Medicare PECOS Update: Denials Will Begin May 1, 2013!

Medicare PECOS Update cmsMedicare PECOS Edits Begin May 1, 2013 – Claim Denials Possible

nEffective May 1, 2013, the Centers for Medicare & Medicaid Services (CMS) will turn on the Phase 2 denial edits. This means that Medicare will deny claims for services or supplies that require an ordering/referring provider to be identified and that provider is not identified, is not in Medicare’s enrollment records, or is not of a specialty type that may order/refer the service/item being billed.nnThe Affordable Care Act, Section 6405, “Physicians Who Order Items or Services are Required to be Medicare Enrolled Physicians or Eligible Professionals,” requires physicians or other eligible professionals to be enrolled in the Medicare Program to order or refer items or services for Medicare beneficiaries. Some physicians or other eligible professionals do not and will not send claims to a Medicare contractor for the services they furnish and therefore may not be enrolled in the Medicare program. Also, effective January 1, 1992, a physician or supplier that bills Medicare for a service or item must show the name and unique identifier of the attending physician on the claim if that service or item was the result of an order or referral. Effective May 23, 2008, the unique identifier was determined to be the National Provider Identifier (NPI). The Centers for Medicare & Medicaid Services (CMS) has implemented edits on ordering and referring providers when they are required to be identified in Part B, DME, and Part A HHA claims from Medicare providers or suppliers who furnished items or services as a result of orders or referrals.nnThis means that starting May 1, Medicare will deny claims for Medicare-covered services ordered/referred by a physician for durable medical equipment, prosthesis, orthotics and services (DMEPOS), clinical lab, radiology services and certification of home health if the physician does not have a Medicare profile in the Medicare enrollment system, PECOS. The Centers for Medicare & Medicaid Services (CMS) says physicians who order such services and are not enrolled should do so immediately, or the applications may not be processed before May 1.nnSo if you order or refer items or services for Medicare beneficiaries and you do not have a Medicare enrollment record, you need to submit an enrollment application to Medicare. You can do this using the Internet-based Provider Enrollment, Chain, and Ownership System (PECOS) or by completing the paper enrollment application (CMS-855O). Review the background and additional information below and make sure that your billing staff is aware of these updates.n

The Ordering and Referring Files n

nMedicare PECOS Update: Denials Will Begin May 1, 2013!The downloads below contain the National Provider Identifier (NPI) and legal name (last name, first name) of all physicians and non-physician practitioners who are of a type/specialty that is legally eligible to order and refer in the Medicare program and who have current enrollment records in Medicare (i.e., they have enrollment records in PECOS).nnA new file will be made available periodically that will replace the posted file; at any given time, only one file (the most recent) will be available. The file can be downloaded by users with technical expertise and further sorted or manipulated. It can also be used to search for a particular physician or non-physician practitioner by NPI or by name. Please note the following: (1) Records are in alphabetical order based on the surname of the physician or non-physician practitioner. (2) Name suffixes (e.g., Jr.), if they exist, are not displayed. (3) There are no “duplicates” in the file. Many physicians or non-physician practitioners share the same first and last name; their corresponding NPIs are the assurance of uniqueness. (4) Deceased physicians and non-physician practitioners are not included in the file.nnThere are two file formats for the Medicare Ordering and Referring File below. The first is a PDF format. This file will allow a user to verify that an individual physician or eligible professional has an approved enrollment record in PECOS using Adobe Acrobat Reader. The second file is a ZIP file. The ZIP file contains the same information as the PDF, however, the file is a CSV format. The CSV file will allow users to open the Ordering and Referring data in Excel, Notepad and other software formats that could be easier for users to search/sort.nnIn order to use the CSV file, please left-click on the “Medicare Ordering and Referring File [ZIP, 64400KB]” and save the CSV document contained in the zipped download. Right-click on the saved CSV file, select “Open With” on the task bar and select the program through which you would like open the Medicare Ordering and Referring File.nnUsers must have the most recent version of Adobe Acrobat Reader and/or Excel in order to open the PDF and/or CSV file.nnThe new Initial Physician and Non-Physician Applications Pending Contractor Review files are lists of applications pending contractor review. These pending applications have NOT been processed by the CMS contractors. These lists have been compiled to allow individuals the ability to verify that an application has been submitted and is awaiting processing.nnThe downloads below are the most recent versions of the O&R file. For a specific create date, please review each document individually.n

Educational Material MLN Matters® article #SE1305 Full Implementation of Edits on the Ordering/Referring Providers in Medicare Part B, DME and Part A Home Health Agency (HHA) Claims.

nMedicare Enrollment Guidelines for Ordering/Referring ProvidersnnThe Basics of Medicare Enrollment for Physicians Who Infrequently Receive Medicare Reimbursementn

Downloads

nMedicare Ordering and Referring File – PDF [ZIP, 32MB] nnMedicare Ordering and Referring File – CSV [ZIP, 9MB] nnInitial Physician Applications Pending Contractor Review [ZIP, 228KB] nnInitial Non Physician Applications Pending Contractor Review [ZIP, 92KB]nn[hr]Click here for more information.n

Need help with PECOS enrollment? Call us today!

nSource: www.envoynews.com; April 3, 2013.

Allergy Season!

Allergy Season!J30.1 – Hay fevernnJ30.81 – Rhinitis due to animal dandernnJ30.2 – Seasonal allergiesnnJ30.89 – Rhinitis due to feathersnnL23.7 – Allergic Dermatitis due to plantsnnIn preparation for the upcoming deadline for ICD-10 implementation, Welter Healthcare Partners presents weekly ICD-10 Codes of the Week! Our goal is to familiarize you with the new and expanded code set and the additional clinical documentation needed from your providers to comply with ICD-10 coding, and more importantly, for accurate and clean claims submission to keep your revenue stream flowing! We are to help YOU prepare for the October 1, 2014 implementation date. Please don’t hesitate to contact us for all of your training and education needs!

Easter Issues

Easter IssuesW61.33xA – Pecked by Easter chick, Initial EncounternnT62.8x1A – Food Poisoning, accidental, Initial Encounter, old hard-boiled Easter EggnnF40.218 – Easter Bunny Phobiann nnIn preparation for the upcoming deadline for ICD-10 implementation, Welter Healthcare Partners presents weekly ICD-10 Codes of the Week! Our goal is to familiarize you with the new and expanded code set and the additional clinical documentation needed from your providers to comply with ICD-10 coding, and more importantly, for accurate and clean claims submission to keep your revenue stream flowing! We are to help YOU prepare for the October 1, 2014 implementation date. Please don’t hesitate to contact us for all of your training and education needs!

CAQH Launches New, Efficient Solution for EFT Enrollment!

CAQH Launches New, Efficient Solution for EFT Enrollment!CAQH recently launched a new solution to enroll in EFT with participating payers through a universal process! Enrollment is easy!nnUsing CAQH’s EFT Enrollment utility, providers can securely enroll in electronic payment programs with payers. The site streamlines enrollment in these programs by eliminating the multiple and different forms required by each payer, and centralizing EFT enrollment between multiple payers. Once the information is entered, making changes for your practice can be done quickly and easily.n

Go to https://solutions.caqh.org for more information.

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Source: www.caqh.org; January 30, 2013.

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Healthcare and Reimbursement Updates

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Part B Rebilling After RAC Audits

cmsOn March 13, 2013, the Centers for Medicare & Medicaid Services (CMS) issued a ruling contrary to its traditional billing policy regarding payment of Part B inpatient services following denial of a Part A claim. Ruling CMS-1455-R came about in response to an increasing number of Administrative Law Judge (ALJ) and Medicare Appeals Council decisions relating to RAC audit appeals which, while upholding Part A denials based on determinations that inpatient admissions were not reasonable and necessary, ordered payment under Part B as if services were rendered at an outpatient or “observation level” of care. The Ruling allows providers to submit Part B inpatient claims for a more expansive range of services upon denial of Part A claims during RAC appeals.nnUnder the Ruling, a hospital may submit Part B inpatient claims for services beyond those listed in the Medicare Benefit Policy Manual (MBPM) when:n

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  1. A Medicare review contractor denies the Part A inpatient claim upon finding that the inpatient admission was not reasonable and necessary;
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  3. The Part B services would have been payable to the hospital if the beneficiary was treated initially as an outpatient; and
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  5. The billed services do not require outpatient status, e.g. outpatient visits, emergency department visits, and observation services.
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nThe Ruling allows hospitals to submit Part B claims for payment provided the hospital withdraws its appeal on the corresponding Part A claim. The Ruling applies to Medicare claims denied by RAC auditors after March 13, 2013, or Medicare claims in a pending RAC appeal at any level as of March 13, 2013. Going forward from this Ruling, the scope of RAC appeals will be limited to review of Part A inpatient claims, and ALJs are not to order Part B payment or remand for consideration of Part B payment.nnLastly, the Ruling sets forth the time period within which a provider must bill the Part B claims. Generally speaking, hospitals must submit Part B claims within 180 days of receipt of an appeal dismissal notice, final or binding unfavorable appeal decision, or determination of a Part A inpatient claim for which there is no pending appeal and for which the hospital does not appeal. Further, Part B inpatient and outpatient claims filed later than one year after the date of service will not be rejected as untimely, provided the denied Part A inpatient claim was timely filed.n

CMS Proposed Rule

nConcurrent with the Ruling, CMS released a proposed rule on Part B inpatient billing that would apply on a prospective basis. Following a Part A claims denial due to inpatient admissions that are not reasonable and necessary, the proposed rule similarly allows payment for reasonable and necessary Part B services had the beneficiary been treated as an outpatient. Likewise, the proposed rule excludes payment for services that require outpatient status. However, unlike the Ruling, the proposed rule also applies when a hospital determines after discharge that a beneficiary’s inpatient admission was not reasonable and necessary. Further, the proposed rule continues to apply timely filing restrictions on Part B billing for inpatient services; contrary to the Ruling, any Part B services must be filed within one year from the date of service.n

What Providers Should Know

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  • Providers should keep this Ruling in mind when reviewing RAC denials to make strategic decisions, that is, the choice between 1) pursuing Part A payments by arguing that inpatient admission was reasonable and necessary versus 2) dropping the appeal and re-billing the claim as Part B inpatient.
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  • Because hospitals still cannot bill for observation services when an inpatient admission is denied, the Ruling will not significantly affect medical services billing but may affect billing for procedures.
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nSource: www.polsinelli.com; March 13, 2013.n

Healthcare and Reimbursement Updates

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2013 Humana Provider Compliance Certification!

2013 Humana Provider Compliance Certification!Health care providers are REQUIRED to complete Compliance Certification! The Centers for Medicare & Medicaid Services (CMS) requires that all Humana business partners, including health care providers, complete required compliance training and certifications.

nHealth care providers can complete this information online via Humana’s secure Compliance website, which requires internet access. To access the website, health care providers must be registered on Humana.com or Availity.com. Detailed instructions and additional information on completing these requirements, including registration, are available here. While health care providers are encouraged to complete the compliance requirements within 30 days of notification, these requirements must be completed no later than December 31, 2013.nnSource: www.humana.com; February 2, 2013.n

Healthcare and Reimbursement Updates

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