Medicare Compliance & Reimbursement

Industry Notes:

CMS Adds 16 Lab Tests to CLIA-Waived Status

Part B practices will benefit from three new tests that you'll be able to report as "CLIA-waived," thanks to an Oct. 21 CMS transmittal on the matter. According to MLN Matters article 2321, CMS will now consider these tests CLIA-waived.

You'll have to append Modifier QW (CLIA-waived test) to these codes, which include the following, among others:

  • 81003 -- Germaine Laboratories Inc. AimStrip Urine Analyzer and Mediwatch urinewatch Urine Analyzer
  • G0434 -- UCP Biosciences, Inc. Drug Screening Test Cups, Diagnostic Test Group Clarity Multiple Drug Screen Cups, and Jant Pharmacal Accutest Drug of Abuse Urine Cup Test

To read the complete article, which has an implementation date of Jan. 3, 2012, visit https://www.cms.gov/transmittals/downloads/R2321CP.pdf.

Keep a Careful Eye on Your Vaccination Reimbursement

Pay attention to your claims for flu vaccinations, or you may be losing Medicare reimbursement that's rightfully yours. "For September claims, influenza vaccinations were priced using the 2010-2011 influenza season rates, instead of pricing with the 2011-2012 rates," Regional MAC NHIC reported.

"Until the problem is solved, please hold your appeal requests," NHIC asks providers in an e-mail message. "As soon as the pricing files are updated you will be notified and you may request an adjustment of your claims." NHIC can't reprocess any incorrectly paid claims until the corrected pricing files are uploaded, the MAC explains.

CMS to Alert Some Practices Facing E-Prescribing Penalty Ahead of Time

Starting in 2012, practitioners will be subject to a one percent payment adjustment on your Part B pay if you don't successfully participate in e-prescribing. In 2013, that payment adjustment will go up to 1.5 percent, and in 2014 it will rise to two percent.

Deadline has passed: With the Nov. 1, deadline gone what hopes are there for those who haven't been successful e-prescribers as indicated by the reporting of the e-prescribing measure? Although some in the provider community had requested that CMS alert them if they will be subject to a penalty in 2012 and would therefore benefit from a hardship exemption, "that turns out not to be feasible," said CMS's Michael Rapp, MD, during an Oct. 18 Open Door Forum.

Timing: CMS is "trying to process the hardships as quickly as we can," CMS's Molly MacHarris said, and practices who have applied will get an email or a hard copy letter when CMS approves or denies the hardship application.

Looking ahead: Hardship exemption categories for the 2013 payment adjustments will be different from those currently on the application, which apply only to 2012. Information about the exemptions possible for 2013 will be in the 2012 Physician Fee Schedule Final rule, which will be available "around Nov. 1," MacHarris noted.

Watch out: The CMS communications won't offer absolute guarantees of which providers might be exempt, because they are based on preliminary PQRS reviews, not final reports, CMS reps added during the call.

Keep in mind: If an individual eligible professional (EP) or Group Practice Reporting Option (GPRO) participating in e-prescribing as a group submits G8553 (indicating a valid e-prescribing event) in addition to submitting a hardship or lack of prescribing privileges code, the hardship/lack of prescribing privileges will take precedence, CMS's Molly MacHarris noted.

Reimbursement, Regulatory Woes Cause HH Closures

Tighter Medicare and Medicaid reimbursement is causing some home care providers to close, and the worst of cuts haven't even hit yet. In Stamford, Conn., Visiting Nurse and Hospice Care of Southwestern Connecticut plans to shut down and turn over its remaining patient load to Masonicare Home Health & Hospice of Wallingford by late November, reports the Stamford Advocate.

Cuts to Medicare and insurance reimbursement rates and the loss of patients with greater ability to pay due to competition are factors in the decision to close, VNHC Board of Directors Chair Mark Santagata told the newspaper. He also cited face-to-face physician encounter requirements as a financial drain. Most of VNHC's staff is expected to be picked up by Masonicare, Santagata says. The agency employs about 69 full-time and 61 per diem staff.

In New York City, Home Services Systems in Astoria, Queens will be shutting down, says its parent HANAC, a Manhattan nonprofit social services organization, reports Crain's New York Business. HANAC cited the state's new managed care system for Medicaid payment, which is replacing its current fee for service system, as a reason.

Home Services' closure "could foreshadow a wave of closings of home health care agencies in New York," the newspaper predicts. Home Services' aides have been told they'll be able to serve their current patients under the new agencies they move to.

A Few Different Claims System Glitches Might Have Held Up Your Claims

Expect to see those problems soon resolved without any effort on your part.

Problem #1: "New billing transactions were incorrectly generating adjustments automatically with a 'G' as the third digit of the type of bill," HHH MAC CGS says in a message to providers. Because the system was automatically generating the adjustments, Requests for Anticipated Payment (RAPs) couldn't be adjusted," HHH MAC Palmetto GBA explains.

The FISS contractor fixed the problem, but the MACs now have to identify and inactivate the G adjustments, they say. CGS will move the inactivated adjustments to status/location I B9997, it says. Palmetto GBA will suspend the claims to a manual location, SM9009, then inactivate them.

CGS expects the correction process to take up to two weeks, it says. In the meantime, "the original claims should continue processing."

Problem #2: Some claims have suspended incorrectly in status and location SM94G2 and other claims have rejected incorrectly with reason code 37236 or 37237. But don't worry, NPI-related edits haven't gone into place yet.

Palmetto has fixed the problem causing the incorrect suspensions and rejections, and plans to process the claims in suspense status and location SM94G2 and to reprocess claims rejected with reason code 37236 or 37237 by Oct. 21, the MAC says.

Educate Docs' Billers To Boost Hospice Referrals

You may boost your hospice referrals if you help your referring physicians learn to navigate Medicare's physician billing system for hospice patients. "Medicare doesn't do a real good job of explaining that," noted Debra Sellers, director of home care services for St. John's Health System in Springfield, Mo, at the National Association for Home Care & Hospice annual meeting in Las Vegas. In her Oct. 4 session, Sellers recommended furnishing in-services for physicians' staff on how to bill Medicare for hospice patients' services.

Resource: For a tool from HHH Medicare Administrative Contractor CGS on how to bill Medicare for physician and nurse practitioner services related to the terminal diagnosis, go to www.cgsmedicare.com/hhh/education/materials/pdf/Physician_and_NP.pdf. A tool from Jurisdiction 4 Part B MAC Trailblazer Health describes how to bill both related and unrelated services from the physician's perspective: www.trailblazerhealth.com/Publications/Job%20Aid/HospiceModifiersGVGW.pdf.