Medicare Compliance & Reimbursement

Tip: Know the new CPT^® 2018 codes that go live on Jan. 1.

Medicare reimbursement is often determined by how well your organization keeps on top of healthcare's important updates and changes. And sometimes missing a CMS deadline or submitting last year's codes will set your practice back financially.

Take a look a these five important deadlines that may affect your Medicare pay:

1. QPP 2017 Transition Hardship Deadline

If you happen to be a Medicare Part B provider in a county impacted by one of the natural disasters that plagued the United States this past fall, you may be eligible for a hardship exception under the Merit-Based Incentive Payment System (MIPS) for your 2017 transition year reporting. "Our Extreme and Uncontrollable Circumstances policy applies to MIPS eligible clinicians in affected areas," says CMS in the interim final rule on the subject. "But doesn't apply to MIPS eligible clinicians in MIPS Alternative Payment Models (MIPS APMs) in 2017 (such as the Medicare Shared Savings Program)."

Some of the reasons for delayed submission due to the hurricanes and wildfires CMS lists include:

• Lack of internet capabilities
• Lack of working Certified EHR Technology (CEHRT)
• Other extreme or uncontrollable circumstances that impede the submission of your 2017 MIPS measures

Deadline: Dec. 31, 2017 is the deadline to submit a Quality Payment Program (QPP) hardship application to CMS for your transition year 2017 MIPS measures submissions.

Resource: To look at the CMS fact sheet on the QPP Extreme and Uncontrollable Circumstances interim final rule, visit www.cms.gov/Medicare/Quality-Payment-Program/Resource-Library/Interim-Final-Rule-with-Comment-fact-sheet.pdf.

2. QPP 2018 Virtual Groups

The "virtual group" option for sole providers and grouppractices of 10 or less to report their MIPS measures together virtually was confirmed in the QPP Year 2 final rule and is a bonus for smaller practices. Despite limited requirements to form a virtual group, many Part B clinicians are unaware of the new reporting opportunity.

Deadline: In the final rule, CMS extended the virtual group participation deadline from Dec. 1 to Dec. 31, 2017 for 2018 MIPS measures that impact 2020 pay.

Reminder: "Virtual group elections have to include at least the information about each TIN [Tax Identification Number] and NPI [National Provider Identifier] associated with the virtual group and the virtual group representative's contact information," says CMS guidance on the QPP Year 2. "The virtual group representative would need to acknowledge that a written formal agreement has been established between each member of the virtual group prior to election."

Resource: For more detailed information on virtual groups and the QPP Year 2 changes, visit www.cms.gov/Medicare/Quality-Payment-Program/Resource-Library/Slides-11-14-QPP-Year-2-public-webinar.pdf.

3. CPT^® Code Options and Revaluations

As Medicare practices prepare their billing systems for 2018, it's a good time to take note of any new payment values that will take effect on Jan. 1 as well as review new CPT® code options and changes.

Conversion factor: CMS released its Medicare Physician Fee Schedule (MPFS) final rule on Nov. 2, which include 1,250 pages of material that confirms the policies that the agency has set for the new year. In its guidance, the agency sets the final 2018 conversion factor at $35.99, an increase over the current conversion factor, which is $35.89.

Tip: Remember that to calculate the fee for a Medicare service, you'll multiply the conversion factor by the total relative value units (RVUs). For instance, code 99213 currently has a total RVU of 2.06 for 2017, which comes out to a fee of $73.93 when multiplied by the 2017 conversion factor of 35.89.

Start date: CPT^® 2018 additions, revisions, and deletions will go into effect on January 1, 2018 as will code revaluations. Prepare now for CPT^® 2018 to stay on top of everything you need to know and get the pay you deserve.

Resource: To read the MPFS final rule published in the Federal Register, visit www.gpo.gov/fdsys/pkg/FR-2017-11-15/pdf/2017-23953.pdf.

4. New CMS-855 Form Requirement for Provider EFTs

For 2018, CMS has altered its Electronic-Funds Transfer (EFT) Authorization Agreement form, commonly known as CMS-855.

The form overhaul offers providers and suppliers more clarity on EFT authorizations. The revised CMS-855 allows users to name the "financial institution's contact person" and report whether the funds transfer is for an individual or going to a group or organization. The update also adds "four digits to the 'Provider's/Supplier's/Indirect Payment Procedure Entity's Account Number with Financial Institution,' making it consistent with the industry standard," said MAC Cahaba GBA in a post on the changes.

Deadline: CMS-855 will be official and required starting on Jan. 1, 2018.

Resource: For more information on the Electronic-Funds Transfer Authorization Agreement form changes, visit www.cahabagba.com/news/revised-cms-588-electronic-funds-transfer-authorization-agreement/.

5. Medicare Card and Number Transition

It's been a long time coming, but CMS begins its Medicare card and number transition in less than four months. The changes require updated systems and new business processes to accept the new beneficiary numbers - that will impact your 2018 payments.

Change review: Due to a rise in identity theft and the "illegal use of Medicare benefits," MACRA mandated that all Medicare cards be replaced with a new number by 2019. The updated cards will include a brand-new number called the Medicare Beneficiary Identifier, or MBI, and CMS will start mailing out the new cards in April 2018.

You may be aware of the change, but is your staff prepared for the card transition or are your systems ready to address the new numbers? "Your systems must be ready to accept the new MBI by April 1, 2018," the agency insists. "It's especially important that you're ready for people who are new to Medicare in April 2018 and later because they'll only get a card with the MBI."

Good news: "There will be a transition period when you can use either the HICN or the MBI to exchange data and information with us," notes CMS in its MBI fact sheet. "The transition period will start April 1, 2018, and run through December 31, 2019."

Start date: Before the April 1, 2018 start date, alert your patients, software vendors, and business partners of the Medicare card and number overhaul, suggests CMS. It is important that your billing system be ready to do the following on day one, according to the MBI guidance:

• Recognize and accept the new Medicare Beneficiary Identifiers.
• Revise your practice protocols for Medicare Railroad Retirement Board patients because they won't be distinguished by their card numbers anymore.
• "Update your practice management system's patient numbers to automatically accept the new Medicare number or MBI from the remittance advice (835) transaction," suggests CMS.

Resources: To utilize the CMS fact sheet on the new MBIs, visit www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/Downloads/Transi­tiontoNewMedicareNumbersandCards-909365.pdf.

To access various links and forums related to Medicare card changes, visit www.cms.gov/Medicare/New-Medicare-Card/index.html.