This week in Medicare—4/3/2024
Electronic Medical Documentation Requests (eMDR) via the Electronic Submission of Medical Documentation System (esMD)
On March 20, CMS revised MLN Matters 11003, which was originally published February 1, 2019, and updated multiple times since, to add information about the implementation of a new feature to accept review outcome letters during the October 2023 release.
Effective date: February 3, 2020
Implementation date: July 1, 2019
HCPCS Quarterly Update
On March 21, CMS published a Download Link for the April 2024 updates to the HCPCS file.
Skilled Nursing Facility 3-Day Rule Billing
On March 25, CMS revised an MLN Fact Sheet regarding SNF 3-day rule billing to clarify that place of service code 21 should be used when a patient is seen in a physician’s office but is an inpatient of the hospital.
Medicare Payment Systems
On March 25, CMS updated its Medicare Payment Systems MLN Educational Tool to update information for a variety of different payment systems based on changes for 2024 finalized through rule-making or previously issued guidance.
OPPS Addendum A and B Updates
On March 26, CMS published download links to the updated versions of the April 2024 Addendum A and Addendum B files.
FY 2025 Inpatient Rehabilitation Facility (IRF) Prospective Payment System (PPS) Proposed Rule
On March 27, CMS released a draft copy of the FY 2025 IRF PPS Proposed Rule, which was published in the Federal Register on March 29. CMS estimates the total IRF PPS payments will increase by 2.8% for FY 2025. CMS is also proposing updates to prospective payment rates, the outlier threshold, case-mix group relative weights and average length of stay values, and more. The rule also includes a proposal regarding updates to the IRF PPS wage index using the core-based statistical areas as defined in the OMB Bulletin 23-01 and would provide a transition for those IRFs who lose the rural adjustment due to their labor market area transitioning from rural to urban.
CMS published a Fact Sheet on the proposed rule on the same date. Comments are due by May 28.
Clarification on Release of 60-Day Quality Improvement Organization Reports by CMS
On March 27, CMS published a Memorandum to state survey agency directors to clarify procedures related to the release of the Quality Improvement Organizations’ (QIO) 60-day report, which occurs after CMS notifies the hospital of an EMTALA violation but before the case is referred to the OIG. CMS states that the 60-day report may not be released to the affected physician and/or hospital until after the OIG investigation is completed and the OIG closes the case.
Effective date: Immediately. Please communicate to all appropriate staff within 30 days.
FY 2025 Hospice Payment Rate Update Proposed Rule
On March 28, CMS published a draft copy of the FY 2025 Hospice Payment Rate Update Proposed Rule, which is scheduled to be published in the Federal Register on April 4. Proposals include a 2.6% increase in hospice payments for 2025 and a proposed aggregate cap amount of $34,364.85. The rule also includes proposals to clarify current policy related to the hospice election statement and notice of election. It would also add clarifying language for hospice certification. CMS also included a comment request regarding the potential implementation of a separate payment mechanism to account for high-intensity palliative care services provided under the hospice benefit.
CMS published a Fact Sheet on the proposed rule. Comments are due by May 28.
FY 2025 Inpatient Psychiatric Facility (IPF) Prospective Payment System (PPS) Proposed Rule
On March 28, CMS published a draft copy of the FY 2025 IPF PPS Proposed Rule, which is scheduled to be published in the Federal Register on April 3. Proposals include a 2.6% update to total estimated payments to IPFs in FY 2025, a proposed revision to the methodology for determining the payment rates under the IPF PPS and patient-level adjustment factors, and a proposed update to the outlier thresholds so that estimated outlier payments remain at 2.0% of total payments. CMS is also proposing to update the wage index using the core-based statistical area labor market areas as defined in the OMB Bulletin 23-01. It would conduct a three-year budget neutral phase-out of the rural adjustment for IPFs located in the 54 rural counties that will become urban under the new OMB delineations.
CMS published a Fact Sheet on the proposed rule. Comments are due by May 28.
FY 2025 Skilled Nursing Facility (SNF) Prospective Payment System (PPS) Proposed Rule
On March 28, CMS published a draft copy of the FY 2025 SNF PPS Proposed Rule, which is scheduled to be published in the Federal Register on April 3. CMS is proposing a 4.1% update to SNF PPS payment rates and would update the SNF market basket base year from the current 2018 base year to the new base year of 2022. The rule also includes proposals to expand CMS’ ability to impose per instance and per day civil monetary penalties for health and safety deficiencies at nursing homes, and it includes several changes to PDPM ICD-10 code mappings to allow for more accurate and appropriate primary diagnoses the meet criteria for skilled intervention during Part A SNF stays.
CMS published a Fact Sheet on the proposed rule. Comments are due by May 28.
Updates to Medicare Claims Processing Manual, Chapter 20, Section 181.1 Payment for Lymphedema Compression Treatment Items
On March 28, CMS published Medicare Claims Processing Transmittal 12557 regarding updates to the chapter on durable medical equipment in the Claims Processing Manual to add information about payment for lymphedema compression treatment items.
Effective date: January 1, 2024
Implementation date: April 29, 2024
Outlier Reconciliation and Cost-to-Charge Ratio (CCR) Updates for the Inpatient Prospective Payment System (IPPS) and Long-Term Care Hospital (LTCH) PPS
On March 28, CMS published Medicare Claims Processing Transmittal 12558 regarding the addition of new criteria to determine which hospitals should have their outlier payments reconciled under the IPPS and LTCH PPS. CMS is also cross-walking the calculation of the IPPS operating and capital CCR and the LTCH CCR from Form CMS-2552-1996 cost report to the Form 2552-2010 cost report.
Effective date: October 1, 2024
Implementation date: October 1, 2024
April 2024 Update of the Ambulatory Surgical Center (ASC) Payment System
On March 28, CMS published Medicare Claims Processing Transmittal 12559 regarding the April 2024 updates to the ASC payment system. Some of the changes include a correction to device offset amounts for existing device HCPCS code C1600, 21 new drug and biological HCPCS codes, new procedure HCPCS codes C9796 and C9797 retroactively effective to January 1, 2024, and more.
Effective date: April 1, 2024
Implementation date: April 1, 2024
July 2024 Quarterly Update to HCPCS Codes Used for SNF Consolidated Billing Enforcement
On March 28, CMS published Medicare Claims Processing Transmittal 12560 regarding the July 2024 updates to the HCPCS codes subject to consolidated billing under the SNF PPS.
Effective date: July 1, 2024
Implementation date: July 1, 2024
Quarterly Update for the DMEPOS Competitive Bidding Program – July 2024
On March 28, CMS published Medicare Claims Processing Transmittal 12561 regarding the instructions for updating the DMEPOS CBP files for the July 2024 quarterly update.
Effective date: July 1, 2024
Implementation date: July 1, 2024
The SSI/Medicare Beneficiary Data for FY 2022 for IPPS Hospitals, Inpatient Rehabilitation Facilities (IRF), and Long-Term Care Hospitals (LTCH)
On March 28, CMS published Medicare Contractor Beneficiary and Provider Communications Transmittal 12562 regarding updated data for determining the disproportionate share adjustment for IPPS hospitals and the low-income patient adjustment for IRFs, as well as payments as applicable for LTCH discharges.
Effective date: April 29, 2024
Implementation date: April 29, 2024
Cost Reporting Updates for Home Office Cost Statement
On March 29, CMS published Provider Reimbursement Manual Transmittal 3 regarding updates to Chapter 28, Home Office Cost Statement, Form CMS-287-22 to clarify cost report instructions.
Effective date: Cost reporting periods ending on or after December 31, 2023