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CMS Seeks Comments on Changes to E/M Documentation Guidelines

Source: Emily Hill, PA, AAPM Coding Consultant
Date: April 4, 2018

In the November 2017 Final Rule, CMS sought comments on potential updates to the Evaluation and Management (E/M) Documentation Guidelines. CMS indicated it was particularly interested in suggestions for initial changes to the history and exam components. CMS further suggested that medical decision making (MDM) and time are more important factors in distinguishing levels of service.

On March 21, 2018, CMS held a public listening session titled E/M Services: Documentation Guidelines and Burden Reduction Listening Session. The purpose of the session was to receive feedback from users regarding the current guidelines and suggestions for potential revisions. More specifically, the session asked questions regarding:

  • Ways to reduce the burden associated with the documentation of patient E&M visits.
  • Ways for CMS to seek input on approaches that other payers take to both the payment and the documentation regarding E&M visits.
  • The role of each currently required item in the E&M visits, specifically the history, physical exam, and medical decision making.
  • Documentation through changes to the underlying E&M code set.
  • Information on duplicative data entry in the medical record.
  • Information about changes to the E&M visits that are specialty specific.

Click here to access links to the audio recording, presentation and transcript.

CMS Releases Tool to Check Your MIPS Eligibility

Source: Emily Hill, PA, AAPM Coding Consultant
Date: April 18, 2018

CMS has recently released its updated MIPS Eligibility Lookup Tool. Enter your NPI number to determine if you need to participate in the MIPS program in 2018. Providers who meet the established low volume threshold do not need to participate.

CMS revised the volume threshold in 2018 to exclude more providers from the requirement to participate. Providers and groups are excluded from MIPS if they:

  • Billed $90,000 or less in Medicare Part B allowed charges for covered professional services under the Physician Fee Schedule (PFS) OR
  • Furnished covered professional services under the PFS to 200 or fewer Medicare Part B-enrolled beneficiaries

MIPS (Merit-based Incentive Payment System) is a key part of the CMS Quality Payment Program (QPP). The QPP replaces the Sustainable Growth Rate (SGR) formula for maintaining budget neutrality and streamlines prior quality programs (Physician Quality Reporting System, Meaningful Use Criteria, and the Value Based Modifier) into a single program. The intent of the QPP is to shift reimbursement from the volume of services provided toward a payment system that rewards clinicians for providing high quality services along with cost savings.

Information on the Quality Payment Program and MIPS can be found at: qpp.cms.gov. The Eligibility Tool can be found at: qpp.cms.gov/participation-lookup.

New Medicare Beneficiary Identifiers (MBIs) Ready for Use

Source: Emily Hill, PA, AAPM Coding Consultant
Date: May 9, 2018

Some Medicare beneficiaries are receiving new Medicare cards with new Medicare Beneficiary Identifiers (MBIs). The MBIs are 11 characters in length and will use randomly selected numbers and upper case letters. The new cards and numbers are being issued in phases by geographic location. It is important to begin using the new MBIs for claims and other transactions once your patient receives the new Medicare card.

Medicare patients in the following locations will receive new cards beginning this month:

  • Delaware
  • District of Columbia
  • Maryland
  • Pennsylvania
  • Virginia
  • West Virginia
  • Alaska
  • American Samoa
  • California
  • Guam
  • Hawaii
  • Northern Mariana Islands
  • Oregon

CMS is encouraging practices to ask patients with Medicare for their new cards and to begin using the new number for all transactions. View the geographic phase-in schedule. All patients will receive new cards by April 2019.

No later than June 2018, CMS will have a Medicare Administrative Contractors’ secure MBI look-up tool so that practices can locate patients’ new MBIs. You can sign up for the portal to use the tool now.

Starting in October 2018 through the end of the transition period (April 1, 2018-December 31, 2019), Medicare will return the MBI on every remittance advice when you submit claims with valid and active HICNs (Health Insurance Claim Numbers).

What Is CDI and How Does It Impact You?

Source: Emily Hill, PA, AAPM Coding Consultant
Date: June 6, 2018

CDI (Clinical Documentation Improvement) has been described as the process of improving healthcare records to ensure improved patient outcomes, data quality, and accurate reimbursement. Hospitals began CDI programs as a response to the advent of DRGs (Diagnosis Related Groups) as a form of reimbursement. Most physicians have experienced the request for supplementary documentation to support additional or more specific ICD codes to enhance hospital reimbursement and data collection.

The ability to collect and track data has resulted in more robust and expanded CDI programs. Although CDI historically has been a hospital-based program, it is moving to physician practices as its importance is recognized. The impact of CDI today may be described as the completeness, consistency, organization and accuracy of the medical record, reflecting the physician’s clinical judgment and medical decision making. The overall goal of a CDI program is to improve clinical documentation, coding, and reimbursement.

From a reimbursement perspective, an effective CDI program can reduce denials and improve the appeals process using improved clinical documentation. Clinically, it results in a more useful medical record and more meaningful patient information and data.

Initiating a program in your practice requires thought and planning but it doesn’t have to be overwhelming. Over the next several months, we’ll focus on the steps of assessment, implementation and maintenance of an office-based CDI program. Improving documentation is inherently a good goal with down-stream benefits of improved reimbursement and an effective clinical record.

RUC Survey of CPT Codes for Injection of Somatic Nerves

Source: Emily Hill, PA, AAPM Coding Consultant
Date: June 20, 2018

Next week we will be contacting a random selection of members to participate in an important AMA/Specialty Society Relative Value Scale Update Committee (RUC) survey of physician work for several somatic and genicular nerve injection CPT codes. In the survey, you may be asked to provide information on several codes, two of which are new to CPT and six of which are established codes.

As you may know, the Medicare payment schedule is based on physician work, practice expense and professional liability insurance. Our society needs your help to assure relative values will be accurately and fairly presented to the Centers for Medicare and Medicaid. Your input in this survey is vital.

AAPM is conducting this survey for the RUC in partnership with several other medical specialties including the American Academy of Neurology, American Academy of Physical Medicine and Rehabilitation, American Society of Anesthesiologists and the Spine Intervention Society. If you are a member of one or more of these additional societies, you may see a survey request from them (rather than from AAPM). In such instance, we ask that you treat their request as similarly vital. We will compile all relevant survey data from the partnering societies for our presentation to the AMA RUC.

For more information on understanding the RUC Survey instrument, please view this youtube video…

If you have any questions, please contact Emily Hill, AAPM Coding and Reimbursement Liaison, at: [email protected]

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