Medicare Compliance & Reimbursement

Industry Notes:

Are You Being Double-Penalized for EHR Non-Participation?

As if taking a one percent hit on your Medicare payments isn’t painful enough, some practices are reminded twice about their EHR penalties. Fortunately, however, they aren’t getting twice the deductions taken out of their pay.

Background: Eligible professionals who are not meaningful users of electronic health records (EHRs) are seeing a one percent negative payment adjustment on their Medicare Physician Fee Schedule charges now that 2015 has arrived. Unfortunately, a glitch in the system at Part B MAC National Government Services (NGS) has caused twice the notifications on that matter.

“Due to a system issue, duplicate remittances were issued for providers subject to EHR negative payments,” the MAC said in a Feb. 23 statement. “These duplicate remittances are not associated with a claim adjustment, thus no claim payment was issued. A fix was installed on Feb. 6. You may keep the duplicate remittance for your records.” 

Comply With the TCPA

What does 2015 have in store for HIPAA compliance requirements and pitfalls? A major concern for the healthcare industry in terms of privacy and security is compliance with yet another federal law: the Telephone Consumer Protection Act (TCPA). Due to the rising trend of using technology like text messaging to patients’ mobile phones for appointment reminders, providers need to be wary of their compliance with the TCPA, said attorney Linn Foster Freedman in analysis for law firm Nixon Peabody.

“TCPA continues to be a minefield for compliance,” Freedman warned. In fact, a case was filed in late 2014 against a pharmacy for texting patients with refill reminders. “TCPA requires that the express written consent of the patient must be obtained prior to texting a patient,” Freedman instructed. “If you plan to text patients at all, take the time now to update your patient intake form to include ‘express written consent’ to text the patient on their cellphone.” 

Know — And Report — Facility NPIs When Your Hospice Patients Aren’t At Home

If reason code 34952 errors are killing your hospice claims, you’re not alone. Medicare Administrative Contractor “CGS has identified reason code 34952 as one of the top Claim Submission Error (CSE) errors,” it says on its website. “The reason code 34952 indicates that a service facility National Provider Identifier (NPI) is required on the claim, but was not reported.”

Do this: For dates of service on or after April 1, 2014, report a service facility NPI when billing any of the following place of service HCPCS codes: Q5003 — hospice care provided in nursing long term care facility (LTC) or non-skilled nursing facility (NF); Q5004 — hospice care provided in skilled nursing facility (SNF); Q5005 — hospice care provided in inpatient hospital; Q5007 — hospice care provided in long term care hospital (LTCH); and Q5008 — hospice care provided in inpatient psychiatric facility, CGS instructs.

“The service facility NPI must be reported in Loop 2310E (when billing in the 5010 electronic claim format) or the SERV FAC NPI field in the Fiscal Intermediary Standard System (FISS) on Claim Page 03,” CGS explains.