This week in Medicare updates—9/1/2021
ICD-10 and Other Coding Revisions to NCDS--January 2022
On August 19, CMS published One-Time Notification Transmittal 10963 regarding the regular ICD-10 conversions and coding updates specific to NCDs.
On August 25, CMS published MLN Matters 12399 to accompany the transmittal.
Effective date: January 1, 2022 - Unless otherwise noted in requirements
Implementation date: September 20, 2021 - MACs; January 3, 2022 - shared system maintainers
Health Care Code Sets: ICD-10
On August 23, CMS revised an MLN Fact Sheet regarding health care code sets to add simple code explanations and information on HIPAA requirements to the introduction.
Interim Final Rule - COVID-19 Vaccine Immunization Requirements for Clients and Staff in Intermediate Care Facilities for Individuals with Intellectual Disabilities (ICFs/IID)
On August 23, CMS published a Memorandum to state survey agency directors regarding implementation of policies from a May 2021 interim final rule on COVID-19 vaccine requirements for long-term care facility residents and staff. The memo includes details about the requirements for educating clients or client representatives and staff on the benefits and potential side effects of the COVID-19 vaccines. It also discusses requirements for offering the vaccine, documentation requirements, staff refusal of the vaccine, and more.
Effective date: Immediately. This policy should be communicated with all survey and certification staff, their managers, and the state/regional office training coordinators immediately.
COVID-19 Medicare Provider Enrollment Relief FAQs
On August 24, CMS updated its Medicare Provider Enrollment Relief FAQs document with information about when and how CMS will resume collecting application fees, conducting fingerprint-criminal background checks, and revalidating providers and suppliers. The updates can be found in FAQs 19, 20, 26, and 27.
CMS Expands Medicare Payments for At-Home COVID-19 Vaccinations
On August 24, CMS published a Press Release to announce it is expanding the payments for at-home COVID-19 vaccinations to include communal spaces of a multi-unit living or communal arrangement as well as assisted living facilities participating in the CDC’s Pharmacy Partnership for Long-Term Care Program when resident are vaccinated through the program. CMS will also pay the additional payment amount for vaccines for up to a maximum of five vaccine administration services per home unit or communal space within a single group living location. This only applies, however, when fewer than 10 Medicare patients receive a COVID-19 vaccine dose on the same day at the same location.
CMS published examples of how the math works for these payments on its Medicare COVID-19 Vaccine Shot Payment webpage, coding information for this service on its Coding for COVID-19 Vaccine Shots webpage, and billing information for this service on its Billing for COVID-19 Vaccine Shot Administration webpage.
CMS Needs to Issue Regulations Related to Phlebotomy Travel Allowances
On August 26, the OIG published a Review summarizing its findings from a previous audit of MAC payments to providers for phlebotomy travel allowances and using that previous audit to determine whether CMS guidance needs to be updated to clarify provider requirements related to phlebotomy travel allowances. The OIG found in its previous audit that 109 of the 202 sampled paid claims did not comply with Medicare guidance. Issues pertained to incorrect prorated mileage, incorrect payment rates, and inadequate documentation. The OIG estimates that the MACs reviewed paid $2.7 million to providers for phlebotomy travel allowance payments that were not compliant with Medicare guidance. The OIG spoke to CMS in June 2020 about the issue and it had not begun the process yet at that point to clarify provider requirements on prorated mileage on claims and also had not issued further guidance.
The OIG recommends CMS work with MACs to educate providers on documentation requirements for phlebotomy travel allowances, instruct MACs to identify and adjust any paid claims that incorrectly used the previous year’s rate, and issue regulations related to phlebotomy travel allowances. CMS generally agreed with the recommendations and noted that in the CY 2022 Physician Fee Schedule (PFS) Proposed Rule, it solicited comments on this travel allowance issue. It said it will consider those comments and the OIG’s recommendation when determining appropriate next steps for phlebotomy travel allowances.
National Expansion Implementation for All Remaining States and Territories of the Prior Authorization Model for Repetitive, Scheduled Non-Emergent Ambulance Transports
On August 27, CMS published a Notice in the Federal Register regarding implementation for the remaining states and territories in the Prior Authorization Model for Repetitive, Scheduled Non-Emergent Ambulance Transports. The expansion will occur in a staggered fashion between December 1, 2021 through August 1, 2022.