This week in Medicare updates—3/28/18
April 2018 Update of the Hospital Outpatient Prospective Payment System (OPPS)
On March 20, CMS published Medicare Claims Processing Transmittal 4005, which rescinds and replaces Transmittal 3988, dated March 2, 2018, to correct the number of drugs and biologicals with OPPS pass-through status effective April 1, 2018, to eleven drugs and to remove HCPCS code J0606 from Table 5 in Attachment A since its status indicator will not change for the April update.
On March 22, CMS revised MLN Matters 10515 to accompany the revised transmittal.
Effective date: April 1, 2018
Implementation date: April 2, 2018
April 2018 Integrated Outpatient Code Editor (I/OCE) Specifications Version 19.1
On March 21, CMS published Medicare Claims Processing Transmittal 4006, which rescinds and replaces Transmittal 3989, dated March 2, 2018, to update the status indicator for the drug code J0606 from SI=G to SI=K in the attachments.
On March 22, CMS published a revised version of MLN Matters 10514 to accompany the revised transmittal.
Effective date: April 1, 2018
Implementation date: April 2, 2018
Claims Processing Actions to Implement Certain Provisions of the Bipartisan Budget Act of 2018
On March 20, CMS published One-Time Notification Transmittal 2047, which rescinds and replaces Transmittal 4003, dated March 16, 2018, to revise the provider education section and change the CR type from a Confidential CR to a One-Time Notification. The original transmittal provides directions to reprocess claims related to several provisions of the Bipartisan Budget Act of 2018, including provisions regarding ambulance add-on payments, the Work GPCI Floor, the 3% home health rural add-on payment, and outpatient therapy caps.
Effective date: January 1, 2018
Implementation date: April 2, 2018 - date to begin reprocessing claims
Correction Notice: Public Meetings in Calendar Year 2018 for All New Public Requests for Revisions to the HCPCS Coding and Payment Determinations
On March 21, CMS published a Correction Notice in the Federal Register to correct the dates for the June meetings listed in CY 2018 HCPCS Public Meeting Notice, published February 28, 2018, as CMS previously published incorrect dates in the original notice for both June meetings. The correct dates are:
- Tuesday, June 5, 2018, 9 a.m. to 5 p.m. ET (Durable Medical Equipment [DME], and Accessories, Orthotics and Prosthetics [O&P], Supplies and Other)
- Wednesday, June 6, 2018, 9 a.m. to 5 p.m. ET (DME and Accessories, O&P, Supplies and Other)
April Quarterly Update for 2018 Durable Medical Equipment, Prosthetics, Orthotics and Supplies (DMEPOS) Fee Schedule
On March 21, CMS published Medicare Claims Processing Transmittal 4004, which rescinds and replaces Transmittal 3994, dated March 9, 2018, to correct typographical errors in the volume adjustment policy section.
On March 22, CMS published MLN Matters 10503 to accompany the transmittal.
Effective date: April 1, 2018
Implementation date: April 2, 2018
All-Payer Combination Option & Other Payer Advanced APMs FAQs, Glossary
On March 22, CMS published an FAQ and a Glossary regarding the All-Payer Combination Option and Other Payer Advanced Alternative Payment Models (APM) under the Quality Payment Program (QPP). The fact sheet provides information on eligibility, nominal amount standards, performance periods, scoring, and the payer initiated and eligible clinician initiated processes within this participation pathway.
APM Special Scoring Standard Resources
On March 23, CMS published four resources regarding special scoring standards for alternative payment models (APM). These resources include:
- Performance Year 2018 Quality Performance Category Scoring Web Interface Reporters Under The APM Scoring Standard
- 2018 Other MIPS APM Quality Performance Category
- Scores for Improvement Activities in MIPS APMs in the 2018 Performance Period
- 2018 Quality Performance Category Scoring for Alternative Payment Models
Announcement of the Approval of the American Association for Laboratory Accreditation (A2LA) as an Accreditation Organization Under the Clinical Laboratory Improvement Amendments of 1988
On March 23, CMS published a Notice in the Federal Register to announce the approval of the A2LA application to be an accreditation organization for clinical laboratories under CLIA. CMS will grant deeming authority to the A2LA for a period of four years.
Applicable date: This notice is applicable from March 23, 2018 to March 23, 2022.
Approval of the Community Health Accreditation Partner for Continued CMS Approval of its Home Health Agency Program
On March 23, CMS published a Notice in the Federal Register to announce the approval of the Community Health Accreditation Partner (CHAP) for continued recognition as a national accrediting organization for home health agencies that wish to participate in Medicare or Medicaid programs.
Dates: This notice is applicable March 31, 2018 through March 31, 2024
Notification of Change in Instructions for Handling Inpatient Rehabilitation Facility (IRF) Active Provider List
On March 23, CMS published Medicare Claims Processing Transmittal 4008 to update the instructions for handling the IRF Active Provider List by instructing regional offices to send direct emails about Active Provider Lists to the CMS designated mailbox.
Effective date: April 23, 2018
Implementation date: April 23, 2018
Revisions to Medicare Claims Processing Manual for End Stage Renal Disease
On March 23, CMS published Medicare Claims Processing Transmittal 4010 to revise an instruction in the manual regarding relative compensation equivalent (RCE) limits for reporting an ESRD facility’s medical director fees on cost reports. These RCE limits are no longer applicable effective January 1, 2016, but A/B MACs may continue to request physician’s logs and other documentation as support for the information reported in the cost report.
Effective date: June 26, 2018
Implementation date: June 26, 2018
Many Medicare Claims for Outpatient Physical Therapy Services Did Not Comply With Medicare Requirements
On March 23, the OIG published a Review of whether Medicare claims for outpatient physical therapy services complied with Medicare requirements. The OIG found that 61% of the 300 claims randomly selected for review did not comply with Medicare requirements, resulting in an estimated $367 million in overpayments during the six-month audit period. Most of the errors were due to incorrect coding, as 145 claims had errors such as a mismatch between the time units in the codes and the time units in the treatment notes (86 claims), missing modifiers (78 claims), and incorrect codes (59 claims). Other claim errors were due to failures to meet medical necessity and/or documentation requirements.
The OIG recommends CMS establish mechanisms to better monitor the appropriateness of outpatient physical therapy claims and educate providers about Medicare requirements for submitting outpatient physical therapy claims for reimbursement.