This week in Medicare updates—4/25/18
CMS Paid Practitioners for Telehealth Services That did not Meet Medicare Requirements
On April 13, the OIG posted a Review of a study done to determine whether CMS paid providers for telehealth services that meet Medicare requirements. The OIG found that CMS paid for telehealth services that did not meet Medicare requirements in 31 of the 100 claims included in the review sample, resulting in an estimated $3.7 million in improper payments during the audit period. Of those 31 claims, 24 were unallowable because beneficiaries received services at nonrural originating sites.
The OIG recommends CMS conduct periodic post-payment reviews to disallow payments for errors for which telehealth claim edits cannot be implemented, work with Medicare contractors to implement all telehealth claim edits, and offer education and training sessions to practitioners on Medicare telehealth requirements.
Updated OIG Work Plan
On April 16, the OIG updated its Work Plan with the following new items:
- CMS Medicare Overpayment Recoveries Related to Recommendations in OIG Audit Reports
- Ensuring Dual-Eligible Beneficiaries' Access to Drugs Under Part D: Mandatory Review
New OIG Compliance Resources Page
On April 16, the OIG announced the creation of a new Web Portal with links to resources for the public that can help providers and suppliers ensure they are in compliance with federal healthcare laws. The resources on the page include:
- Toolkits
- Provider Compliance Resources and Training
- Advisory Opinions
- Voluntary Compliance and Exclusions Resources
- Special Fraud Alerts, Other Guidance, and Safe Harbor Regulations
- Resources for Health Care Boards
- Resources for Physicians
- Accountable Care Organizations
Medicare Quarterly Provider Compliance Newsletter
On April 16, CMS published the Medicare Quarterly Provider Compliance Newsletter for April 2018. This edition of the newsletter contains Comprehensive Error Rate Testing (CERT) reports on E/M services and ventilator services provided as a durable medical equipment (DME) device. The newsletter also includes a recovery auditor finding on improper billing by suppliers billing for DME for beneficiaries in a Medicare inpatient stay.
Comment Request: Consumer Assessment of Healthcare Providers and Systems Outpatient and Ambulatory Surgery (OAS CAHPS) Survey
On April 16, CMS published a Comment Request in the Federal Register regarding an information collection titled, “Consumer Assessment of Healthcare Providers and Systems Outpatient and Ambulatory Surgery (OAS CAHPS) Survey.” Comments are due by June 15, 2018.
Update on CMS policy on posting RAC review topics
On April 16, CMS posted an Update to its Provider Resources page regarding the way it will handle posting proposed and approved RAC review topics. CMS noted it will post monthly lists of proposed RAC review topics and will add a list of approved RAC review topics in June of 2018. After a new issue has gone through the CMS 30-day posting, the issue will then be posted to each RAC website.
CMS’s Policies and Procedures Were Generally Effective in Ensuring That Prescription Drug Coverage Capitation Payments Were Not Made After the Beneficiaries’ Dates of Death
On April 18, the OIG posted a Review of whether CMS’ policies ensured that capitation payments were not made to Medicare Advantage organizations’ prescription drug plans and stand-alone drug plans for Medicare Part D coverage on behalf of deceased beneficiaries after their dates of death. The OIG found that CMS’ policies and procedures were generally effective in preventing payments for Medicare Part D coverage on behalf of deceased beneficiaries after their death, but CMS had not identified and recouped all improper capitation payments. As of March 7, 2017, CMS had not recouped $1.1 million in capitation payments, which represented .097% of the total capitation payments made after beneficiaries’ dates of death. The OIG recommends CMS recoup those payments and implement system enhancements to identify and recoup improper capitation payments in the future.
PEPPERs Available for Hospices, SNFs, IRFs, IPFs, CAHs, LTCHs
On April 19, CMS published a Notice in the weekly MLN Connects newsletter to announce that fourth quarter FY 2017 Program for Evaluating Payment Patterns Electronic Reports (PEPPERs) are now available for a variety of facility types. This data can be used to support internal auditing and monitoring activities.
Updated Corporate Integrity Agreement Documents
On April 20, the OIG published information on a new Corporate Integrity Agreement with Banner Health of Phoenix, AZ.
Update of the Internet Only Manual (IOM), Medicare Claims Processing Manual, Publication 100-04, Chapter 37 - Department of Veterans Affairs (VA) Claims Adjudication Services Project
On April 20, CMS published Medicare Claims Processing Transmittal 4023 to update the manual to include requirements for processing VA Durable Medical Equipment, Prosthetics, Orthotics and Supplies (DMEPOS) claims.
Effective date: July 20, 2018
Implementation date: July 20, 2018
Quarterly Healthcare Common Procedure Coding System (HCPCS) Drug/Biological Code Changes - July 2018 Update
On April 20, CMS published Medicare Claims Processing Transmittal 4025 regarding the quarterly updates to drug/biological HCPCS codes. Beginning July 1, 2018, the following HCPCS codes will be introduced:
- Q9991, Injection, buprenorphine extended-release (sublocade), less than or equal to 100 mg
- Q9992, Injection, buprenorphine extended-release (sublocade), greater than 100 mg
- Q9993, Injection, triamcinolone acetonide, preservative-free, extended release, microsphere formulation, 1 mg
- Q9995, Injection, emicizumab-kxwh, 0.5 mg
Effective date: July 1, 2018
Implementation date: July 2, 2018