The policies that CMS publishes each year in the OPPS proposed rule don't always come as a surprise. Sometimes, CMS will announce its future intent in a previous rule in order to notify providers about data it is looking at or requesting comments on.
When CMS introduced the -X{EPSU} modifiers in August 2014 to be used in specific instances to replace modifier -59 (distinct procedural service), the agency encouraged "rapid migration" to the new modifiers.
Q: I work in long-term care, and I am familiar with the language in HIPAA regulations regarding requests for electronic copies of medical records for a reasonable fee according to community standards. However, my company does not maintain its medical records in electronic form, nor do we presently have the capability of converting our paper records into electronic format.
CMS released updated I/OCE specifications in January with several changes that could require providers to examine claims submitted early in 2015 that include comprehensive APCs (C-APC) to ensure proper payment.
