ATTN: Medicare Electronic Funds Transfer (EFT) – JH Implementation Alert
Colorado Providers:nnWe are getting a new Medicare Administrative Contractor (MAC). No longer will Trailblazer be our Medicare contractor. The new company, Novitas Solutions, Inc.nnIf you receive payments through EFT (and you probably do) you must update your information.nnIf you need assistance please e-mail us at info@WHPelter.comnnDO NOT leave this to chance. Payment disruptions (you have heard the horror stories) can be avoided by being proactive.nn
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Medicare Electronic Funds Transfer (EFT) – JH Implementation Alertn IMMEDIATE ACTION REQUIRED TO AVOID PAYMENT DISRUPTION
nDear Provider:nnWelcome to Novitas Solutions, Inc., the Jurisdiction H (JH) Medicare Administrative Contractor (MAC). Our goal is to ensure a smooth transition of your services from your current contractor, TrailBlazer Health Enterprises (TrailBlazer), to Novitas Solutions as the JH MAC. As part of this transition, the Centers for Medicare & Medicaid Services (CMS) requires each active provider/supplier currently enrolled for EFT with TrailBlazer to continue receiving electronic payments from Novitas Solutions.nnTo ensure continued receipt of your electronic payments, the CMS requires you have a 05/10 version of the CMS-588 EFT Authorization Agreement (Agreement) on file with Novitas Solutions. Failure to have a 05/10 version of the Agreement on file with Novitas Solutions may result in a delay or interruption of your Medicare payments post-transition.nnPlease review the below information to determine the type of action you need to take in response to this letter:n
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- If you completed and submitted a 05/10 version of the Agreement to TrailBlazer prior to May 29, 2012 for Part B providers and May 30, 2012 for Part A providers, you are permitted to submit a copy of that Agreement to Novitas Solutions at the address provided on the second page of this letter.
- If you have never completed the 05/10 version of the Agreement, or you did not maintain a copy of a previously submitted 05/10 version, you are required to submit a new 05/10 version of the Agreement to Novitas Solutions at the address provided on the second page of this letter.
- The requested 05/10 version of the Agreement is for the continuation of existing EFT payments. Novitas Solutions cannot accept EFT changes (i.e., changes in bank routing information or authorized representative changes) prior to the planned implementation date of October 29, 2012 for Part A providers and November 19, 2012 for Part B providers. If you wish to change your existing information, please submit those changes to TrailBlazer in advance of the cutover.
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nChanges to EFT information submitted to TrailBlazer on or after May 29, 2012 for Part B providers and May 30, 2012 for Part A providers will be forwarded to Novitas Solutions as part of the transition, no further action is needed on your part.nnNOTE: You are not required to complete a CMS-855 Enrollment application as part of this process. For your convenience we have enclosed a hard copy 05/10 version of the Agreement for you to complete.nnThe “Instructions for Completing the EFT Authorization Agreement” on page 3 of the CMS-588 form provides specific instructions for completion of the agreement. The following are additional tips for completing the CMS-588 form:n
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- CMS-588 Part I – Check the New EFT Authorization box as the reason for the submission (already checked on the attached copy).
- CMS-588 Part II – Ensure that you complete the Medicare Identification Number (your Medicare provider transaction access number (PTAN) or CMS certification number (CCN) that you currently use as issued by the outgoing contractor) as well as the National Provider Identifier (NPI).
- CMS-588 Part III – Ensure banking information is provided including financial institution name, routing number,account number and type of account.
- CMS-588 Part IV – Enter the name and telephone number of a contact person who can answer questions about theinformation submitted.
- CMS-588 Part V – Ensure that your organization’s authorized or delegated official signs the CMS-588 form.
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nIn the event that you need another copy of this form, you may also download a blank agreement from the CMS Website at www.cms.hhs.gov. Please write “JH Transition” at the top of the form for easier identification.nnSubmit a copy or newly completed 05/10 version of the Agreement within 30 days from the date of this letter to the address below:n
Novitas Solutions, Inc.nProvider Enrollment ServicesnJH TransitionnPO Box 890095nCamp Hill, PA 17089-0095nAttention: Shelley Kuhn
nYou will receive a letter notifying you when your application has been processed. Should you have questions or need assistance, see our JH transition website at www.novitas-solutions.com or call us at 1-877-235-8073. Please be sure to identify yourself as a JH provider to expedite the handling of your call.nnThank you for your cooperation. We look forward to serving you.nnSincerely,nProvider Enrollment ServicesnNovitas Solutions, Inc.
d on July 13 that it has not imposed a deadline on states to determine whether to expand their Medicaid programs. The Supreme Court recently ruled that states are not required to participate in the Affordable Care Act’s expansion of the Medicaid program, which expands eligibility to people with incomes up to 133 percent of the federal poverty level. In response to a letter from 10 Republican governors, CMS Acting Administrator Marilyn Tavenner responded that “there will be no deadline for a state to tell [the Department of Health and Human Services] its plans on the Medicaid eligibility expansion.” In addition, states that do not expand Medicaid or establish a health insurance exchange will not have to pay back any federal funding that it has received already.nnIn related news, the National Association of Public Hospitals and Health Systems (NAPH) is concerned that up to 30 states may decline to expand Medicaid. The NAPH President and CEO, Bruce Siegel, said that up to 13 million people would remain uninsured if 30 states, including the 26 that filed suit against the federal government to challenge the ACA and the Medicaid expansion, do not expand Medicaid. NAPH is concerned that hospitals will not be able to provide services if states do not expand Medicaid, particularly in light of the ACA’s reduction in Disproportionate Share Hospital (DSH) payments.nnSource: www.polsinelli.com; Polsinelli Shughart PC; July 18, 2012.
HHS Secretary Kathleen Sebelius sent a letter to state governors July 10 reiterating HHS’ willingness to work with states to help them implement the ACA, to provide assistance and funding to states as they move forward with the establishment of their exchanges, and to allay concerns over Medicaid expansion issues. In her letter, she announced that HHS will host ACA implementation forums in July and August across the country to provide an opportunity to states and stakeholders to learn more about next steps in implementation and to ask questions regarding the establishment of the insurance exchanges. These forums begin next week, starting in Washington, DC. The dates and locations may be found below.n
The U.S. Department of Health & Human Services’ Office for Civil Rights (OCR) has made public its long-awaited HIPAA audit protocol, posting it on its website June 26.nnThe Health Information Technology for Economic and Clinical Health (HITECH) Act, which amended the Health Insurance Portability and Accountability Act in 2009, required OCR to conduct a pilot audit program to assess HIPAA compliance. OCR established the audit protocol, which is searchable and organized around modules, to conduct the audits. The first 20 preliminary audits have been conducted; in all, 115 covered entities will be audited in the pilot program, which will end in December 2012.nnThe audit protocol covers the following requirements:n
Recently, the United States Supreme Court issued its long-awaited decision on the constitutionality of the Patient Protection and Affordable Care Act (the “Act”). In a 5 – 4 decision, with Chief Justice Roberts writing for the majority, the Court upheld the constitutionality of the controversial individual mandate and, thus, the remainder of the Act, with one exception discussed below. The Court upheld the individual mandate on the grounds that it was within Congress’ taxing power to require those who choose to not purchase health insurance to, in essence, pay a tax. A majority of the Court did not agree that the individual mandate was a valid exercise of Congress’ power to regulate interstate commerce.nnImportantly, the Court overturned the provision of the Act that would have allowed the federal government to take away all Medicaid funds from states that chose to not extend Medicaid coverage to all individuals under the age of 65 with incomes below 133% of the federal poverty level. This could mean that a number of states will opt out of the Medicaid expansion thereby reducing the number of currently uninsured who will receive coverage in 2014.nnThe Court’s decision means that all of the other provisions of the Act will remain in place including guaranteed issue, no lifetime caps, no exclusions for preexisting conditions, payment and delivery system reforms such as ACOs, and enhanced fraud and abuse enforcement powers.nnThe decision does not necessarily mean that the Act cannot be repealed by congress or a new president. Congressional Republicans have stated they will continue their efforts to defund the Act, and to repeal it if Gov. Romney becomes President and Republicans take control of both houses of Congress.nnSource: http://www.supremecourt.gov/
The health plans are increasingly putting pressure on providers (especially surgeons) to utilize IN-network providers, vendors, facilities, etc.nnOne Example: For years, it has become common place for Out Of Network (OON) surgical assists (many of whom are SA’s or C-SA’s) to get a hold of the surgeons bill for a surgical case and send out claims for 100% of the surgeon’s fee (the total fee prior to any contractual discount or even multiple procedure discounting) on the cases where they participate as first or even second assist. Some states have laws that force the health plan to hold the patient harmless to bills if the surgeon and the facility (or some combination) is IN-Network. The SA’s and some “creative” billing services are capitalizing on this loop hole to send in OON bills at 100% of charges. In many cases they actually get paid these amounts. Making it more profitable to be the SA than the actual surgeon! Imagine having virtually no-risk, no overhead, no staff to pay. You just show up for the case and get up to 5 -10 times what the actual surgeons gets for the case!nnWell, as we have always suspected, the health plans are finally saying NO MORE. In addition, many patients are not aware that there is an OON provider taking part in their case until they (the patient) gets a surprise, a huge bill – if even just the OON Co-Pay from someone they don’t know, never met, didn’t know was going to be in the case. The other un-intended consequence is that the total cost of a case (something that one surgeon is measured against others by) has astronomically gone up due to this practice. The surgeon, who is IN-Network gets a black mark because the overall cost of his/her cases is affected by the charges and network status of everyone involved.nnSome health plans are filing suit, others are forcing their In-Network surgeons (in the case of the OON SA assists) to make their patients aware of the use of an OON provider. We recently have seen United institute this for the use of OON facilities.