Medicare AWV

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Sioux Falls
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Our clinic has started doing the Medicare AWV's with a phone call from the nurse. The patient doesn't come in and no vitals are taken. They just do the Depression screening and the AWV questionnaire with them. Then a few days later the patient comes in for an E/M to go over their chronic conditions. I know the AWV can be done by the nurse just wondering if it is ok to to it this way. I thought they should at least have a weight and blood pressure. We had been doing them both on the same day.
 

thranowski

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Orlando, FL
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Our clinic has started doing the Medicare AWV's with a phone call from the nurse. The patient doesn't come in and no vitals are taken. They just do the Depression screening and the AWV questionnaire with them. Then a few days later the patient comes in for an E/M to go over their chronic conditions. I know the AWV can be done by the nurse just wondering if it is ok to to it this way. I thought they should at least have a weight and blood pressure. We had been doing them both on the same day.
I'm a little confused by this wording. Are you saying the nurse does the depression screening and AWV questionnaire on the phone, and then the patient comes in for the AWV with the provider? I would see nothing wrong with that so long as the screenings that are able to be billed are billed on the DOS the nurse performs them. If nothing additional is being billed, then I would just put a note in the chart that it was obtained via phone by the nurse on xx/xx/xxxx.

AWV's cannot be performed by RNs. It has to be a health care professional, which is defined here:
Health professional means -
(i) A physician who is a doctor of medicine or osteopathy (as defined in section 1861(r)(1) of the Act); or
(ii) A physician assistant, nurse practitioner, or clinical nurse specialist (as defined in section 1861(aa)(5) of the Act); or
(iii) A medical professional (including a health educator, a registered dietitian, or nutrition professional, or other licensed practitioner) or a team of such medical professionals, working under the direct supervision (as defined in § 410.32(b)(3)(ii)) of a physician as defined in paragraph (i) of this definition.
Here is a link to the definitions and requirements from CMS https://www.cms.gov/Outreach-and-Ed...entive-services/medicare-wellness-visits.html
 
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Sioux Falls
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I'm a little confused by this wording. Are you saying the nurse does the depression screening and AWV questionnaire on the phone, and then the patient comes in for the AWV with the provider? I would see nothing wrong with that so long as the screenings that are able to be billed are billed on the DOS the nurse performs them. If nothing additional is being billed, then I would just put a note in the chart that it was obtained via phone by the nurse on xx/xx/xxxx.

AWV's cannot be performed by RNs. It has to be a health care professional, which is defined here:

Here is a link to the definitions and requirements from CMS https://www.cms.gov/Outreach-and-Ed...entive-services/medicare-wellness-visits.html
The patient comes in a week later to go over their chronic conditions. Nothing is said about going over the AWV components. That is all templates and the same for every patient except the answers.
 

thranowski

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Orlando, FL
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The patient comes in a week later to go over their chronic conditions. Nothing is said about going over the AWV components. That is all templates and the same for every patient except the answers.
So the nurse charges the AWV and then the doctor charges an OV?

1) The RN/MA is not allowed to bill that, they are not considered a health professional. They can collect the information but the provider has to review and perform the AWV.
2) Billing an additional visit for elements that would be covered under the AWV (see link for elements according to CMS) would be considered fraud and/or abuse.

If there are sick symptoms at the AWV, you can bill an OV with it. I.e. the patient comes in for AWV but also has a cough or new pain in their hip, etc.
 
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So here's the scenario patient gets a call on 12/1 by the nurse. The visit is charged out as the AWV by the doctor. The patient doesn't actually come into the clinic to be seen by the physician. Then on 12/8 the patient actually comes in to be seen by the doctor and then the chronic conditions are discussed and billed out as an E/M. So what exactly is the doctor supposed to do for the AWV. I am having a hard time explaining this to the providers.
 

thranowski

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Orlando, FL
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So here's the scenario patient gets a call on 12/1 by the nurse. The visit is charged out as the AWV by the doctor. The patient doesn't actually come into the clinic to be seen by the physician. Then on 12/8 the patient actually comes in to be seen by the doctor and then the chronic conditions are discussed and billed out as an E/M. So what exactly is the doctor supposed to do for the AWV. I am having a hard time explaining this to the providers.
Oh, boy. The nurse can't perform an AWV and therefore you can't bill it. It doesn't matter if the doctor is the one who adds the charge (lol, I love how they think they're so clever). He didn't perform the service. Medicare has every right to request recoupment for every single AWV a nurse performed.

The 2nd visit is what the actual AWV is supposed to be. The nurse can call the patient beforehand to obtain all the information, but on the in person visit, the provider should be reviewing it, performing the physical exam, discussing chronic conditions, and billing that out as the AWV.

Certain questionnaires like depression screenings or drug/alcohol screenings or yearly advance directives reviews can be billed in addition to the AWVs with the appropriate modifiers.

You can also bill an additional OV E&M charge with the AWVs on the same day if there are any new conditions or any changes to any chronic conditions that require more work. It has to meet the E&M standards. If it's just refilling rxs or renewing referrals for chronic conditions without changes, that's part of the AWV.

In the link I gave you if you scroll down it has all the elements of an AWV. You can show that to the providers, but I'm sure your doctors know what they're supposed to be doing. They had to have worked at clinics performing routine physicals before this. They just think they've found some loophole to make more money.
 

AmandaBriggs

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Coeur d'Alene, Idaho
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There is an allowance in the Code of Federal Regulations that allows an RN to perform an AWV for patients. Here is a link to that information (see section 280.5): https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/bp102c15.pdf. The AWV is also on CMS's list of telehealth services and audio-only interaction satisfies the telehealth requirement. I would like to point out that if an RN is providing this service, it can only be for the subsequent annual wellness visits and there must be a provider present within the office while the service is being provided.
 

thranowski

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Orlando, FL
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There is an allowance in the Code of Federal Regulations that allows an RN to perform an AWV for patients. Here is a link to that information (see section 280.5): https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/bp102c15.pdf. The AWV is also on CMS's list of telehealth services and audio-only interaction satisfies the telehealth requirement. I would like to point out that if an RN is providing this service, it can only be for the subsequent annual wellness visits and there must be a provider present within the office while the service is being provided.
Can you please quote where in there it says an RN can perform a subsequent AWV? I'm not finding it.
 
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