Medicare Compliance & Reimbursement

Plus:  AHIMA asks CMS for more time before moving to ICD-10.

With all the discussion of new CPT codes, it's easy to let the new Category III codes fall through the cracks. But CPT 2009 will offer a few Category III codes for you to use effective Jan. 1. A sampling of the new Category III codes follows:
 • 0184T -- Excision of rectal tumor, transanal endoscopic microsurgical appraoch (ie, TEMS)
 • 0186T -- Suprachoroidal delivery of pharmacologic agent [does not include supply of medication]
 • 0188T -- Remote real-time interactive video-conferenced critical care, evaluation and management of the critically ill or critically injured patient; first 30-74 minutes
 • 0195T -- Arthrodesis, pre-sacral interbody technique, including instrumentation, imaging (when performed), and discectomy to prepare interspace, lumbar; single interspace
 As with the Category I 2009CPT codes, you'll have to wait until CMS releases the 2009 Fee Schedule before it's clear whether Medicare will reimburse you for these
new codes.

IN OTHER NEWS
 • The American Health Information Management Association (AHIMA) thinks ICD-10 is a positive move for the industry -- but contends that health care practitioners need more time to adapt to the new system.
 According to an Oct. 10 letter from AHIMA's Vice President of Policy and Government Relations Dan Rode, MBA, FHFMA, an additional year would help practices adjust to the code set.
 "AHIMA urges HHS to issue a final rule for the implementation of ICD-10-CM and ICD-10-PCS before the end of this year and establish an ICD-10 and ICD-10-PCS implementation date that is no later than Oct. 1, 2012," the letter indicates.
 This would allow practices an extra year -- the current proposed implementation date is Oct. 1, 2011.
 To read the entire AHIMA  letter, visit www.ahima.org/ icd10/documents /comments_icd10_nprm.pdf.

 • If you owe back taxes, the IRS can now come calling in non-traditional ways -- in fact, it might just garnish some of your Medicare reimbursement until you've paid back what you owe.
 According to Centers for Medicare & Medicaid Services Transmittal 368, with an effective date of Oct. 1, businesses that owe tax money to the IRS may face levies.
 "CMS may reduce federal payments subject to the levy by 15 percent, or the exact amount of the tax owed if it is less than 15 percent of the payment," the transmittal indicates. "The levy is continuous until the overdue taxes are paid in full, or other arrangements are made to satisfy the debt."
 What this means to you: If you owe back taxes, the IRS will arrange to take 15 percent of your Medicare reimbursement until your levy has been satisfied, says attorney Michael Schaff with Wilentz, Goldman and Spitzer in Woodbridge, N.J.

This means that you will continue collecting reimbursement, but the payment will be reduced by 15 percent until you no longer owe the IRS money.

Some providers will say, "I can't afford to pay these back taxes yet, I have to pay my ... staff first," suggests Randall Karpf with East Billing in East Hartford, Conn. "But the CMS transmittal confirms that the government will make that decision for you. Some [providers] may have to cut back on other expenses until their levies are paid off."

Medicare's signal: If the government has garnished part of your Medicare reimbursement, you'll see the code "WU" in the PLB03-1 data field, along with Medicare's phone number in case you have questions about the adjustment.

To read the complete CMS transmittal, visit the CMS Web site at www.cms.hhs.gov/transmittals/downloads/R367OTN.pdf. To review the related MLN Matters article, visit the CMS Web site at www.cms.hhs.gov/MLNMattersArticles/downloads/MM6125.pdf.