This week in Medicare updates—10/28/2020
Medicare Quarterly Provider Compliance Newsletter
On October 19, CMS published the Medicare Quarterly Provider Compliance Newsletter regarding two recovery auditor findings. These include a reminder about unbundling for emergency department services billed on the same date as critical services for the same beneficiary and a reminder about Medicare coverage requirements and documentation for pneumatic compression devices.
Proposed Decision Memo for Screening for Colorectal Cancer - Blood-Based Biomarker Tests
On October 19, CMS published a Proposed Decision Memo regarding coverage of blood-based biomarker tests as appropriate colorectal cancer screening tests once every three years or at FDA indicated intervals for Medicare beneficiaries who meet certain requirements. Although CMS proposes to cover blood-based biomarker tests if the tests meet certain thresholds, the only FDA approved test currently available, Epi proColon®, does not meet proposed criteria and therefore CMS proposes non-coverage of this test under the NCD.
By issuing the proposed decision memo, CMS initiates a 30-day public comment period on this policy. That comment period will end on November 15.
Proposed Decision Memo for AlloMap® Molecular Expression Testing for Detection of Rejection of Cardiac Allografts
On October 19, CMS published a Proposed Decision Memo regarding coverage of AlloMap® Molecular Expression testing for detection of rejection of cardiac allografts. CMS is proposing not to issue an NCD for coverage of this product, as it believes MACs are better suited for determining coverage for patients who may benefit from this test.
By issuing the proposed decision memo, CMS initiates a 30-day public comment period on this policy. That comment period will end on November 15.
COVID-19 FAQs on Medicare Fee-for-Service Billing
On October 20, CMS updated an FAQ regarding the latest guidance on billing for COVID-19. This round of updates included changes to Section D on high throughput COVID-19 testing to update the payment information for those tests, information on using CPT codes 98966-98968 during the PHE, billing information for telehealth originating site facility fee charges during an inpatient stay, and information on special SNF benefit periods pursuant to PHE waivers.
CMS continues to update this document on a regular basis. Providers should review frequently for new information.
Change to the Payment of Allogeneic Stem Cell Acquisition Services
On October 20, CMS published Medicare Claims Processing Transmittal 10402, which rescinds and replaces Transmittal 10371, dated September 24, 2020, to remove the FISS responsibility from business requirement 11729.9.1. The original transmittal was issued regarding changes to the claims processing system to prepare it to pay for allogeneic stem cell acquisition services on a reasonable cost basis.
CMS revised MLN Matters 11729 on the same date to accompany the transmittal.
Effective date: For cost reporting periods beginning on or October 1, 2020
Implementation date: October 5, 2020 - Analysis and Design; January 4, 2021 - Design, Coding, and Testing
Home Health Agency Provider Compliance Audit: Gem City Home Care LLC
On October 23, the OIG published a Review of whether Gem City Home Care complied with Medicare requirements for billing home health services. The OIG found that Gem City billed Medicare incorrectly for 25 of the 100 home health claims reviewed. These issues pertained to services provided to beneficiaries who did not require skilled services or services provided to beneficiaries who were not homebound. The OIG estimated that Gem City received overpayments of at least $2.67 million for the audit period.
The OIG recommends Gem City refund Medicare for the identified overpayments, identify and return any similar overpayments, and strengthen procedures to ensure homebound statuses are verified and continually monitored. Gem City said it took “significant exception” with the OIG’s findings, which originally stated 36 of 100 claims were billed incorrectly. After further review, the OIG changed its findings to determine only 25 claims were billed incorrectly.
Electronic Correspondence Referral System (ECRS) User Guide Updates
On October 23, CMS published Medicare Secondary Payer Transmittal 10401 regarding updates to the ECRS User Guide and the ECRS Web Quick Reference Card. These changes affect information on processing prescription drug assistance requests, duplicate record prevention, updates to certain ICD-10 diagnosis codes, and clarifying language on certain set-up processes.
Effective date: November 24, 2020
Implementation date: November 24, 2020