This week in Medicare updates—6/23/2021
Provider Cost Reporting Forms and Instructions, Chapter 41, Form CMS-2540-10
On June 11, CMS published Provider Reimbursement Transmittal 10 regarding updates to the Skilled Nursing Facility Cost Report (Form CMS-2540-10) by revising and modifying various forms and instructions, many of which were updated due to changes from the COVID-19 PHE.
Effective date: Cost reporting periods ending on or after March 31, 2021
Medicare Billing for Cardiac Device Credits
On June 14, CMS updated an MLN Fact Sheet regarding billing for cardiac device credits. The new information applies to reporting a device credit of 50% or greater in the FD code value portion of a claim. In 2020, Medicare started applying a device offset cap to the APC claims that require implantable devices and have device offsets of greater than 30%.
Part B Drug Payments: Impact of Price Substitutions Based on 2019 Average Sales Prices (ASP)
On June 15, the OIG published a Data Snapshot regarding savings generated by CMS’ price substitution policy based on ASPs from 2019. The OIG found that this policy saved Medicare and beneficiaries $6.2 million over one drug based on price substitutions for 18 drugs. The OIG said that if CMS expanded the price substitution criteria by including drugs that exceed the 5% threshold in a single quarter, an additional 24 drugs would have been included in the policy based on 2019 data and CMS could have generated an additional $11.2 million in savings.
Updated OIG Work Plan
On June 15, the OIG updated its Work Plan with the following new items:
- Accuracy of Place-of-Service Codes on Claims for Medicare Part B Physician Services When Beneficiaries Are Inpatients Under Part A
- Audit of Independent Organ Procurement Organizations' Organ Acquisition Overhead Costs
- Audit of CMS Clinical Laboratory Fee Schedule Rate-Setting Process for Public Health Emergencies
- Medicare Payments for Clinical Diagnostic Laboratory Tests in 2020
Quarterly Update for Clinical Laboratory Fee Schedule (CLFS) and Laboratory Services Subject to Reasonable Charge Payment
On June 15, CMS published Medicare Claims Processing Transmittal 10853, which rescinds and replaces Transmittal 10810, dated May 20, 2021, to revise the policy section and add an updated July PLA Codes attachment. The original transmittal was published regarding the quarterly updates to the CLFS.
CMS revised MLN Matters 12285 on the same date.
Effective date: July 1, 2021
Implementation date: July 6, 2021
Changes to the Laboratory NCD Edit Software for July 2021
On June 15, CMS published Medicare Claims Processing Transmittal 10854, which rescinds and replaces Transmittal 10658, dated March 23, 2021, to change the ICD-10 effective dates in many of the business requirements. The original transmittal was published regarding the July 2021 quarterly release of the edit module for clinical diagnostic laboratory services.
CMS revised MLN Matters 12171 on the same date.
Effective date: July 1, 2021 - unless noted differently in requirements
Implementation date: July 6, 2021
Comment Request: Medicare Advantage Chronic Care Improvement Program (CCIP) Attestations; National Implementation of Hospital Consumer Assessment of Healthcare Providers and Systems (HCAHPS)
On June 17, CMS published a Comment Request in the Federal Register regarding the submission of the following information collections for OMB review:
- Medicare Advantage Chronic Care Improvement Program (CCIP) Attestations
- National Implementation of Hospital Consumer Assessment of Healthcare Providers and Systems (HCAHPS)
Comments are due by July 19.
Comment Request: Medicare Part C and Part D Data Validation (42 CFR 422.516[g] and 423.514[j])
On June 17, CMS published a Comment Request in the Federal Register regarding an information collection titled, “Medicare Part C and Part D Data Validation (42 CFR 422.516[g] and 423.514[j]).”
Comments are due by August 16.
Comment Request: Hospice Request for Certification and Supporting Regulations; Laboratory Personnel Report (CLIA) and Supporting Regulations
On June 17, CMS published a Comment Request in the Federal Register regarding the submission of the following information collections for OMB review:
- Hospice Request for Certification and Supporting Regulations
- Laboratory Personnel Report (CLIA) and Supporting Regulations
Comments are due by July 19.
Updated List of CMS Recognized PC IOLs and AC IOLs
On June 17, CMS published an updated List of presbyopia-correcting intraocular lenses (PC IOLs) and astigmatism-correcting IOLs (AC IOLs). There are new PC IOLs under three different brands, new AC IOLs under five different brands, and new PC/AC IOLs under two different brands.
New/Updated Emergency Use Authorizations for COVID-19 Monoclonal Antibody Treatments
On June 17, CMS updated its COVID-19 Vaccines and Monoclonal Antibodies webpage with information on billing and coding for a new product (sotrovimab) and updated information for Regeneron’s casirivimab and imdevimab treatment.
Sotrovimab received an EUA as a COVID-19 monoclonal antibody treatment, effective May 26. Providers should report Q0247 for the product, M0247 for the administration, or M0248 for administration in the home or residence. The government will not provide the drug for free. The payment allowance for Q0247 is $2,394. Payment for administration in a healthcare setting (M0247) will be $450, and payment for home administration (M0248) will be $750.
On June 3, the FDA revised the EUA for the casirivimab and imdevimab combo product to change the dose from 2400 mg to 1200 mg. Providers should report Q0244 for the 1200 mg dose of this product, M0243 for administration in a healthcare setting, and M0244 for administration in the patient’s home or residence. The government is providing this product for free, but administration will be paid at the same rate per setting as the other antibody treatments.
Direct Contracting Model - Professional and Global Options: Homebound Home Health Waiver and Concurrent Care for Beneficiaries that Elect the Medicare Hospice Benefit - Implementation
On June 17, CMS published Demonstrations Transmittal 10859, which rescinds and replaces Transmittal 10466, dated November 13, 2020, to remove the provider education BR 11942.12. The transmittal is no longer sensitive and may now be posted to the internet. The transmittal discusses implementation of the Homebound Home Health Waiver and the Concurrent Care for Beneficiaries that Elect Medicare Hospice Benefit under the Direct Contracting Model. It also establishes the demo code for the model, which is 92.
Effective date: April 1, 2021
Implementation date: January 4, 2021 - Analysis, Design, and some Coding; April 5, 2021 - Complete Coding, Testing, and Implementation