Medicare Compliance & Reimbursement

Rural health clinics may have been shortchanged since January.

Have your preventive visit payments been dwindling over the last few months? Centers for Medicare & Medicaid Services (CMS) has taken notice — and is trying to remedy the problem.

At issue: The January 2013 quarterly release include an error that shorted rural health clinics for annual wellness visits (AWVs) and initial preventive physical exams (IPPEs) that they reported, CMS stated in a May 16 news blast.

“Until system changes can be implemented, rural health clinics should follow the billing instructions outlined below to ensure there is no further delay in your Medicare payments,” the agency advised. Those steps are as follows:

• Submit AWV services to your MAC with either G0438 or G0439 and revenue code 052X and “ensure no other services are reported on the claim with the same line item date of service as the AWV,” CMS notes.
• Submit IPPE services on a separate claim to your MAC. So if you report an encounter on the same date as an IPPE, “submit the first claim with revenue code 052X and no HCPCS/CPT code,” CMS advises. “The second claim should be submitted with revenue code 052X and HCPCS code G0402.”

Payers that were holding these claims waiting for a system fix will soon begin returning these claims to practices, but you’ll have to resubmit them using the guidelines above.

Senate Confirms Official CMS Administrator

The Centers for Medicare & Medicaid Services has its first permanent Administrator in seven years. The Senate confirmed former nurse and hospital exec Marilyn Tavenner in a 91-to-7 vote.

The National Association for Home Care & Hospice praised Tavenner for helping resolve outlier payment problems home health agencies had been experiencing since the imposition of the 10 percent cap in 2010.

CMS Wants Your Feedback on PQRS Measures

If you’ve always wished that CMS would add Physician Quality Reporting System (PQRS) measures for a specific specialty area, then now is your chance to voice your concerns to the agency. CMS is now accepting quality measure suggestions that it could include in future years’ PQRS bonuses.

CMS is particularly interested in filling “gaps” that exist in the PQRS system involving clinical outcomes, patient-reported outcomes, care coordination, safety, appropriateness, efficiency, patient experience, and engagement, according to a May 23 email to providers on the topic.

If you are interested in submitting a measure for CMS consideration, visit the CMS Call for Measures page at www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/MMS/CallForMeasures.html.

Get Ready For More State Scrutiny Of Your Data

You should be paying attention to your claims and other data, because authorities certainly are — and state regulators could soon be doing it even more.

The HHS Office of Inspector General has finalized a rule that will allow State Medicaid Fraud Control Units to use federal matching funds to “identify fraud through screening and analyzing State Medicaid data,” the OIG says in a notice in the May 17 Federal Register.

“Most commenters supported our proposal to provide Federal reimbursement for data mining activities by MFCUs, citing potential cost savings through earlier identification of Medicaid fraud, the benefit of conserving administrative resources by better targeting of antifraud investigations, and the potential for increased effectiveness in finding and eliminating fraud and abuse,” the OIG says in the final rule.

States will have to submit a request to use funds for data mining. “A data mining request must describe how data mining will be coordinated with the State Medicaid agency and OIG approval of any request will be coordinated with the Centers for Medicare & Medicaid Services,” the OIG explains in a notice of the regulation.

The rule is at oig.hhs.gov/fraud/medicaid-fraud-control-units-mfcu/index.asp.

Face-To-Face Visits Aren’t Required For All Home Care Patient Updates

If your physicians have been visiting home care patients more often due to 2013’s face-to-face visit requirement, know that this rule does not mean that you have to see the patient every time his or her condition changes.

“The face-to-face encounter is only required for the initial episode of home health services,” HHH Medicare Administrative Contractor National Government Services reminds providers. Medicare doesn’t require F2F for subsequent episodes. “An additional face-to-face document would not be required unless the patient was discharged from home health and then readmitted with 60 days or more between episodes,” NGS explains.

That includes when the patient’s diagnosis changed for a recert or resumption of care, NGS says in a question-and-answer document from its April 24 webinar on “Understanding the Medicare Home Health Coverage Guidelines.”

“It would not be necessary to get another face-to-face encounter,” NGS clarifies. “It is only required for the initial episode of care.”

Patient Insists On Service But Refuses To Sign ABN? Get A Witness

Does your practice have to be on the hook if a patient refuses to sign an ABN? No, says a recent question-and-answer from Medicare contractor NHIC.

“If the beneficiary demands the service and refuses to pay, the notifier should have a second person witness the provision of the ABN and the beneficiary’s refusal to sign,” the notification says. “They should both sign an annotation on the ABN attesting to having witnessed said provision and refusal.”

What if there is no one else available to witness? “The second witness may be contacted by telephone to witness the beneficiary’s refusal to sign the ABN by telephone and may sign the ABN annotation at a later time,” it says. “An unused patient signature line on the ABN form may be used for such an annotation; writing in the margins of the form is also permissible.”

This is supported by language in the Medicare Claims Processing Manual, which you can read at www.cms.gov/Regulations-and-Guidance/Guidance/Manuals .