This week in Medicare updates—1/15/2020
Updated Corporate Integrity Agreement Documents
On January 6, the OIG published information on a new Corporate Integrity Agreement with Nassir, MD, Youram, of Los Angeles, CA. It also published information on closed cases with:
- Cochinwala, Fuad Rehman; OSD Management, LLC and One Step Diagnostic, of Houston, TX
- Health Diagnostic Laboratory, Inc., of Richmond, VA
- Villegas, Jesus, D.D.S., Fairfield Pediatric Dentistry, L.L.C., and Haven Pediatric Dentistry, LLC, of Milford, CT
Comment Request: Applications for Part C Medicare Advantage, 1876 Cost Plans, and Employer Group Waiver Plans to Provide Part C Benefits
On January 6, CMS published a Comment Request regarding the submission for OMB review of an information collection titled, “Applications for Part C Medicare Advantage, 1876 Cost Plans, and Employer Group Waiver Plans to Provider Part C Benefits.”
Comments are due to the OMB desk officer by February 5, 2020.
New Beneficiary Notices Available
On January 7, CMS published new versions of the Important Message from Medicare, Detailed Notice of Discharge, and Medicare Outpatient Observation Notices. Hospitals will be required to use the new versions of these notices beginning April 1, 2020. Both the new and older versions of these notices are acceptable for use through March 31, 2020.
User CR: ViPS Medicare System (VMS) - Increase Edit Code Maximum
On January 8, CMS published One-Time Notification Transmittal 2416, which rescinds and replaces Transmittal 2384, dated November 8, 2019, to revise the default date in business requirement 11398.2.1 and to add the IDR to BRs 11398.2 and 11398.2.1. The original transmittal was issued regarding modifications to the VMS to increase the allowable number of entries on the Edit Code Description Table Screen within the Automated Parameter Claims Parameter (VMPA/4C) System.
Effective date: April 1, 2020
Implementation date: April 6, 2020
Updates to CR 11152 Implementation of the Skilled Nursing Facility (SNF) Patient Driven Payment Model (PDPM)
On January 9, CMS published Medicare Claims Processing Transmittal 4491, which rescinds and replaces One-Time Notification Transmittal 2379, dated November 1, 2019, to change the CR type from a One Time Notification to a Standard CR type, which adds a manual attachment that updates chapter 6 of CMS Pub. 100-04. The correction also revises the background section and adds two new business requirements (11513.4 and 11513.5. The original transmittal was issued to implement changes that will include the Veterans Administration (VA) in the updates to the SNF Prospective Payment System as required for PDPM. These VA changes were erroneously left out of the original change request.
On January 9, CMS revised MLN Matters 11513 to accompany the transmittal.
Effective date: April 1, 2020
Implementation date: April 6, 2020
ICD-10-CM Browser Tool
On January 9, the CDC posted the ICD-10-CM Browser Tool, a beta version of a tool which allows for a web-based search of ICD-10-CM codes. It also provides instructional information for usage of the codes and access to multiple fiscal year version sets.
CMS Offers Broad Support for Puerto Rico Amid Earthquakes
On January 9, CMS published a Press Release regarding actions it is taking to support Puerto Rico in the aftermath of recent earthquakes. These actions include temporary waivers for certain Medicare requirements, special enrollment opportunities to allow for immediate access to healthcare, steps to ensure dialysis patients can obtain services, and more.
For more information on CMS activities related to earthquake relief, visit CMS’ emergency website.
Home Health (HH) Patient-Driven Groupings Model (PDGM) - Split Implementation
On January 9, CMS published Medicare Claims Processing Transmittal 4489, which rescinds and replaces Transmittal 4482, dated December 20, 2019, to correct the RAP payment percentage in the policy section of the business requirement form. The original transmittal was issued to implement policies for PDGM as described in the CY 2019 Home Health final rule.
On December 23, CMS revised MLN Matters 11081 to accompany the transmittal.
Effective date: January 1, 2020 - Claim “From” dates on or after this date
Implementation date: July 1, 2019 - for design and requirements; October 7, 2019 - for coding and testing including Beta HH Pricer; January 6, 2020 - for continued testing and implementation. To the extent feasible, tasks during the three releases may be worked using an Agile process.
Appropriate Use Criteria (AUC) for Advanced Diagnostic Imaging - Approval of Using the K3 Segment for Institutional Claims
On January 10, CMS published Special Edition MLN Matters 20002 regarding guidance for claims processing subject to AUC for advanced diagnostic imaging services. Starting in CY 2020, ordering professionals will be expected to consult qualified clinical decision support mechanisms (CDSM) and provide information to furnishing practitioners and providers for reporting on claims. The article includes information on how to report the ordering professional’s NPI on institutional claims in the K3 segment.
Applicability of Proficiency Testing (PT) Referral to Cytology/Histopathology Slide Staining by a Separate Entity
On January 10, CMS published a Memorandum to state survey agency directors regarding a clarification on how PT referral applies to cytology/histopathology slide staining by a separate entity. If a laboratory merely sends PT slides to a separate entity for staining and slides are returned to the original laboratory for examination, CMS would not consider it a PT referral as entities that only conduct certain preparatory steps for testing are not considered labs and are not subject to CLIA.
Effective date: Immediately. This policy should be communicated with all survey and certification staff, their managers, and the state/regional office training coordinators within 30 days of the memorandum.
Updated Provider Self-Disclosure Settlements
On January 10, the OIG published an updated List of Provider Self-Disclosure Settlements, including:
- On December 16, The Center for Orthotic and Prosthetic Care of Kentucky, LLC, of Kentucky, reached a $335,838 settlement with the OIG to resolve allegations that it violated civil monetary penalties law regarding kickbacks by paying remuneration to an individual based on their marketing of and referral generation for orthotics and prosthetics supplies purchased or ordered from the COPCK Paducah office.
- On December 17, A1 Pharmacy & Surgical Supply, LLC, of North Carolina, reached a $515,060.68 settlement with the OIG to resolve allegations that it submitted claims for brand name diabetes monitoring and treatment supplies when it had actually dispensed a less expensive brand or generic supplies.
- On December 20, St. Charles Health System d/b/a St. Charles Bend, of Oregon, rached a $10,000 settlement with the OIG to resolve allegations that it employed an individual it knew or should have known was excluded from participation in federal health care programs.
Update to Chapter 3, Section 3.2.3.1 Additional Documentation Requests (ADR) of Publication 100-08
On January 10, CMS published Medicare Program Integrity Transmittal 933, which rescinds and replaces Transmittal 907, dated October 4, 2019, to change the effective date to February 3, 2020. The original transmittal was issued regarding instructions to MACs and RACs who request additional documentation to perform prepayment and post payment reviews utilizing an eMDR via the esMD.
Effective date: February 3, 2020
Implementation date: January 6, 2020
Manual Updates Related to CY 2020 Home Health Payment Policy Changes, Maintenance Therapy, and Remote Patient Monitoring
On January 10, CMS published Medicare Benefit Policy Transmittal 265 regarding updates to the manual related to policy changes from the 2019 and 2020 Home Health Prospective Payment System final rules. Specific policy changes include changes related to the implementation of PDGM 30-day episode periods, split percentage payments, maintenance therapy provision, and the definition of remote patient monitoring.
CMS published MLN Matters 11577 on the same date to accompany the transmittal.
Effective date: January 1, 2020
Implementation date: February 11, 2020