Providers setting charges based on an understanding of their costs is not a new concept, says Jugna Shah, MPH, president and founder of Nimitt Consulting. However, providers struggle with this or fail to do it correctly, and then stand to deteriorate their future payment rates since CMS relies on provider data to set payment rates not only for inpatient and outpatient services, but also for laboratory services.
Eight CPT® codes for multianalyte assays with algorithmic analyses (MAAA) procedures are now classified as not covered under OPPS (status indicator E), retroactive to January 1, 2013. These codes are now subject to I/OCE edit 9.
In January 2013, CMS introduced 42 therapy functional reporting G codes (nonpayable). These G codes are to be reported in conjunction with therapy services (physical, occupational, and speech). CMS also introduced seven complexity/severity modifiers to be used with these G codes.
CMS is reexamining inpatient criteria because it has seen a significant increase in the number of patients spending more than 24 hours in observation. Providers are worried that a Recovery Auditor will deny a short inpatient stay for lack of medical necessity and recoup payment years later. So instead, some facilities place patients in observation for longer time periods.
The AMA revamped coding for molecular pathology beginning in 2012 and continuing in the 2013 CPT ® Manual. Now CMS is trying to determine how to pay for those tests and the agency wants to hear from providers.
Providers were glad to see CMS' ruling (CMS-1455-R) released March 13 (published in the Federal Register on March 18), which allows full Part B payment for inpatient stays that had been denied as not reasonable and necessary. The ruling had very few details on how the process would work, but on March 22, CMS published Transmittal R1203OTN instructing contractors and providers on the details.
Our experts answer questions about modifiers for diagnostic interventional procedures, Medicare recognition of CPT® code 9066, reporting add-on code for psychotherapy with interactive complexity, reporting G0378 for all payers, and wound care coding.
CMS corrected edit 84, added five APCs to the I/OCE, deleted two APCs, and changed the description of another as part of the April updates to the I/OCE. In addition, CMS deleted all of the genetic testing modifiers, retroactive to January 1.
The AMA revised the molecular pathology codes in the CPT® Manual in 2012, but at that time CMS did not adopt the codes as it was still debating whether and how to change the reimbursement system for these services going forward. For CY 2013, CMS elected to recognize the codes, which meant it had to finalize how to pay for them. While CMS did not change pamyent for these services under the Clinical Laboratory Fee Schedule (CLFS) despite industry pressure, its change to the new codes means a change in the payments providers can expect this year and in the future.
Successful appeals can actually lead to CMS policy changes. Facilities have been successfully appealing to receive Part B payments after a Medicare review contractor denied a Part A stay as not medically necessary. As a result, CMS is changing its policy on rebilling for Part B services.
