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Monday, May 10th, 2010
On March 23, 2010, President Obama signed into law the Affordable Care Act (ACA). Section 3401(i) of the ACA imposes a 0.25 percentage point reduction to the OPPS market basket for Calendar Year (CY) 2010, effective for services furnished on or after January 1, 2010.
The Centers for Medicare & Medicaid Services is working to expeditiously implement Section 3401(i) of ACA. Providers will begin seeing payments under this provision in the late May/early June time frame. Be on the alert for more information about this provision and its impact on past and future claims.
Posted in MEDICARE UPDATES | No Comments »
Thursday, May 6th, 2010
Recoupment is the act of recovery by a Medicare contractor—such as National Government Services or by a recovery audit contractor (RAC)—of any outstanding Medicare debt by reducing present or future Medicare remittance advice payments and applying the amount withheld to the indebtedness. It applies to the recovery of funds for all Medicare Part A and Medicare Part B claims for which a demand letter is issued.
The Medicare Prescription Drug, Improvement, and Modernization Act (MMA) of 2003, Section 935 amended Title XVIII of Social Security Act to add a new paragraph to Section 1893(f)(2)(a), which required the Centers for Medicare & Medicaid Services (CMS) to change:
Previously, if a provider elected to appeal an overpayment determination prior to enactment of Section 935 of the MMA, it did not affect Medicare’s ability to recover the debt. Section 935 of the MMA amended that process to protect providers during the initial stages of the appeal process at both the first and second levels of appeal by limiting the recoupment process while the appeal process is underway. Provider appeal rights and the time frames for filing an appeal have not changed.
Steps in the Recoupment Process—Medicare Part A
If however, an adjustment is considered to be an overpayment and the 935 rules apply, the claim will be marked as being eligible for limitation on recoupment provisions.
The RAC claims will also be adjusted. The RAC will send files identifying claims to be adjusted to National Government Services, and we will process the adjustments.
National Government Services Demand Letters
RAC Demand Letters
Medicare will stop recoupment:
Providers can Choose How to Respond to the Demand Letter
Providers have a choice regarding how they want to respond to demand letter.
Demand Letter Tips
The Appeals Process
Level 1 Redetermination and Level 2 Reconsideration
Only submission of a valid and timely request for redetermination will start the appeal process in motion. Correspondence stating “intent” to appeal will not be accepted.
Upon the receipt of a provider’s valid and timely request for a redetermination of overpayment, National Government Services will take the following steps:
There are three possible outcomes for a redetermination or reconsideration:
Note: The MRN issued is the same letter used for any type of appeal. It is not specific to the MMA Section 935 recoupment process.
If the provider chooses to submit a request for reconsideration to the QIC, the QIC will notify National Government Services of their receipt of the valid and timely request.
National Government Services will:
For financial reporting purposes, the status of the debt during the redetermination and reconsideration appeal levels is “appeal.”
When recoupment begins or resumes, the status will be changed to reflect the status “eligible for offset.”
Level 3 Administrative Law Judge
The third level of appeal is the administrative law judge (ALJ). It is important at this level to understand that whether or not a provider subsequently appeals overpayment to the ALJ, Medicare appeals council or federal court, Medicare will continue to recoup until the debt is satisfied in full.
If an appeal is decided in favor of the provider by the ALJ (level 3) or later, Medicare is required to pay the provider interest that is added to the refund returned to the provider.
Thank you,
National Government Services, Inc.
Corporate Communications
If you want to update your profile or unsubscribe from any of our lists, you will first need to set up a password for your account. To do this, click on the Login link from the Listserv page on the www.NGSMedicare.com Web site, then select one of the following:
§ Login – existing / transferred subscribers can obtain a new password and subscribe or unsubscribe from lists
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§ Join – new subscribers can create an account and subscribe to lists
Posted in MEDICARE UPDATES | No Comments »
Wednesday, May 5th, 2010
The National Government Services Local Coverage Determination (LCD) for Debridement Services (L27373) will have revisions added in June 2010 which provide additional information regarding coverage and documentation of surgical debridement services. Listed are the documentation requirements as outlined in the upcoming revision.
The patient’s medical record must contain documentation that fully supports the medical necessity for services included within this LCD. (See Indications and Limitations of Coverage section of LCD.) This documentation includes, but is not limited to, relevant medical history, physical examination, and results of pertinent diagnostic tests or procedures.
The medical record should include the following information:
1)An operative note or procedure note for the debridement service. This note should describe the anatomical location treated, the instruments used, anesthesia used if required, the type of tissue removed from the wound, the depth and area of the wound and the level of debridement. The immediate post procedure care and follow-up instructions should also be included. The current procedural terminology (CPT) code submitted should reflect the level of debridement and not necessarily the depth of the wound which may not always be the same.
2) Identification of the wound location, size, depth and stage either by description and/or a drawing or photograph.
3) A description of the type(s) of tissue involvement, the severity of tissue destruction, undermining or tunneling, necrosis, infection or evidence of reduced circulation. If infection has developed, the patient’s response to this infection should be described.
4) The patient’s comorbid medical and mental condition, and all health factors that may influence the patient’s ability to heal tissue, such as, but not limited to the following: mental status, mobility, infection, tissue oxygenation, chronic pressure, arterial insufficiency/small vessel ischemia, venous stasis, edema, type of dressing, chronic illness such as diabetes mellitus, uremia, chronic obstructive pulmonary disease (COPD), malnutrition, congestive heart failure (CHF), anemia, iron deficiency, and immune deficiency disorders.
5) A determination of the initial treatment plan to include the expected frequency and duration of the skilled treatment and the potential to heal. Continuation of treatment plan with ongoing evidence of the effectiveness of that plan, including diminishing area and depth of the ulceration, resolution of surrounding erythema and/or wound exudates, decreasing symptomatology, and overall assessment of wound status (such as stable, improved, worsening, etc.). Appropriate changes in the ongoing treatment plan to reflect the clinical presentation must be present in the record.
The documentation must include that if indicated, ongoing pressure relief has been prescribed, for example, shoe inserts, modifications, padding, frequent position changes, etc. and monitoring is occurring.
In cases of excessive frequency or prolonged duration of treatment, documentation should include an evaluation for possible infection (e.g., culture and sensitivity), osteomyelitis (e.g., x-ray), and treatment of any infection by antibiotics. Any other conditions that may significantly affect wound healing should also be appropriately addressed in the medical record.
Photographic documentation of wounds either immediately before or immediately after debridement is recommended for prolonged or repetitive debridement services (especially those that exceed five extensive debridements per wound [CPT code 11043 and/or 11044]). If the provider is unable to use photographs for documentation purposes, the medical record should contain sufficient detail to determine the extent of the wound and the result of the treatment.
Medical records must be made available to Medicare upon request.
Last Modified: 4/28/2010
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Wednesday, May 5th, 2010
Providers have expressed interest in the ability to submit medical records for review electronically. National Government Services is pleased to announce that we are now able to accept medical records submitted on a CD-ROM. We prefer that providers load the documents onto the CD-ROM using WinZip®.
Documents included the CD-ROM should be for the same National Government Services business department. Do not send records intended for the Medical Review Department on the same CD-ROM as records submitted for the Appeals Department.
It is important that the you include a cover sheet with each CD-ROM. The cover sheet should include:
Please download and use the Cover Sheet for Electronically Submitted Medical Records
to submit with each CD-ROM. Please note that this form is available for your convenience but is not required.
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Monday, May 3rd, 2010
2010 Physician Quality Reporting Initiative & Electronic Prescribing Incentive Program
National Provider Call with Question & Answer Session
The Centers for Medicare & Medicaid Services’ (CMS) Provider Communications Group will host a national provider conference call on the 2010 Physician Quality Reporting Initiative (PQRI) and Electronic Prescribing Incentive Program (eRx). This toll-free call will take place from 1:30 p.m. – 3:00 p.m., EDT, on Wednesday, May 12, 2010.
The PQRI is voluntary quality reporting program that provides an incentive payment to identified individual eligible professionals (EPs), and beginning with the 2010 PQRI, group practices who satisfactorily report data on quality measures for covered Physician Fee Schedule (PFS) services furnished to Medicare Part B Fee-For-Service (FFS) beneficiaries.
The PQRI was first implemented in 2007 as a result of section 101 of the Tax Relief and Health Care Act of 2006 (TRHCA), and further expanded as a result of the Medicare, Medicaid, and SCHIP Extension Act of 2007 (MMSEA), and the Medicare Improvements for Patients and Providers Act of 2008 (MIPPA). The eRx Incentive Program is an incentive program for eligible professionals initially implemented in 2009 as a result of section 132(b) of the MIPPA. The eRx Incentive Program promotes the adoption and use of eRx systems by individual eligible professionals (and beginning with the 2010 eRx Incentive Program, group practices).
Following a few program announcements and updates, the lines will be opened to allow participants to ask questions of CMS PQRI and eRx subject matter experts.
Educational products are available on the PQRI dedicated web page located at, http://www.cms.hhs.gov/PQRI , on the CMS website, in the Educational Resources section, as well as educational products are available on the eRx dedicated web page located at http://www.cms.hhs.gov/ERxIncentive on the CMS website. Feel free to download the resources prior to the call so that you may ask questions of the CMS presenters.
Conference call details: Date: May 12, 2010
Conference Title: Physician Quality Reporting Initiative (PQRI) – National Provider Call
Time: 1:30 p.m. EDT
In order to receive the call-in information, you must register for the call. It is important to note that if you are planning to sit in with a group, only one person needs to register to receive the call-in data. This registration is solely to reserve a phone line, NOT to allow participation.
Registration will close at 1:30 p.m. EDT on Tuesday, May 11, 2010, or when available space has been filled. No exceptions will be made, so please be sure to register prior to this time.
http://www.eventsvc.com/palmettogba/051210
1. Fill in all required data.
2. Verify that your time zone is displayed correctly in the drop down box.
3. Click “Register”.
4. You will be taken to the “Thank you for registering” page and will receive a confirmation email shortly thereafter. Note: Please print and save this page, in the event that your server blocks the confirmation emails. If you do not receive the confirmation email, please check your spam/junk mail filter as it may have been directed there.
For those of who will be unable to attend, a transcript of the call will be available at least one week after the call at http://www.cms.hhs.gov/pqri on the CMS website.
If you require services for the hearing impaired please send an email to: Medicare.TTT@PalmettoGBA.com.
Geanelle E. Griffith, MSW
Geanelle E. Griffith
Centers for Medicare & Medicaid Services
Provider Communications Group
Division of Provider Relations & Outreach
410-786-4466 410-786-4466
410-786-0330 (fax)
Posted in MEDICARE UPDATES | No Comments »
Monday, April 26th, 2010
It is important to note that the Medicaid e-prescribing incentive program applies only to an electronic transmission For the purposes of the incentive program, an electronic prescription (e-prescription) is defined as: a prescription created electronically and transmitted via encrypted, interoperable computer-to-computer electronic data interchange in machine-readable (non-facsimile) format that is compliant with Medicare Part D data standards and requirements and New York State Pharmacy Regulations.
The e-prescription must originate from the prescriber’s computer system (an electronic health record, electronic medical record, or stand-alone e-prescribing software) and must be transmitted to the retail pharmacy’s computer system. It is permissible to employ the services of an intermediary or e-prescribing network to transmit the e-prescription. The incentive will not apply to prescriptions transmitted electronically by facsimile.
To be eligible to participate in this incentive program, physicians must be enrolled in the Medicaid FFS program and have an individual National Provider Identifier (NPI) number. Moreover, the e-prescription must be compliant with Medicare Part D standards. Medicare currently requires the use of the National Council for Prescription Drug Programs (NCPDP) Prescriber/Pharmacist Interface SCRIPT standard Version 8.1. Additionally, to qualify for the incentive, the e-prescription must be written for a beneficiary who is enrolled in Medicaid FFS, Medicaid Managed Care, or Family Health Plus programs. The incentive program does not affect current Medicaid prior authorization requirements. Consequently, before transmitting the e-prescription for certain drugs, prior authorization may be required.The incentive payment will be applicable to one original fill and up to five (5) refills within 180 days to both the prescriber and pharmacy, provided that the refilled item is picked up by or delivered to the beneficiary. This represents a maximum payment of $4.80 to the prescriber, and $1.20 to the pharmacy. MSSNY is working with the Department of Health to assure that physicians and their eligible ancillary prescribing associates are apprised of the availability of this incentive program and its requirements. The long-term goals of the program are to reduce medication errors, encourage pharmaceutical practices that produce better patient outcomes, and yield savings.
Posted in MEDICAID UPDATES | No Comments »
Friday, April 23rd, 2010
A Customer Care Online Inquiry Form has been added to the NGSMedicare.com Web site.
The form can be used by providers/suppliers to submit questions and requests (claims filing issues, Medicare coding queries, etc.) to the General Inquiries team and offers a faster and more efficient alternative to the current paper process. To access the new online inquiry form on the National Government Services Web site, follow these steps:
Thank you,
National Government Services, Inc.
Corporate Communications
Posted in MEDICARE UPDATES | No Comments »
Monday, April 19th, 2010
Late on Friday, April 16 the President signed H.R. 4851, the Continuing Extension Act of 2010, into law, reinstating Medicare physician payments to where they were on March 31 and again postponing the 21.3 percent cut that was supposed to take effect in 2010. This most recent extension of 2009 payment rates will continue through the end of May, and will be applied retroactively to all physician services provided to Medicare patients in April. The legislation passed the Senate at about 5:45 last night by a bipartisan vote of 59-38, and subsequently passed the House shortly after 8:00 pm by a bipartisan vote of 289-112.
Yesterday (4/15), the hold on processing April claims that the Centers for Medicare & Medicaid Services (CMS) had placed to avoid implementing the payment cut technically expired. However, with Congressional action so imminent, we do not believe many claims were actually processed at the lower payment rates. However, we have been informed by CMS that any claims paid that reflected the 21.3 percent cut will be reprocessed automatically without any action required from physicians.
The AMA is continuing to work closely with House and Senate leadership offices and with White House officials on a long-term solution to the sustainable growth rate formula, and we expect to have more to report on these efforts very soon.
Posted in MEDICARE UPDATES, NATIONAL HEALTHCARE NEWS | No Comments »
Friday, April 9th, 2010
Background: On April 5, 2010, the Centers for Medicare & Medicaid Services (CMS) announced the capitation rates for Medicare Advantage plans for 2011. The 2011 Rate Announcement was accompanied by the final 2011 Call Letter for Medicare Advantage (Part C) and Medicare prescription drug (Part D) plans.
CMS stated in the 2011 Advance Notice that, if new legislation was enacted after the Advance Notice was released, but before the Rate Announcement was published, changes would be incorporated into the Announcement. As required by Section 1102 of the Health Care and Education Reconciliation Act of 2010, the capitation rates for 2011 are the same as the capitation rates for 2010.
In previous years’ Rate Announcements, CMS included final estimates of the National Per Capita Growth Percentages (MA Growth Percentages) as well as tables summarizing the key assumptions that were used to develop the MA Growth Percentages. The final estimates of the MA Growth Percentages were used to trend the previous years’ capitation rates to the payment year. Given that the capitation rates for 2011 are the same as the capitation rates for 2010, the MA Growth Percentages have no relevance for the 2011 capitation rates. Therefore, this Rate Announcement does not include final estimates of the MA growth percentages or the associated key assumptions tables.
The Rate Announcement also contains the following key changes in response to this new legislation:
The Rate Announcement also contains a discussion of the provisions in the health reform legislation that begin to close the Part D coverage gap in 2011 and the effect of these provisions on plans’ Part D bids.
In addition to changes resulting from new legislation, the following key changes or updates have been made to the Advance Notice and draft Call Letter in response to public comments received from beneficiary advocacy groups, associations, Congressional agencies, members of the public, and health plans:
Annual parameter updates to Medicare Part D benefits are unchanged (with the exception of a $10 increase in the Initial Coverage Limit).
|
Part D Benefit Parameters |
2010 | 2011 |
| Defined Standard Benefit | ||
| Deductible | $310 | $310 |
| Initial Coverage Limit | $2,830 | $2,840 |
| Out-of-Pocket Threshold | $4,550 | $4,550 |
| Minimum Cost-sharing for Generic/Preferred
Multi-Source Drugs in the Catastrophic Phase |
$2.50 | $2.50 |
| Minimum Cost-sharing for Other Drugs in the
Catastrophic Phase |
$6.30 | $6.30 |
| Retiree Drug Subsidy | ||
| Cost Threshold | $310 | $310 |
| Cost Limit | $6,300 | $6,300 |
(Note: The changes from 2010 to 2011 are rounded to the closest appropriate unit)
The Final Rate Announcement and Call Letter can be viewed at: http://www.cms.hhs.gov/MedicareAdvtgSpecRateStats/ .
Posted in MEDICARE UPDATES | No Comments »
Friday, April 9th, 2010
CMS needs to hear from you!
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