This week in Medicare updates—6/27/2018
July 2018 Update of the Hospital Outpatient Prospective Payment System (OPPS)
On June 15, CMS published Medicare Claims Processing Transmittal 4075, which rescinds and replaces Transmittal 4064, dated June 1, 2018, to make several changes to the July 2018 OPPS update transmittal. Some of these changes include:
- The addition of three new codes to the update (two for biosimilar biological products, one for proprietary lab analyses)
- A change in status indicators for drug codes J9216 and Q2049 to SI “E2”
- The addition of code Q9994 to business requirement 10781.2
CMS published a revised version of MLN Matters 10781 on June 19 to accompany the revised transmittal.
Effective date: July 1, 2018
Implementation date: July 2, 2018
July 2018 Integrated Outpatient Code Editor (I/OCE) Specifications Version 19.2
On June 15, CMS published Medicare Claims Processing Transmittal 4074, which rescinds and replaces Transmittal 4065, dated June 1, 2018, to make revisions to the Summary of Changes and Summary of Modifications documents. The original transmittal was issued regarding instructions and specifications for the July 1, 2018 quarterly update to the I/OCE.
CMS published a revised version of MLN Matters 10699 on June 18 to accompany the revised transmittal.
Effective date: July 1, 2018
Implementation date: July 2, 2018
Correction Notice: FY 2019 IPPS Proposed Rule
On June 18, CMS published a Correction Notice in the Federal Register to correct technical and typographical errors that appeared in the IPPS Proposed Rule, published May 7, 2018. Corrections include fixing incorrect contacts listed for the Medicaid Promoting Interoperability Program and erroneous citations to 45 CFR when discussing CEHRT capabilities and standards that eligible hospitals and CAHs must use.
Dates: June 20, 2018
Updated Civil Monetary Penalties and Affirmative Exclusions
On June 18, the OIG published an updated List of Civil Monetary Penalties and Affirmative Exclusion agreements, including:
- James S. Dunn, Jr., MD, and James S. Dunn Jr., MD, Inc. d/b/a Auburn Urogynecology and Women’s Health, of Auburn, California, reached a $419,578 settlement agreement on June 11 with the OIG to resolve allegations that Dr. Dunn submitted claims to Medicare for items that he knew or should have known were not provided as claimed or were false or fraudulent. These claims included submitting diagnostic CPT codes when therapeutic services were performed and providing physical therapy services by an unqualified individual.
- Comanche County Hospital Authority, d/b/a Comanche County Memorial Hospital, of Lawton, Oklahoma, reached a $566,806 settlement agreement on June 11 with the OIG to resolve allegations that Comanche submitted claims to Medicare for emergency ambulance transportation to skilled nursing facilities and patient residences that should have been billed at the lower non-emergency rate. Comanche also disclosed that it submitted claims for emergency ambulance transportation that were not medically reasonable or necessary and/or did not have documentation consistent with the patient’s condition.
Comment Request: Use of Restraint and Seclusion in Psychiatric Residential Treatment Facilities (PRTFs) for Individuals Under Age 21 and Supporting Regulations
On June 19, CMS published a Comment Request in the Federal Register regarding an information collection titled “Use of Restraint and Seclusion in Psychiatric Residential Treatment Facilities (PRTFs) for Individuals Under Age 21 and Supporting Regulations.” Comments are due by August 20, 2018.
CMS Seeks Public Input on Reducing the Regulatory Burdens of the Stark Law
On June 20, CMS published a Press Release regarding a Request for Information (RFI) to seek public input on how to address regulatory burdens associated with the physician self-referral law (Stark Law). CMS is looking for comments regarding how the law may impede care coordination due to the role of care coordination in value-based systems. CMS is specifically interested in analyzing terms of arrangements between parties that participate in alternative payment models or other novel financial arrangements, the need for revisions or additions to exceptions to Stark Law, and the terminology related to alternative payment models and Stark Law.
Comments on the RFI are due by August 24, 2018.
Revisions to the Telehealth Billing Requirements for Distant Site Services
On June 20, CMS published One-Time Notification Transmittal 2095, which rescinds and replaces Transmittal 4026, dated April 27, 2018, to revise business requirement 10583.1. The original transmittal implements a requirement for providers to only use the GT modifier on institutional claims billed under CAH Method II.
CMS published a revised MLN Matters 10583 on June 21 to accompany the revised transmittal.
Effective date: October 1, 2018
Implementation date: October 1, 2018
Update to the Hospital Transfer Policy for Early Discharges to Hospice Care
On June 20, CMS published One-Time Notification Transmittal 2094, which rescinds and replaces Transmittal 2055, dated April 27, 2018, to remove business requirement 10602.4. The original transmittal updates the transfer policy for hospice care in accordance with the Bipartisan Budget Act of 2018’s modification to the law requiring that, beginning in FY 2019, discharges to hospice care will also qualify as a post-acute care transfer and will be subject to payment adjustments.
Effective date: October 1, 2018
Implementation date: October 1, 2018
CMS Launches Data Element Library Supporting Interoperability
On June 21, CMS published a Press Release and Fact Sheet to announce its new Data Element Library (DEL), a resource that will provide streamlined access to CMS assessment data elements for post-acute care facilities. The DEL will also support industry efforts to promote electronic health record (EHR)/health information technology (IT) interoperability, and CMS anticipates that the DEL will make it easier for IT vendors to incorporate data elements into provider EHRs.
July 2018 Update of the Ambulatory Surgical Center (ASC) Payment System
On June 21, CMS published Medicare Claims Processing Transmittal 4076, which rescinds and replaces Transmittal 4067, dated June 1, 2018, to add missing policy section language as section B.2.e, with a corresponding table in Attachment A, policy section B.2.b and B.2.f, update impacted Attachment A table number labels in the policy section, business requirement 10788.3 and 10788.4, and Attachment A. The original transmittal was issued to implement the July quarterly update of the ASC payment system.
Effective date: July 1, 2018
Implementation date: July 2, 2018
Use of Accessible and Applicable Claims History During Medical Review
On June 22, CMS published Medicare Program Integrity Transmittal 802 to clarify the role of accessible claims/billing history during the course of medical review.
Effective date: July 24, 2018
Implementation date: July 24, 2018