Otolaryngology Coding Alert

Consider some important MIPS-related changes.

The 2021 Medicare Physician Fee Schedule (MPFS) final rule includes a series of notable changes and policy revisions that will have a profound impact on your otolaryngology practice. However, in order to understand the scope of these changes, it’s important that you look beyond the evaluation and management (E/M) highlights to consider what else within the final rule may have an influence on your day-to-day coding.

“The overwhelming focus for the MPFS final rule changes has been on the 2021 E/M changes,” says Chelsea Kemp, RHIT, CCS, COC, CDEO, CRC, CEDC, CGIC, HIM coding specialist at Dignity Health Yavapai Regional Medical Center in Prescott, Arizona. “However, there are many other important changes coming in 2021 that require careful review and preparation for any coding professional,” Kemp explains.

Specifically, there are two areas within the final rule that otolaryngology coders, billers, and physicians should home in on. First, have a look at the revised rules on diagnostic testing and medical record review designed to give nonphysician practitioners (NPPs) an expanded level of access and control. Next, among a host of changes to Merit-based Incentive Payment System (MIPS) measures, there’s a few otolaryngology measures you should pay special attention to.

Round out your 2021 MPFS final rule knowledge with these two important areas of consideration.

Consider Loosened NPP Supervision Restrictions

Under the MPFS regulation at §410.32(b)(1), the Centers for Medicare & Medicaid Services (CMS) has amended the guidelines on diagnostic supervision to allow for certain NPPs to now perform diagnostic supervision services without a “general level of physician supervision.” In other words, NPPs are now eligible to perform and bill for specific qualifying otolaryngology diagnostic services without a physician present. Previously, NPPs were allowed to order diagnostic tests, but only the patient’s physician could supervise the diagnostic testing.

In an otolaryngology, allergy, or audiology practice, some of these tests may include 92612 (Flexible endoscopic evaluation of swallowing by cine or video recording), performed by a speech language pathologist; or 95024 (Intracutaneous (intradermal) tests with allergenic extracts, immediate type reaction, including test interpretation and report, specify number of tests), performed by a nurse practitioner (NP).

Biller’s note: When billing for supervision services involving an NPP, make sure that you adhere to your state laws and payer-specific rules. “For example, in New Jersey the medical board requires that anyone doing allergy testing or administering allergy shots must be, at a minimum, an NP,” says Barbara J. Cobuzzi, MBA, CPC, COC, CPC-P, CPC-I, CENTC, CPCO, of CRN Healthcare in Tinton Falls, New Jersey. “Furthermore, Horizon BCBS still requires that the physician be the provider that administers the testing,” Cobuzzi adds.

The justification for the change to allow NPPs to supervise diagnostic tests is based on the fact that NPPs are already eligible to perform such services under many states’ scope of practice rules. These rules were initially implemented in May of 2020 as a means of easing the burden of providers during the public health emergency (PHE). Following suit with a variety of other previously “temporary” guidelines, CMS has decided to implement this new diagnostic supervision policy permanently. According to CMS, these NPPs “are authorized to receive payment under Medicare Part B for the professional services they furnish either directly or ‘incident to’ their own professional services.”

With respect to otolaryngology, CMS considers the following sets of NPPs eligible for diagnostic supervision services:

• NPs,
• Clinical nurse specialists (CNSs),
• Physician assistants (PAs), and
• Certified registered nurse anesthetists (CRNAs).

Refresher: In the 2020 MPFS final rule, CMS added further autonomy to the role of NPP by stating that both physicians and NPPs can “review and verify documentation entered into the medical record by members of the medical team for their own services that are paid under the MPFS.”

Factor in These Key ENT MIPS-Related Changes

In order to stay on top of your MIPS reporting, you should consider a few substantiative changes made to existing measures to consider for applicable clinical encounters.

First, have a look at quality measure 065, which you’ll now report for a “Appropriate Treatment for Upper Respiratory Infection (URI).” This is revised from previous years, in which reporting was exclusively designated for children 3 months to 18 years of age. It now includes patients of “3 months-17 years, 18-64 years, 65 years and older.” You’ll also find the description is revised to read the following: “Percentage of episodes for patients 3 months of age and older with a diagnosis of upper respiratory infection (URI) that did not result in an antibiotic dispensing event.” Previously, the guidance only allowed MIPS reporting when antibiotics were prescribed on or 3 days “after the episode.”

Following the same lead as measure 065, you’ll find similar changes to measure 066, which is revised from: “Appropriate Testing for Children with Pharyngitis” to: “Appropriate Testing for Pharyngitis.” You’ll now report this measure for any patient “3 years and older with a diagnosis of pharyngitis that resulted in an antibiotic dispensing event and a group A streptococcus (strep) test.”

Next, have a look at the CMS document titled “Telehealth Guidance for Electronic Clinical Quality Measures (eCQMs) for Eligible Professional/Eligible Clinician 2021 Quality Reporting.” In it, you’ll find an updated list of measures that CMS deems eligible and ineligible for reporting as a telehealth visit. With respect to otolaryngology, you’ll see that MIPS measure 093: “Acute Otitis Externa (AOE): Systemic Antimicrobial Therapy – Avoidance of Inappropriate Use,” is now eligible for telehealth reporting in 2021. You’ll also find MIPS measures “Biopsy Follow-Up;” 279: “Sleep Apnea…;” and 331/332: “Adult Sinusitis…” are now included as telehealth eligible.

For a complete list of changes to each of the above MIPS measures and others that may impact your reporting, see “Group D: Previously Finalized Quality Measures with Substantive Changes Finalized and Not Finalized for the 2023 MIPS Payment Year and Future Years” at the following link:

https://www.federalregister.gov/documents/2020/12/28/2020-26815/medicare-program-cy-2021-payment-policies-under-the-physician-fee-schedule-and-other-changes-to-part

Furthermore, you can see a complete list of telehealth eligible, and ineligible, MIPS measures at the following CMS link: https://ecqi.healthit.gov/sites/default/files/2021-eCQM-Telehealth-Guidance-Document-With-QRDA-Update-508.pdf.