This week in Medicare updates—7/22/2020
Influenza Vaccine Payment Allowances - Annual Update for 2020-2021 Season
On July 10, CMS published Medicare Claims Processing Transmittal 10213 regarding the payment allowances for the seasonal influenza vaccine.
CMS published MLN Matters 11882 on the same date to accompany the transmittal.
Effective date: August 1, 2020
Implementation date: August 3, 2020
Notice of New Interest Rate for Medicare Overpayments and Underpayments - 4th Qtr Notification for FY 2020
On July 13, CMS published Medicare Financial Management Transmittal 10220 regarding notification of the new interest rate for Medicare overpayments and underpayments. The Department of the Treasury has changed the private consumer rate to 9.50%.
Effective date: July 20, 2020
Implementation date: July 20, 2020
Updates in the Fiscal Intermediary Shared System (FISS) Inpatient Provider Specific Files
On July 14, CMS published Medicare Claims Processing Transmittal 10222, which rescinds and replaces Transmittal 10140, dated May 15, 2020, to add BR 11797.3.1. The original transmittal was issued regarding modifications to systems in accordance with changes to wage index caps for SNFs, inpatient psychiatric facilities, and inpatient rehabilitation facilities for FY 2021.
Effective date: October 1, 2020
Implementation date: October 5, 2020
Medicare Appeals System (MAS) Enhanced Web Services for Part A MACs
On July 14, CMS published One-Time Notification Transmittal 10223, which rescinds and replaces Transmittal 10172, dated June 12, 2020, to change the implementation date from July 13, 2020, to August 18, 2020. The original transmittal was issued to serve as a notice for MACs that a project to update automation of appeal creation and document uploading is beginning after MAS Amazon Web Service Stage 3 was completed in April 2020.
Effective date: August 18, 2020
Implementation date: August 18, 2020
FAQs: Exceptions for Dialysis Facilities Affected by COVID-19
On July 14, CMS updated an FAQ document regarding the Extraordinary Circumstances Exception for the ESRD Quality Incentive Program. The new FAQs address scoring for certain measures once reporting resumes, and who should report information if an isolation facility drew patient labs and dialyzed a patient instead of the home facility.
COVID-19 FAQs on Medicare Fee-for-Service Billing
On July 15, CMS updated an FAQ regarding the latest guidance on billing for COVID-19. This round of updates included a revision for information on delayed filing deadlines for cost reports impacted during the COVID-19 PHE. The revised due date for the cost reporting period ending 12/31/2019 is now 8/31/2020. It also included new information stating that SNFs or hospitals can accept government resources to help with the COVID-19 emergency and still bill Medicare due to an exception for services furnished as a means of controlling infectious diseases.
CMS continues to update this document on a regular basis. Providers should review frequently for new information.
Updated Corporate Integrity Agreement Documents
On July 15, the OIG published information on new Corporate Integrity Agreements with the following organizations:
- Associated Pain Specialists, P.C., of Knoxville, TN
- Universal Health Services, Inc. and UHS of Delaware, Inc., of King of Prussia, PA
Hospitals Overbilled Medicare $1 Billion by Incorrectly Assigning Severe Malnutrition Diagnosis Codes to Inpatient Hospital Claims
On July 15, the OIG published a Review of whether hospitals complied with Medicare billing requirements when assigning severe malnutrition diagnosis codes to inpatient hospital claims. The OIG found that hospitals billed Medicare incorrectly for 173 of the 200 claims reviewed. The vast majority of those claims (164 claims) contained severe malnutrition diagnosis codes when hospitals should have instead used codes for other forms of malnutrition or no malnutrition diagnosis code at all. A minority of claims (nine claims) had medical record documentation that supported a secondary diagnosis code other than severe malnutrition, but the error did not change the DRG or payment. These errors resulted in net overpayments of $914,128, which the OIG estimates would represent overpayments of $1 billion for FYs 2016 and 2017.
The OIG recommends CMS collect the portion of overpayments within the reopening period and notify providers so they can identify, report and return any overpayments in accordance with the 60-day rule. It also includes other recommendations, such as reviewing all claims that were not part of the sample but are within the reopening period. CMS concurred with the recommendations, but it noted that the estimated overpayments identified by the OIG represent less than 0.5% of overall payments made for inpatient services during the audit period. The OIG stated that because 82% of claims in the sample were not correctly billed, the findings are significant and should be addressed.
Updated OIG Work Plan
On July 15, the OIG updated its Work Plan with the following new items:
- Audit of CMS's Controls Over the Expanded Accelerated and Advance Payment Program Payments and Recovery
- Assessing Trends Related to the Use of Psychotropic Drugs in Nursing Homes
- Hospital Collection Effort for Medicare Bad Debt Basic Health Program Eligibility Determinations
- Biosimilar Trends in Medicare Part D
- Beneficiary Cost-Sharing in Part D
- Analysis of New Rural Add-On Payment Methodology
July 2020 Update of the Hospital Outpatient Prospective Payment System (OPPS)
On July 15, CMS published Medicare Claims Processing Transmittal 10224, which rescinds and replaces Transmittal 10207, dated July 2, 2020, to correct numerous errors or omissions from the previous two versions. Changes include an updated section on COVID-19 lab tests and services and other laboratory tests coding update, the addition of three new COVID test codes to Table 1 (87426, 0223U, and 0224U), a change in the status indicator for HCPCS code Q5112 from E2 to K, and more. The original transmittal was issued regarding the July 2020 update of the OPPS.
CMS revised MLN Matters 11814 on the same date to accompany the transmittal.
Effective date: July 1, 2020
Implementation date: July 6, 2020
Comment Request: Information Collection for Machine Readable Data for Provider Network and Prescription Formulary Content for FFM QHPs; more
On July 17, CMS published a Comment Request in the Federal Register regarding the following information collections:
- Information Collection for Machine Readable Data for Provider Network and Prescription Formulary Content for FFM QHPs
- Beneficiary and Family Centered Data Collection
Comments are due by September 15, 2020.
Comment Request: Medication Therapy Management Program Improvements--Standardized Format
On July 17, CMS published a Comment Request in the Federal Register regarding the submission for OMB review of an information collection titled “Medication Therapy Management Program Improvements--Standardized Format.”
Comments are due to the OMB desk officer by August 17, 2020.
Application From The Joint Commission for Continued Approval of its Hospital Accreditation Program
On July 17, CMS published a Final Notice in the Federal Register announcing its decision to approve The Joint Commission for continued recognition as a national accrediting organization for hospitals that wish to participate in the Medicare or Medicaid programs.
Dates: This decision is effective on July 15, 2020 through July 15, 2022.
File Conversions Related to the Spanish Translation of the HCPCS Descriptions
On July 17, CMS published Medicare Claims Processing Transmittal 10221 regarding the regular quarterly file conversions related to the Spanish translation of HCPCS descriptions provided by First Coast Service Options.
Effective date: October 1, 2020
Implementation date: October 5, 2020