happens if you bill the surgery without performing that included E/M? A new OIG report suggests that you might have to get used to less surgical pay if you are failing to perform E/Ms.

On April 20, the OIG released its report, "Nationwide Review of E/M Services Included in Eye and Ocular Adnexa Global Surgery Fees for Calendar Year 2005," which noted that out of 300 global surgeries that the OIG reviewed, 240 of the surgeries did not include a qualifying E/M, even though surgeons were paid for these E/M services via the global surgical payment. This resulted in $97.6 million in overpayments to surgeons.

As a result, the OIG recommends that CMS either adjust the number of E/M services included in eye surgeries, or change the fee schedule amounts to reflect the unperformed E/M services.

• The Joint Commission has allowed for more exemptions to its unannounced survey policy and has extended the advance notice timeframe. Home care providers that qualify for an exemption will now receive seven days' notice instead of five, says the accrediting body (formerly JCAHO).

The Oakbrook Terrace, Ill.-based organization has added "small, non-deemed health and hospice organizations, if not part of a hospital" and "small home care organizations that provide only one service" to its timeframe exemption list.

"We found that unannounced surveys can disrupt the delivery of patient care in very small home care organizations," Debra Zak, former executive director of the Commission's Home Care Accreditation Program, says on the accrediting body's Web site.

• CMS has clarified that hospices won't have to report visits in 15-minute increments for inpatient settings even if the inpatient facility is their own, Janet Neigh with the National Association for Home Care and Hospice says, based on the April 24 Transmittal No. 6440 (CR 1713).

CMS is "continuing to exempt visit reporting by nonhospice staff when hospice patients in a contract facility are receiving [General Inpatient care]," the transmittal notes.

Providers should continue to report the number of GIP visits, however, CMS adds.

• CMS is putting a new claims edit in place starting Oct. 5 for prospective payment system episodes dated Jan.

1, 2008 or later, according to April 24 Transmittal No. 6393 (CR 1714).

Under the edit, the Medicare claims system will allow home health agencies to change the fifth digit of the HIPPS code, which represents the nonroutine supplies level, only from a number to its corresponding NRS-level letter or vice versa. When PPS refinements instituting NRS payments took effect in January 2008, CMS lifted the requirement that the HIPPS code's fifth digit match on the request for anticipated payment (RAP) and final claim. That's so agencies could record that they provided no supplies when they first said on the RAP they would, or vice versa.

• May is National Arthritis Awareness Month, and CMS is taking the chance to promote awareness among healthcare providers and remind them that Medicare provides coverage for a range of osteoarthritis treatments.

In short, "National Arthritis Awareness Month provides an excellent opportunity for healthcare professionals to help increase awareness, knowledge, and understanding of strategies for managing arthritis," CMS said in an email to providers. The agency listed several ways that providers can help patients with arthritis, including:

• Stay informed of the latest clinical guidelines for prevention, diagnosis, and treatment.

• Familiarize yourself with Medicare's coverage of the continuum of treatments for osteoarthritis, ranging from physician office visits related to osteoarthritis care to total joint replacement surgery.

• Talk with your patients about risk factors for arthritis, prevention methods they can take to reduce their risk. factors, and lifestyle changes that can improve joint health

• Encourage eligible Medicare patients to take advantage of Medicare's benefits that can help improve physical functions and decrease pain associated with arthritis.