F R O M T H E F I E L D
Billing Certainty in Rehab Guidelines
By Lynn Berry, PT, CPC
Section 3134 of the Affordable Care Act (ARA) added Section 1848(c) (2) (K) of the Social Security Act, which specifies the identification of potentially misvalued codes, with reductions applied accordingly. The calendar year (CY) 2011 Proposed Rule stipulated a 50 percent reduction to the Practice Expense Component of every unit billed above one, regardless of discipline, for a single date of service for rehab, in both facility and non-facility settings. This was changed to 25 percent in the CY 2011 Final Rule. The Medicare and Medicaid Extenders Act of 2010 made another change, so that practice expense above one unit would be reduced by 20 percent for non-facility charges and by 25 percent for facility charges.
What this means for the independent occupational, physical, and speech language pathology therapist when billing by the same billing National Provider Identifier (NPI) on the same date of service, is that the first unit of the code with the highest practice expense relative value unit (RVU) will be paid at 100 percent, with a 20 percent reduction of the practice component for services above the first unit for non-facility providers.
How will a non-facility billing department know what the practice will be paid for that date? Easily, says the Centers for Medicare & Medicaid Services (CMS). Find the practice expense RVU for each applicable component of service for that date (listed as a "5" under multiple procedures on the Medicare Physician Multiple Procedure File Data Base). Then look up the code for that service on the fee schedule. You will be paid full value for the service with the highest practice expense RVU. For all other codes, no matter what the discipline, you will be paid 80 percent of the practice component RVU amount.
Although CMS has provided Medicare Administrative Contractors (MACs) with a column in their database that designates the payment amount for fully valued services (per Change Request 7050, Transmittal 826), no such columns are available to providers on the published fee schedule.
For help, turn to professional association membership, such as the American Physical Therapy Association (APTA). On the APTA website, there is a multiple procedural payment reduction rule (MPPR) calculator, as well as a Medicare Outpatient Fee Schedule Pricer. Input all the codes and applicable units of service used by the patient on that date of service from every discipline covered by your billing NPI, as well as your location, and the calculator will tell you the amount payable for each code, which codes have reduced payments, and your total payable amount for the day.
G O O D T I P S
Not Too Late to Test 5010
Early results from the first National 5010 Testing Days, June 15th are in. The second National 5010 Testing Day is August 24th; will you be ready January 1, 2012 when 5010 is the norm?
CMS posted the Top 10 837P Submission Errors from the June test. These include:
- Wrong postal and zip information for the service location
- Failure to provide the correct Payer's ID Number
- Wrong Provider or Tax ID number
- Incorrect subscription number for the patient
Trailblazer also posted their Top 10 for each state. These include:
- Wrong postal information for the provider
- No approval for the provider to submit claims electronically
- Wrong NPI for the provider
Clearly, it is time to bone up on the new submission standards. Not being able to use Post Office boxes and other important changes will derail reimbursement in January if not addressed now.
Providers' billing offices can access real-time help desk support and enjoy direct access to their MAC during the August 24 test. Take advantage of the opportunity to iron out bugs, before it is too late.
I N T H E N E W S
WEDI Needs Feedback by Noon, Friday
The Workgroup for Electronic Data Interchange (WEDI) ASC X12N group requests help from billers regarding overpayment recoupment efforts. The survey will help ASC X12N define and study the business issues of the health care industry's over and under payment recoupment processes and perform a gap analysis between current use of the standard transaction and future requirements to determine if modifications to future guides are appropriate.
If you have experience with over and under payment recoupment processes or have information about over and under payment recoupment that you think would be helpful, please complete this brief survey. This survey closes at noon central time, July 29, 2011.
F E A T U R E D S T O R Y
By Jackie Stack, CPC, CPC-I, CEMC, CFPC, CIMC, CPEDC
Controlling patient collections is difficult. Collecting co-payments, deductibles, and self-pay amounts up front makes a huge difference, but there are still times when patients owe money. Sending statement after statement is expensive. How do you know when to write off the amount as non-collectable or turn the account over to a collection agency?
The practice must determine its own collection policy. The policy should be documented in the practice compliance plan, and applied consistently. The practice must make a good faith effort to collect from the patient. Most practices send at least three statements.
Decide if you want the aid of a collection agency. The agency contacts the patients, saving your practice time and money, and usually is paid a percentage of the amount collected. Send a final notice to the patient stating that if they don't pay their account within certain time, the bill will be turned over to a collection agency.
Many practices want to write off the balance due to financial hardship. If your practice decides to go this route, be sure the practice has a financial hardship policy. The patient must be able to prove an inability to pay. Be consistent. Creating an application for your patients to complete showing monthly income, assets, monthly expenditures, and the number of dependents will help you confirm financial hardship.
FROM THE FIELD is thoughts and experiences from you the reader. If you have any tips, ideas, case studies, or just anecdotes please submit them to us for future editions.