In other news: You can still avoid additional e-scribe penalties.
As many veteran coders are aware, just because CPT Codes makes a change, you aren't guaranteed to see Medicare follow suit. That's the case with the latest "new versus established" patient definition that CPT® 2012 published, which won't have much impact on Part B claims, CMS reps said during a Jan. 24 Open Door Forum.
Background: CPT® 2012 states, "A new patient is one who has not received any professional services from the physician or another physician of the exact same specialty and subspecialty who belongs to the same group practice, within the past three years." The portions of the description that are new for 2012 are underlined.
What wasn't clear to many practices was that many payers -- including Medicare -- don't acknowledge subspecialty designations in their computer systems, making the new definition irrelevant.
"CMS claims processing systems do not recognize physician subspecialties," said CMS's Erin Smith during the call. "Therefore, CMS's instructions for billing new and established E/M codes has not changed for 2012. Physicians and practitioners should continue to interpret the phrase 'new patient' to mean a patient who has not received any professional services (that is, E/M or other face-to-face services such as a surgical procedure) from the physician or another physician in the same group practice and same specialty within the previous three years," she added.
Keep in mind: Interpreting a diagnostic test in the absence of a face-to-face service does not affect the designation of a new patient.
For Medicare services, the same specialty is determined by the physician's or the practitioner's primary specialty enrollment in Medicare, Smith said. In addition, she added, each type of non-physician practitioner has a specialty code designation. For instance, all PAs are specialty code 97. Recognized Medicare specialties can be found online at www.cms.gov/MedicareProviderSupEnroll/Downloads/JSMTDL-08515MedicarProviderTypetoHCPTaxonomy.pdf. Contact your MAC if you aren't sure which specialty your practitioners enrolled under.
A caller asked whether CMS is considering any enhancements to its system that will allow practitioners to register with Medicare as both a specialty and a subspecialty, but a CMS rep said the agency has no current plans to pursue any such change. "If you feel like your specialty is clearly defined, and you do specialized work that is separate from the specialty, you could apply for a separate specialty code," the CMS rep. said. But the CMS rep. confirmed that even if a physician currently registers with both a specialty and subspecialty, Medicare has no way for its computerized systems to actually look at the subspecialty.
E-Prescribing Penalties Kick In
Unfortunately for some practices (and their wallets), CMS's e-prescribing penalties have now taken effect. As you are probably aware, your practice is subject to a one percent payment adjustment on your Part B pay this year if you didn't successfully participate in e-prescribing during 2011 and you didn't qualify for any of the exemptions that CMS offered.
"The 2012 e-prescribing payment adjustment has started," said CMS's Lauren Fuentes during the same CMS conference call. "We'd like to advise eligible professionals to review their remittance advices for claims submitted for dates of service on or after Jan. 1, 2012."
"If you did not successfully e-prescribe in 2011, you still have an opportunity to avoid the 2013 payment adjustment [of 1.5 percent] by recording 10 e-prescribing events via claims for services provided between Jan. 1 and June 30, 2012," Fuentes said. She advised practices to visit www.cms.gov/erxincentive for more information on the penalties.