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Nancy Reading, RN, BS, CPC
Medicare’s modernization act and the 2006 tax relief legislation that rolled back the negative Medicare conversion factor give a temporary reprieve to the “TC” technical component when an independent lab furnishes the pathology services as part of a business arrangement. The stay comes to a close on Dec. 31, 2007, which is quite a lengthy extension given that the original final rule calling for the demise of the TC was published Nov. 2, 1999. The final rule and the extended deadline apply to all independent laboratories contracted prior to July 22, 1999, and copies of the agreements should be forwarded to local carriers to confirm the covered arrangement. Once the current deadline expires, independent labs and the associated hospitals should have contracts in place stipulating payment agreements for the technical preparation of specimens under review. Independent laboratories providing services to hospitals without a covered agreement may not bill for the TC component of the inpatient or outpatient pathology services provided.
Will the Tax Relief Package Ever End?
Carrie Severson, CPC, CPC-H, CPC-P
Section 202 of the tax relief act that turned back the conversion factor for 2007 also mandates that Medicare Part B will cover the administration of vaccines that are covered under Part D of Medicare. A new G code (G0377) has been created for the administration of Part D vaccines and payment for G0377 will be crosswalked to CPT code 90471. In short, when a physician administers a Part D vaccine, the physician should use G0377 to bill the local carrier for the administration of the vaccine. Payment to the physician will be on an assigned basis only. Normal beneficiary deductible and coinsurance requirements apply to the administration. The participating drug plan makes payment for Part D covered vaccines.
Medicare Part B will not pay for the vaccine itself. The policy expires after one year, which is about the amount of time it will take to understand and put the directive into practice. For more information, see MLN Matters MM 5459 at
Care Plan Oversight Codes Will Come in Handy
Chris Fraizer, CPC, CPC-H, CPC-P
Two care plan oversight codes new to CPT in 2006 will certainly come in handy considering an eventual $1.75 billion grant program spread over five years (2007-2011) to help states shift Medicaid’s traditional emphasis on institutional care to home and community-based services. This Money Follows the Person (MFP) initiative was included in the Deficit Reduction Act of 2005 (DRA) and will go towards four objectives that basically foster the independent living skills people need to live within their home and community, as opposed to a larger congregate setting. According to Leslie Norwalk, acting administrator of the Centers for Medicare and Medicaid Services (CMS), with these grants states can transition thousands of individuals – predominantly the elderly and those with developmental disabilities – from institutions into community settings. The grants help eliminate the cumbersome waiver programs states use to fund these types of programs, and which are separate from the approved state Medicaid plans. And the codes?
They are CPT 99339 and 99340, which report the home care plan oversight services a physician provides when coordinating the medical care and related services of children and adults with special health care needs. For more details about the New Freedom Initiative grants, go to
Applying for NPI is but Half the Wait (and Counting)
Nancy Reading, RN, BS, CPC
No matter how many days remain before the National Provider Identifier (NPI) deadline, you might need even more time to complete the process according to Centers for Medicare and Medicaid Services (CMS) estimates. CMS, which posts a countdown clock on its Web site, gives a ballpark figure of around 120 days to complete the NPI process due to external “out-of-yourcontrol” affairs such as coordinating the physician’s NPI with the billing systems of vendors and clearinghouses. Although the word on the NPI has been out in final rule for three years this past January, some 40 percent of all eligible physicians were in jeopardy of missing the deadline. And, to top that off, CMS has handed out 1.6 million of the identifiers, the number outstanding could mean an extension past the May 23, 2007 date, similar to the deadline extended for compliance to the electronic transaction rule of the same health care regulation (Health Insurance Portability and Accountability Act, or HIPAA).
And, now for the NPI refresher course:

  • Who should apply for an NPI?

-Those licensed to provide health care services and billing third parties for the services provided.

  • Who should not apply for an NPI?

-Physicians who have opted out of government medical programs.
-Groups, partnerships, or corporations.
-Entities that bill or are paid for health care services furnished by other health care providers.
-A taxpayer identifying number, not by an NPI, is used to identify a billing or pay-to entity.
-Clearinghouses, administrative services only vendors, billing services, or health care provider service locations. CMS promises to soon publish the NPI notice of data dissemination everyone has been asking about. According to a recent CMS open forum, the notice is in clearance which is the step prior to official release. For more about the NPI, go to

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