This week in Medicare updates—3/7/2018
Update to the Federally Qualified Health Center (FQHC) Prospective Payment System (PPS) for Calendar Year (CY) 2018 - Recurring File Update
On February 23, CMS published Medicare Claims Processing Transmittal 3982, which rescinds and replaces Transmittal 3972, dated February 8, 2018, to include information in the background and policy sections about the FQHC geographic adjustment factor (GAF) changes resulting from statutory requirements. Transmittal 3982 also includes a revised business requirement about the adjustment of FQHC claims. The original transmittal was issued regarding the grandfathered tribal FQHC PPS rate for 2018.
Effective date: April 1, 2018
Implementation date: April 2, 2018
Provider Compliance Tips for Computed Tomography (CT) Scans
On February 26, CMS published a Fact Sheet regarding ways to document and bill for CT scans and services. The fact sheet contains tips on how to prevent denials and lists documentation that should be provided if a provider or facility receives a documentation request from a Medicare review contractor. It also lists HCPCS codes for CT scans and services which would require the use of modifier -CT.
Consumer Assessment of Healthcare Providers and Systems (CAHPS) for Merit-based Incentive Payment System (MIPS) Survey
On February 27, CMS posted three documents, including a CAHPS Application Form, the Minimum Survey Vendor Business Requirements, and an FAQ document for CAHPS for MIPS survey vendors, to its Quality Payment Program resources website. All three documents pertain to the 2018 reporting year. Those who wish to receive approval as a CAHPS for MIPS survey vendor must submit their application by March 20, 2018.
Advisory Opinion No. 18-01 on an Exclusion from Medicare, Medicaid and All Other Federal Healthcare Programs
On February 27, the OIG posted an Advisory Opinion regarding an anonymous individual who was excluded from Medicare, Medicaid, and all other federal healthcare programs due to a criminal conviction for healthcare fraud. The individual sought an opinion on whether the individual could be employed by a newly formed, for-profit corporation to market its pharmacy services.
The OIG ruled that while the proposed arrangement could violate the exclusion and constitute grounds for sanctions, the OIG would not impose such sanctions in this specific case because the marketing services of the individual involved would be far removed from the emergency medications the company or its customers would provide to beneficiaries of Medicare, Medicaid, or any other federal healthcare program.
Public Meetings in Calendar Year 2018 for All New Public Requests for Revisions to the HCPCS Coding and Payment Determinations
On February 28, CMS published a Notice in the Federal Register announcing the dates, time, and location of the HCPCS public meetings for 2018. The meeting dates and topics are as follows:
- Monday, May 14, 1 p.m. - 5 p.m. ET: Drugs, Biologicals, Radiopharmaceuticals, Radiologic Imaging Agents
- Tuesday, May 15, 9 a.m. - 6 p.m. ET: Drugs, Biologicals, Radiopharmaceuticals, Radiologic Imaging Agents
- Wednesday, May 16, 9 a.m. - 6 p.m. ET: Drugs, Biologicals, Radiopharmaceuticals, Radiologic Imaging Agents
- Thursday, May 17, 9 a.m. - 12 p.m. ET: Drugs, Biologicals, Radiopharmaceuticals, Radiologic Imaging Agents
- Tuesday, June 1, 9 a.m. - 5 p.m. ET: Durable Medical Equipment and Accessories, Orthotics and Prosthetics, Supplies and Other
- Wednesday, June 2, 9 a.m. - 5 p.m. ET: Durable Medical Equipment and Accessories, Orthotics and Prosthetics, Supplies and Other
ICD-10 and Other Coding Revisions to National Coverage Determinations (NCDs)
On February 28, CMS published One-Time Notification Transmittal 2039, which rescinds and replaces Transmittal 2033, dated February 16, 2018, to correct instructions in business requirement 7, NCD 210.3, Colorectal Cancer Screening, and the accompanying spreadsheet. The original transmittal was issued regarding a maintenance update of the ICD-10 conversions and other coding updates specific to NCDs.
Effective date: July 1, 2018
Implementation date: April 2, 2018 for CMS Local MACs; July 2, 2018 - CMS Shared System Maintainers
2018 Merit-based Incentive Payment System (MIPS) Cost and Advancing Care Information Performance Categories Fact Sheets
On March 1, CMS published a Fact Sheet regarding the cost performance category of MIPS to provide information on the Year 2 policies for the category. In 2018, the cost category will account for 10% of the total MIPS score. The fact sheet discusses the 2018 cost measures, the cost category scoring system, and the reason for focusing on cost as an element of MIPS.
On March 1, CMS also published a Fact Sheet regarding the advancing care information performance category of MIPS. This fact sheet reviews the 2018 advancing care information measures, the advancing care information category scoring system, methods for reporting advancing care information data, and activities which can be used for a bonus score in the category.
Updated Civil Monetary Penalties and Affirmative Exclusions
On March 1, the OIG published an updated List of Civil Monetary Penalties and Affirmative Exclusion agreements reached in January, including:
- Piedmont Newton Hospital, of Covington, Georgia, reached a $52,414 settlement agreement with the OIG on January 11 to resolve allegations that Piedmont violated the Emergency Medical Treatment and Labor Act by failing to provide appropriate medical screening and then inappropriately transferring the patient to a different hospital. The patient suffered a bowel perforation and later died from the condition.
- Clarksville Health System, f/k/a Gateway Medical Center, reached a $40,000 settlement agreement with the OIG to resolve allegations that it violated the Emergency Medical Treatment and Labor Act by failing to accept an appropriate transfer. The health system had been asked to accept a patient for transfer who needed the specialized services of a urologist, which was not available at the original hospital. Clarksville refused to accept the transfer, although the OIG alleged that Clarksville had both the capability and capacity to stabilize the patient’s emergency medical condition in that situation.
Diagnosis Code Update for Add-On Payments for Blood Clotting Factor Administered to Hemophilia Inpatients
On March 1, CMS published Medicare Claims Processing Transmittal 3990, which rescinds and replaces Transmittal 3974, dated February 8, 2018, to change the diagnosis code in business requirement 10474.2 from D68.28 to D68.32. The original transmittal noted that effective July 1, 2018, ICD-10-CM code D68.32 (antiphospholipid antibody with hemorrhagic disorder) will not receive an add-on payment under the hemophilia clotting factor criteria.
Effective date: July 1, 2018
Implementation date: July 2, 2018
New Medicare Card: Video for Your Waiting Room
On March 1, CMS announced a new Video to play in waiting rooms regarding the new Medicare cards. The video tells patients when and how they will receive the new card, and MLN Matters provided links to the video on YouTube or in opened caption and 1080p formats.
Patients Over Paperwork Newsletter
On March 1, CMS posted the February Patients over Paperwork newsletter, which examines the new Meaningful Measures initiative, updates readers on the documentation review improvement, and discusses ways CMS is meeting with providers to reduce paperwork burdens. Anyone interested can sign up for the newsletter here.
Indian Health Services (IHS) Hospital Payment Rates for Calendar Year 2018
On March 2, CMS published Medicare Claims Processing Transmittal 3987 regarding the annual update of the IHS payment rates for 2018. The hospital outpatient and ancillary Part B rates for 2018 are listed in an attachment to the transmittal. This transmittal authorizes Novitas Solutions, Inc., to make the necessary payment adjustments for 2018.
Effective date: January 1, 2018
Implementation date: April 2, 2018
April 2018 Update of the Hospital Outpatient Prospective Payment System (OPPS)
On March 2, CMS published Medicare Claims Processing Transmittal 3988 regarding changes to and billing instructions for various payment policies implemented in the April 2018 OPPS update. There are revisions listed in the transmittal pertaining to HCPCS, APC, HCPCS Modifier, and Revenue Code additions, changes, and deletions. All of these should be reflected in the April 2018 Integrated Outpatient Code Editor.
Effective date: April 1, 2018
Implementation date: April 2, 2018
April 2018 Integrated Outpatient Code Editor (I/OCE) Specifications Version 19.1
On March 2, CMS published Medicare Claims Processing Transmittal 3989 regarding instructions and specifications for the I/OCE updates for April 1, 2018. The April 2018 changes are listed in two attachments to the transmittal.
Effective date: April 1, 2018
Implementation date: April 2, 2018
Appropriate Use Criteria for Advanced Diagnostic Imaging - Voluntary Participation and Reporting Period - Claims Processing Requirements - HCPCS Modifier -QQ
On March 2, CMS published One-Time Notification Transmittal 2040 to provide instructions on how and when to report HCPCS modifier -QQ (ordering professional consulted a qualified clinical decision support mechanism [CDSM] for this service and the related data was provided to the furnishing professional).
This modifier will be used as part of a program created by the Protecting Access to Medicare Act (PAMA) of 2014, which aims to increase the rate of appropriate advanced diagnostic imaging services rendered to Medicare beneficiaries. If such a service is ordered, a provider will be required to consult a qualified CDSM, an electronic portal through which the practitioner can access appropriate use criteria during the patient workup. These consultations must take place for applicable imaging services furnished in an applicable setting and paid under an applicable payment system, such as the physician fee schedule, OPPS, or ambulatory surgical center payment system. Participation in the program is currently voluntary, but it is expected that the program will be more fully implemented around January 1, 2020.
Effective date: July 1, 2018
Implementation date: July 2, 2018
Comprehensive Error Rate Testing (CERT) Program Dispute Process
On March 2, CMS published Medicare Program Integrity Transmittal 774 regarding revisions to the manual to increase the number of disputes each MAC is allowed to file per month in response to CERT reviews. Each MAC will now be allowed to file two disputed claims per month.
Effective date: March 19, 2018
Implementation date: March 19, 2018