Practice Management Alert

If you-ve had Transmittal 87 on incident-to billing on your desk, waiting to find time to review the 23-page document, you may as well use it for scrap paper now. On the very day that practices were supposed to start using the new incident-to guidelines, CMS rescinded Trans-mittal 87, noting that the document "will not be replaced at this time."

Possible rationale: Several medical associations expressed concern about the new guidelines, saying that practices didn't have enough time to learn all of the regs- nuances in the one-month period between the transmittal's publication (May 2) and the implementation date (June 2).

In a May 21 letter to CMS Acting Administrator Kerry Weems, the AMA and the Medical Group Management Association (MGMA) asked CMS to delay the transmittal's implementation and to "reconsider the administratively burdensome and costly documentation requirements" that the incident-to transmittal would have required. CMS, however, did not indicate that the AMA/MGMA letter had anything to do with its intention to scrap Transmittal 87. In fact, CMS did not reveal any reason at all for choosing to rescind the transmittal.

"Medicare usually reissues rescinded transmittals," says Barbara J. Cobuzzi, MBA, CPC, CPC-H, CPC-P, CPC-I, CHCC, president of CRN Healthcare Solutions, a coding and reimbursement consulting firm in Tinton Falls, N.J. "Since this transmittal was rescinded due to the short time frame for implementation, I would not be surprised to see it reissued with a larger time frame for implementation."