Medicare Compliance & Reimbursement

Several MACs Open Up ICD-10 Testing Registrations

March 3 is less than a month away, so Part B MACs are prepping now for ICD-10 testing week, which contractors will host from March 3 through March 7. During that week, you’ll have an opportunity to submit claims with ICD-10 codes on them to ensure that you’re filling out your claim forms properly and that you’ll be completely prepared when ICD-10 takes effect on Oct. 1.

According to NGS Medicare, a Part B payer, you can register now for testing, but you’ll have to keep these items in mind when you start submitting your test claims:

• All ICD-10 test files must have a “T” in the ISA15 Test/Prod indicator field.
• You must use current dates of service for the claims — future dates will be rejected.
• You must use valid ICD-10 codes, and you cannot mix ICD-9 and ICD-10 codes on the claim — you can only use ICD-10 codes.

To confirm your registration for ICD-10 testing week and what you’ll need to prepare, visit your MAC’s website or contact your payer representative for details.

CMS: Time Is On Your Side For Psych Billing

Revisions to CPT’s psychiatry and psychotherapy codes last year led to helpful new coding opportunities for practices — but were also wrought with errors, CMS has determined. In an effort to quell the problems that these codes were creating, the agency issued MLN Matters article SE1407, which outlines the primary problems that MACs have seen with these codes.

“The main error with the revised psychiatry and psychotherapy codes is the failure to document the time spent on the E/M service separately from the time spent on the add-on psychotherapy service,” CMS says in the article, referring to codes +90833, +90836 and +90838. “When a beneficiary requires an E/M service with a psychotherapeutic service on the same day, by the same provider, both services are payable if they are significant and separately identifiable and billed using the correct codes.”

You cannot use the time spent providing psychotherapy to meet the criteria for your E/M service or vice-versa — you must compute the time separately for the two services, CMS says.

To read the complete article on this topic, visit www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/downloads/SE1407.pdf.

Medicare Strike Force Prosecutes Record Number Of Healthcare Fraudsters

If it feels like news about healthcare prosecutions is winding down, don’t be fooled — the news may have lessened, but the actual prosecutions have increased.

That’s the word from a recent Department of Justice news release, which indicates that a record number of health care prosecutions took place in Fiscal Year 2013 thanks to the efforts of the Medicare Fraud Strike Force.

“These record results underscore our determination to hold accountable those who take advantage of vulnerable populations, commit fraud on federal health care programs, and place the safety of others at risk for illicit financial gain,” said Attorney General Eric Holder in a Jan. 27 news release. “By targeting our enforcement efforts to ‘hot spots’ in nine cities, the Medicare Fraud Strike Force is allowing us to fight back more effectively than ever before.”

The strike force currently operates in the following nine cities: Baton Rouge, La.; Brooklyn, N.Y.; Chicago; Dallas; Detroit; Houston; Los Angeles; Miami and Tampa, Fla. Since its inception just seven years ago, strike force prosecutors have charged more than 1,700 defendants who have collectively billed the Medicare program more than $5.5 billion.

“The Medicare Fraud Strike Force is one of this country’s most productive investments,” said Acting Assistant Attorney General Mythili Raman of the Justice Department’s Criminal Division in the news release. “We are not only putting hundreds of criminals who steal from Medicare in prison, but also stopping their theft in its tracks, recovering millions of dollars for taxpayers, and deterring potential criminals who ultimately decide the crime isn’t worth it.”

Resource: To read the complete news release on this topic, visit www.justice.gov/opa/pr/2014/January/14-crm-082.html.

OIG Tells Provider It’s OK To Pay For Referrals

Providers that furnish a wide array of services may be able to pay for referrals to their non-federally paid business lines, a new Advisory Opinion from the HHS Office of Inspector General suggests.

In the opinion, a company that has a variety of senior living and nursing facilities asks if it’s OK to pay a third party placement agency for referrals to its facilities that don’t take federal or state reimbursement from Medicare or Medicaid. The possibility exists that while the referred patients currently don’t receive services reimbursed federally, they could progress to that stage and receive services from another business line in the company that does take Medicare and Medicaid reimbursement — namely, a skilled nursing facility or therapy offered by SNF therapy staff.

The conclusion: Paying for these referrals is OK, because the company stipulates that the referred patients must not be federally funded at all at the time of referral, the OIG says in the opinion. The arrangement is also acceptable because the fee for the referral is based on the patient’s first month or two of non-federally-paid services.

Finally, since the referral is to the communities that don’t take any federal funds at all, the OIG gives the arrangement a thumbs up. “Whether an individual resident originally placed by the Placement Agency will receive Federally payable services provided by an Affiliated Entity at some point in the future, due to a change in circumstances, is substantially speculative and outside the control of the Placement Agency,” the OIG judges.

For further details please contact the OIG at: http://oig.hhs.gov/contact-us.

Face-To-Face Rises To Top Of HHA Claims Denial List

For home health agencies, relying on physician office staff can help avoid reimbursement-draining denials. If you feel deluged with denials for face-to-face requirements, you’re not alone.

F2F is the top reason for denials of home health claims, according to Home Health & Hospice Medicare Administrative Contractor Palmetto GBA. “Face to Face Encounter Requirements Not Met” accounted for nearly 74 percent of denials for 32x claims and more than 77 percent of 33x claims, the MAC says on its website.

“The documentation of the encounter must include a brief narrative, composed by the certifying physician, describing how the patient’s clinical condition as observed during that encounter supports the patient’s homebound status and need for skilled services,” Palmetto reminds agencies.

Tip: “The certifying physician may dictate the face-to-face encounter documentation content to one of the physician’s support personnel to type,” the MAC offers. “The documentation may also be generated from a physician’s electronic health record.”

For more information on F2F denials and how to avoid them, buy Eli’s Face-To-Face Documentation Handbook 2014 at www.codinginstitute.com/face-to-face-documentation-handbook-2014.html.