Medicare Compliance & Reimbursement

One MAC OKs RNs/LPNs providing annual wellness visits.

If your practice sees patients with insurance coverage through Noridian, you'll need to take note of a new chemotherapy drug administration rule from the (MAC). Ensure you're properly reporting injections for these patients before you start seeing denials.

As of March 1, you won't be able to use administration code 96402 (Chemotherapy administration, subcutaneous or intramuscular; hormonal anti-neoplastic) with some drugs as you have in the past. According to information that Noridian first released on May 6, 2010, the preparation and administration of Gonadotropin-releasing hormones (GnRH), also known as luteinizing-hormone-releasing hormones (LHRH) does not meet the CPT^® manual requirements of the use of the chemotherapy administration codes.

Noridian issued a notice that stated: "Medicare considers the use of the chemotherapy administration codes to appropriately describe the parenteral administration of the following drugs ONLY:

Turn To 96372: You'll no longer be able to report 96402 for the administration. Instead of chemotherapy drug administration codes 96401-96549, you should choose a code from the 96360-96379 code series, according to Noridian.

AWVs: CMS staffers confirmed that MACs can determine whether they'll allow licensed practical nurses (LPNs) and registered nurses (RNs) to perform annual wellness visits (AWVs) and collect from Medicare for those services. That's the word from a Feb. 22 CMS Open Door Forum, where practices called in with several questions affecting Part B providers.

One caller phoned into the forum to ask about a Q&A posted on the Web site of WPS Medicare, a Part B payer in four states, which asks whether an RN or LPN can perform "the entire annual wellness visit (AWV, G0438-G0439)." WPS responds on the site, "Yes, an RN or LPN can perform the visit. They need to be under the direct supervision of a physician and the state license needs to allow for them to do all the components of the service."

"Remember, the LPN's not billing," said CMS's William Rogers, MD, reminding the caller that the visit would be billed under the physician's NPI as "incident to." But the caller still considered it "odd" that an LPN could perform an AWV, since it's similar to an E/M service.

"It's a different sort of service -- there's not really any clinical judgment involved," Rogers said. "It's a service which includes a lot of sort of administrative steps, verifying that people have certain preventive services done and things like that, and so it is intended to be a collaborative service."

Keep in mind that CMS does not have a national policy allowing LPNs and RNs to perform AWVs, but reps from the agency confirmed that it's within the rights of the individual MACs to make this determination.