Medicare Compliance & Reimbursement

CMS Allows TCM Code Reporting for Both New and Established Patients

You’ve got questions about the new transitional care management (TCM) codes 99495-99496? the Centers for Medicare & Medicaid Services (CMS) finally has some answers, thanks to a new FAQ document on the subject, which fills in the holes that CPT^® rules didn’t cover. CMS’s Ryan Howe alerted practices to the new information during the agency’s March 12 Open Door Forum, noting several important points about the TCM codes that you’ll have to keep in mind while billing, as follows:

·         When determining which place of service (POS) code to use on your TCM claim, you should use the location that “required the face-to-face visit,” CMS says in its March 12 document, Frequently Asked Questions about Billing Medicare for Transitional Care Management Services.

·         The 30-day TCM period begins on the date of discharge and continues for the next 29 days. Your date of service should be the 30^th day of care — not the first, Howe said during the CMS call.

·         CMS will reject any claims with dates of service prior to Jan. 30, 2013, since the codes became effective on Jan. 1 and only cover 30-day periods.

·         You can report TCM codes for both new and established patients, Howe said, which is a departure from CPT^® rules. “CPT^® guidance suggests that the codes are only for established patients, but for Medicare purposes, they can be reported for new patients as well,” he said.

·         If 30 days pass between discharge and the initial communication with the TCM practitioner, you cannot report TCM codes, Howe said during the call.

·         Medicare will only pay the first TCM claim received per beneficiary in one 30-day period beginning on the date of discharge, so if more than one practitioner reports the code for the same patient, only the doctor whose claim is received first will get paid.

·         If the patient dies before the 30^th day of transitional care management, you cannot report the TCM codes, since they cover a full 30 days. Instead, you’d report the appropriate E/M code.

For more on the TCM codes, read the FAQs at www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/PhysicianFeeSched/Downloads/FAQ-TCMS.pdf.

CMS Grants ‘CLIA-Waived’ Status to 9 Lab Tests

Practices will benefit from nine new lab tests now classified as “CLIA-waived,” thanks to a March 15 MLN Matters article on the topic.

According to article MM8212, CMS will now consider the following tests CLIA-waved. You’ll have to append modifier QW (CLIA-waived test) to these codes, which include the following services, among others:

·         82055 (Alcohol (ethanol); any specimen except breath) for Germain Laboratories AimStrip Alcohol Saliva.

·         G0434 (Drug screen, other than chromatographic) for Chemtron Biotech’s Chemtrue Single/Multi-Panel Drug Screen Cassette Tests, American Screening Corporation’s Multi-Drug Testing Cards and Cups, and UCP Biosciences’ UCP Compact Drug Test Cards and Cups.

·         85610 (Prothrombin time) for Coag-Sense Prothrombin Time Monitoring System (Professional use).

·         81003 (Urinalysis, by dip stick or tablet reagent for bilirubin, glucose, hemoglobin, ketones, leukocytes, nitrite, pH, protein, specific gravity, urobilinogen, any number of these constituents; automated, without microscopy) for CLIA waived Inc.’s Automated Urinalysis Test System.

To read the article in its entirety, visit www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/MM8212.pdf.

Physician Partners Can’t Sign F2F

Physician documentation practices that work in other areas just won’t cut it for the home health face-to-face requirement. So illustrates a newly updated tool on F2F from Home Health & Hospice Medicare Administrative Contractor NHIC.

“It is not acceptable for a physician partner of the certifying physician to sign a face-to-face encounter document for the partner while the certifying physician is out of town or otherwise unavailable,” NHIC stresses in the educational article on its website. “The face-to-face must be signed and dated by the certifying physician.”

The article, which includes pointers and examples of acceptable F2F forms and documentation, is at www.medicarenhic.com/providers/articles/HHFacetoFaceRev022813.pdf.

Alabama HHA Settles Whistleblower Suit For $150K

Make sure you’re following Medicare regulations, or one of your employees — even executives — may be only too happy to benefit from it.

Alabama home care company Techota is learning that lesson the hard way. The company that owns home health agencies operating in rural Alabama will pay $150,000 to settle a whistleblower lawsuit filed in 2011, reports The Birmingham News. Fifteen percent of that amount will go to registered nurse Veronica McDonald, who was the agency director of Techota’s Cahaba Valley Home Health at the time. Techota also must pay $27,500 for McDonald’s legal fees.

When McDonald was employed in October 2010, she “immediately became aware that CV Home Health’s business practices [were] designed to fraudulently inflate billing … by falsely representing the type and severity of patients’ medical conditions,” according to her lawsuit. “Ms. Mc-Donald was consistently instructed to falsify and alter patient assessments and nursing notes to create the false appearance that patients required skilled care and qualified for the Medicare home health benefit, resulting in false claims,” the newspaper reports.

For example: The lawsuit cites one case in which a patient requested that the home health nurses visit him at his job “because he was too busy to be home every time nurses came to provide treatment,” says McDonald’s law firm Frohsin & Barger in a release. In other cases, “nurses did little more than deliver cigarettes to people and sit with them watching television,” the release says.

The Department of Justice joined in a portion of the lawsuit. Techota also has agreed to enter a Corporate Integrity Agreement with the HHS Office of Inspector General.