Manage My Practice

In the MLN Matters dated July 30, 2010, Change Request (CR) 7080, CMS gives additional instructions on the timely filing rule*:

• For institutional claims that include span dates of service (i.e., a “From” and “Through” date span on the claim), the “Through” date on the claim will be used to determine the date of service for claims filing timeliness.

• For professional claims (CMS-1500 Form and 837P) submitted by physicians and other suppliers that include span dates of service, the line item“From” date will be used to determine the date of service and filing timeliness. (This includes supplies and rental items).  For physicians and other suppliers that bill claims with span dates, these span date services cannot exceed one month.

• BE AWARE: If a line item “From” date is not timely, but the “To” date is timely, Medicare contractors will split the line item and deny untimely services as not timely filed.

• Claims having a date of service of February 29th must be filed by February 28th of the following year to be considered as timely filed. If the date of service is February 29th of any year and is received on or after March 1st of the following year, the claim will be denied as having failed to meet the timely filing requirement.

*Change request (CR) 6960 specified the basic timely filing standards established for FFS reimbursement, which are a result of Section 6404 of the Patient Protection and Affordable Care Act of 2010 (ACA) that states that claims with dates of service on or after January 1, 2010, received later than one calendar year beyond the date of service will be denied by Medicare.

Here’s your pop quiz:

The NCCI edits are:

A.  pairs of services that should not be billed by the same physician for the same patient on the same day.

B.  definition refinements for HCPCS codes.

C.  diagnosis codes (ICD-9) that cannot be billed together on a CMS 1500 claim.

The answer is below the picture.

If you answered “A”, you’re on top of your game!  The King of the National Correct Coding Initiative (NCCI) quarterly analysis is Mr. Frank Cohen and he provides that analysis free of charge for all.  Thank you, Frank!  With his analysis, you have the opportunity to see what’s changed and what’s new, to tweak your system to catch the pairs, and to make sure you are providing the right care at the right time as well as maximizing your reimbursement.

The Cohen Report:

In summary, there are 16,843 new edit pairs, bringing the total number of active edit pairs to 653,718. Six of these are backdated to an effective date of January 1, 2010. The majority of these (75.17%)  are associated to the edit policy “Misuse of column two code with column one code” with 12.82% associated to “Standard preparation / monitoring services for anesthesia”. There are 6,042 unique Column 1 codes and 274 unique Column 2 Codes within the new edits.

I have posted my analysis worksheets for those interested in the details. Go to www.frankcohen.com and click on the Download tab.

Many practices and providers take their patient schedule for granted.  They overlook the opportunity to improve both productivity and effectiveness by managing their schedule. Here are ten tips for office managers to make sure that the patient schedule works for you and for your practice.

1.    Evaluate the schedule template with the providers and nurse manager quarterly.

By using actual issues from the previous period, discuss what has worked and what has not.   Have providers share their concerns and

discuss their recommendations for change.   Nursing often has many ideas to improve the flow of patients through the practice and is a valuable source of information.  Keep track of changes made and evaluate their effectiveness at the following meeting.

2.    Standardize visits types.

There are many reasons an individual provider likes their “own” schedule. As managers, we know that this makes it very difficult for the front desk staff to do their jobs.  Standardization reduces the potential for errors and disruption that proprietary schedules may cause.  Your role in the discussion with providers will be that of facilitator, staff advocate, and coach.

Bring forward options for standardized visit types.  Many practices use a block template based on 10, 15 or 20-minute blocks of time.  The number of blocks used per visit type are agreed to and used to fill the schedule.  There may be additional restrictions placed on the schedule such as no more than one new patient per half-day session.  Minimize the number of restrictions or ideally eliminate them to assure your days are as flexible as possible to meet your patient needs.  You may also want to consider open access scheduling.  Moving to this system often takes time and effort to eliminate the backlog of booked patients but once fully in place can be very successful.

3.    Track scheduling errors and issues perceived to be scheduling errors monthly.

Errors in scheduling cause patient dissatisfaction, back up your waiting room, and lead to stress and possibly short tempers.   Ask providers and staff to tell you when they think patients are scheduled incorrectly.  Track this over time to determine if changes in the system are needed, how visit type use can be improved, and what training may be needed.

4.     Know where scheduling bottlenecks are.

What is your average wait time in the office per provider?  Do a time study on each provider and measure how long it actually takes for a patient to get through an office visit.  Note the time they arrive for check in and registration functions, their time in the waiting room, when the nurse completes check in functions in the exam room, when the provider enters the exam room, when the provider leaves the exam room and when the patient exits the office.   Overlay this on your schedule.  The information you gather will help you identify bottlenecks and provide meaningful data to share with your providers when recommending a change in the schedule template.

5.     Know how much a visit is worth in revenue.

Adding one visit per day by addressing schedule gaps, clinical start times, no-show appointments or changing the length of visits will increase your revenue.  If your provider works four days per week and 48 weeks per year at an average visit reimbursement of $75, one additional visit per day will add $14,400 in annual revenue to the bottom line!

6.    Train your scheduling staff and update the training regularly.

Training a new staff member often brings up questions the entire staff can benefit from.  Be sure to keep track of questions and include answers in future written training materials as well as in staff meeting discussions.  Develop a training checklist for scheduling staff and have both the trainer and new employee initial when each area is mastered.  This checklist can also be used for annual performance reviews.   For current staff, take a look at their computer terminals and see what “sticky notes” are posted there, indicating areas that need special consideration or additional training.

7.    Have the schedule be a frequent agenda item for staff meetings.

Get the staff perspective on what is working and what is not on a regular basis.  You may find that nursing can provide a great deal of information on how the schedule impacts patient flow from their perspective. Take time for staff to discuss “what if” scenarios and how they would handle a particularly difficult situation.  The goal is to have a schedule that staff understands, is user friendly and is consistently used.

8.    Have a policy on the number of providers out at one time for vacation or holidays and follow it.

Everyone deserves time off but having many providers out at once can lead to a very hectic week for those remaining.  Plan as much in advance as possible for time away.  If you do end up with a number of providers out at once, remember that the person remaining will also be responsible for reviewing lab and radiology results for their colleagues as well as answering questions regarding patients that they may not know.  Allow extra time in the schedule for this.

9.    Know what changes in demand to expect during the year and plan for it.

Do you have more requests for acute visits in January, camp physicals in April, or school sports physicals in August?  Minimize last minute adjustments to your schedule by knowing any seasonal trends in scheduling.  Take a look at the schedules from past years to predict when you need more or less acute slots and adjust your schedule template for this. Manage the time you’ve allotted by marketing efforts in the office and local papers reminding your patients to schedule in advance.

You may also want to consider adding additional clinical hours during this time to make sure you can meet demand.  Consider asking part time providers for extra hours per week or using per diem staff.

10.    Deal with your patient no-shows.

Consider writing a policy on no-shows if you do not have one.  If you have one, follow it.  Make sure that your policy follows any state regulations to avoid patient abandonment claims.

Educate your patients.  Develop a set of professional communications about your visit cancellation and no-show policy that begin with your welcome to the practice letter.  Post a notice of your policy in your waiting room.  Send letters following each no-show and then the termination letter stating the reason for the termination and that the patient is still responsible for their account balance.   Be the contact person on the letter so that if the patient calls with questions, they speak with you rather than take up provider time or that of your staff.

If you have a patient that consistently no-shows but the providers do not want to terminate them from the practice, determine what other help you can provide to get the patient to the visit on time.  Consider additional reminder calls, assistance with other services such as transportation, or offering the ability to come in and wait without a scheduled time.   Though this may take more staff time, the revenue from the appointment should make it worth your while.

Donna Izor, MS, FACMPE is founder of West Pinnacle Consulting, LLC. Her 20 years of experience as a medical practice executive lends her special expertise in the areas of primary care and specialty practices, employed inpatient physicians, regulatory oversight, facility design, physician compensation and relations, and new program development. She has worked with academic, community hospital, and private practices.  You can contact Donna at donna.izor@gmail.com.

Many managers have told me they know their providers are in PECOS but they’re not on the list OR they never enrolled their providers but they are on the list OR they’ve sent their paperwork and have not heard back for 2, 4, 6 weeks – should they be worried?  The CMS website says “It is possible that it could take 45-60 days, sometimes longer, for Medicare enrollment contractors to process enrollment applications,” so I guess we all need to chill out a little.

The massive undertaking of qualifying every single healthcare professional who refers/orders or provides medical services to Medicare patients in order to sift out those who would lie about providing goods and services is fraught with confusion, miscommunication and misunderstanding.  That’s okay, though, because CMS says no checks for services or goods will be withheld due to providers not being listed in PECOS, at this time. They know it’s a mess and it will take quite a while to get everyone straightened out, on the list and able to get checks from CMS if and only if their name is on the list.  We still have until January 3, 2011.

Below is the CMS fact sheet published last week.

Medicare Enrollment Guidance for Physicians that Infrequently Receive Reimbursement from the Medicare Program

Traditionally, most physicians have enrolled in the Medicare program to furnish covered services to Medicare beneficiaries.  However, with the implementation of Section 6405 of the Affordable Care Act, some physicians will need to enroll in the Medicare program for the sole purpose of certifying or ordering services for Medicare beneficiaries. These physicians do not send claims to a Medicare contractor for the services they furnish.

In the process of implementing the provisions contained in the Affordable Care Act, we have become aware of several unique enrollment issues for certain types of physicians or practitioners. Specifically, we have modified the process of enrollment to accommodate the special circumstances of the following individual physicians and practitioners:

• Physicians employed by the Department of Veterans Affairs
• Physicians employed by the Public Health Service
• Physicians employed by the Department of Defense Tricare program
• Physicians employed by Federally Qualified Health Centers (FQHCs), Rural Health Clinics (RHCs) or Critical Access Hospitals (CAHs)
• Physicians in a Fellowship
• Dentists, including oral surgeons

This document provides guidance to those practitioners.

Q: How can I verify whether I am already enrolled in PECOS?

A: If a physician is concerned or uncertain about whether s/he is actually enrolled in the Provider Enrollment, Chain and Ownership System (PECOS), s/he can  review the Ordering and Referring file found in the download section of the “OrderingReferringReport” tab (click here) on the Medicare Provider and Supplier Web Site.

Providers and suppliers can check with the ordering or referring physician to see if the physician is currently seeing Medicare patients and the physician’s claims are being paid. Until we advise otherwise, your orders and referrals will not be rejected due to the lack of an approved enrollment record in PECOS.

Q: I am a physician employed by the Department of Veterans Affairs, Department of Defense Tricare program, by the Public Health Service, an FQHC, an RHC, or a CAH.  Do I need to enroll in PECOS to order and refer items or services for Medicare beneficiaries?

A: Yes, but we have abbreviated the enrollment process and documents for physicians employed by the Department of Veterans Affairs, the Public Health Service, the Department of Defense Tricare program, an FQHC, an RHC, or a CAH. However, because this is a unique solution to enrollment for a specific set of physicians, our systems will not accommodate the abbreviated forms on-line. Therefore, any physician employed by the Department of Veterans Affairs, the Public Health Service, the Department of Defense Tricare program, an FQHC, an RHC, or a CAH, who is not already enrolled in PECOS, must use the paper enrollment application process
and do the following:

Complete the following sections of the paper CMS-855I, “Medicare Enrollment Application for Physicians and Non-Physician Practitioners” and mail the completed form to the designated Medicare enrollment contractor:

• Section 1 – Basic Information (they would be a new enrollee)
• Section 2 – Identifying Information (section 2A, 2B, 2D and if appropriate 2H and 2K)
• Section 3 – Final Adverse Actions/Convictions
• Section 4C/4E – Practice Location Information (same as section 2B)
• Section 13 – Contact Person
• Section 15 – Certification Statement (must be signed and dated—blue ink recommended)
• Section 17 – Supporting Documentation (cover letter stating the provider is only enrolling to order and refer services to a beneficiary)

Note: Physicians who are employed by the Department of Veterans Affairs, the Public
Health Service, the Department of Defense Tricare program, an RHC, FQHC, or CAH
are not required to include the Electronic Funds Authorization Agreement (CMS-588)
or the Medicare Physician and Supplier Agreement (CMS-460) with the enrollment
form.

Q: I am a  physician in a fellowship program.  Do I need to enroll in PECOS?

A: If you are a physician in a fellowship, and licensed in the State, you can enroll in Medicare for the sole purpose of ordering or referring items or services for Medicare beneficiaries. To enroll as a “referring and ordering physician-only” you would need to complete the abbreviated enrollment application form in the same way as other physicians (VA, DoD, PHS, FQHC, RHC CAH) who are enrolling to order and refer only (see previous question.) If you elect to enroll to order and refer only, you would not be enrolled in Medicare for the purpose of providing Medicare services to Medicare beneficiaries. In order to provide covered services to Medicare beneficiaries, a physician would need to complete the full enrollment application either on-line or in hard copy.

Q: I am an Oral Surgeon or Dentist – How do I Enroll in PECOS?

A: Dentists, including oral surgeons, must enroll in the Medicare program to receive reimbursement for services furnished to Medicare beneficiaries or to order covered items or services for Medicare beneficiaries. Oral surgeons would complete the same paper forms, or on-line application, as any other practitioner enrolling in PECOS.
If you elect to enroll as a “referring and ordering physician-only”, you would need to complete the abbreviated enrollment application form in the same way as other physicians (VA, DoD, PHS, FQHC, RHC CAH) who are enrolling to order and refer only (see previous two questions.)  If you elect to enroll to order and refer only, you would not be enrolled in Medicare for the purpose of providing Medicare services to Medicare beneficiaries.

In order to provide covered services to Medicare beneficiaries, a dentist, including oral surgeons, would need to complete the full enrollment application either on-line or in hard copy.

Note:  In completing the enrollment application portion dealing with specialty, oral surgeons would check the “oral surgery (dentist only)” box found in section 2 of the Medicare enrollment application and any other dentist would check the box titled, “Undefined Physician Type” and specify that they are a dentist in the space provided.  In the near future, we will revise the Medicare enrollment application to add “Dentist” as a physician specialty.

Internet-based PECOS

Physicians and practitioners who are employed by the Department of Veterans Affairs, the Defense Department, the Public Health Service, an RHC, FQHC, or CAH must complete the paper enrollment application that has been modified and shortened to accommodate the special situation of these professionals. All other physicians and practitioners who furnish services to Medicare beneficiaries must enroll in the Medicare program to receive reimbursement and order/refer in the Medicare program.  For those physicians and practitioners using the on-line process, we have developed a document that will help you through the PECOS enrollment process.   It will be easier to complete the process if you review this document before you begin the enrollment process.

• The document titled, “Internet-based PECOS — Getting Started Guide for Physicians and Non-Physician Practitioners” can be found here.

• Although you are permitted to complete your enrollment application in hard copy, it will be easier and quicker if you use the Internet-based Provider Enrollment, Chain and Ownership System (PECOS) to complete the Medicare enrollment process.  The Internet-based PECOS application is completed via the web here.
• After submitting an enrollment application via Internet-based PECOS, you must:
  • Print, sign and date (blue ink recommend) the Certification Statement(s), and
  • Mail the Certification Statement(s) and applicable supporting documentation to the designated Medicare contractor (no later than 7 days after you complete the online portion.)
  • NOTE: The Medicare contractor will not be able to begin to process your enrollment application until it receives a signed and dated Certification Statement.

Additional Medicare Enrollment Information

To ask a provider enrollment question, contact the Medicare contractor for your State. Medicare provider enrollment contact information for each State can be found here.

To report Internet-based PECOS navigation, access, or printing problem with Internet-based PECOS, contact the EUS Help Desk at 1-866-484-8049 or send an e-mail to the EUS Help Desk to EUSSupport@cgi.com

For additional information regarding the Medicare enrollment process, visit the website here. Of course, if you have any additional questions about the Medicare enrollment process, you can contact the designated Medicare contractor for your state.

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If you haven’t started yet but plan to use the online process to enroll your providers or yourself, here’s a really excellent SlideShare presentation by David Zetter that steps you through the enrollment process by showing screen shots of each step.  You can contact David Zetter here.

I was fortunate enough to be listening by phone to the historic (yes, historic) announcement of the final meaningful use rules by Kathleen Sebelius, Secretary HHS; Don Berwick, MD, new CMS Administrator; David Blumenthal, MD, national coordinator for health information technology at HHS; Regina Benjamin, MD, Surgeon General and a surprise speaker, Regina Holliday, artist and activist for patient rights.

The memorable quotes I wrote down were:

Kathleen Sebelius: “When electronic health records are well-designed and implemented correctly, they can be a powerful force for reducing errors, lowering costs, raising quality of care, and increasing doctor and patient satisfaction.” That is the best one-sentence description of “Why EHR?” I’ve ever heard.

Don Berwick: “If it’s (EHR) so good, why doesn’t everyone use it? Because it’s HARD.” There is a little slice of honesty that you won’t get from most EHR vendors.

David Blumenthal: “We are only as good in treating patients as the information we have.” Wow, an admission that could rock the medical world if we stopped and thought about it.

Regina Holliday: “I will not stop until we all have the right see our own information.” Regina’s Medical Advocacy Blog is here. Her lauded mural “73 Cents” refers to how much per page she was told by the hospital medical records department she would have to pay to get a copy of her husband’s records while he was still in that hospital.

The Meat: Specifics of Stage 1 Meaningful Use (2011 and 2012)

Meaningful use includes both a core set and a menu set of objectives that are specific for eligible professionals and hospitals.

For Eligible Professionals (definition here), there are a total of 25 available meaningful use objectives. 20 of the objectives must be completed to qualify for an incentive payment. 15 are core objectives that are required, and the remaining 5 objectives may be chosen from the list of 10 menu set objectives.

For Hospitals, there are a total of 24 available meaningful use objectives. 14 are core objectives that are required, and the remaining 5 objectives may be chosen from the list of 10 menu set objectives.

Stage 1 (2011 – 2012) sets the baseline for electronic data capture and information sharing.

Stage 2 (est. 2013) and Stage 3 (est. 2015) will continue to expand on this baseline and be developed through future rule making.

As I am sure you expect, there will be much more information to come.

U.S. Department of Health and Human Services

Watch the webcast live here.

Note: I am republishing this to my email subscribers because none of the links worked the first time around. I’ve fixed everything now – so sorry for the error – must have been healthcare fatigue!

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I’ve noticed that a lot of people in healthcare seem unusually tired and even, if I dare say so, somewhat cranky.  This includes me.  I’ve decided we’re all suffering from healthcare fatigue – fatigue from dealing on a daily basis with so much change, uncertainty, and financial stress.  Here’s my top ten list of healthcare management stressors accompanied by posts I’ve written that discuss the topic or suggest resources for the challenge.

10. Red Flags Rules – on again, off again, patients don’t want to have their pictures taken or let you copy their driver’s licenses.

• Red Flags Rules (RFR) Delayed for the Fifth Time – This Time Until December 31, 2010
• Red Flags Rule and Identity Theft Prevention: You Don’t Have To, But You Should!

9. HIPAA - don’t be fooled, HIPAA is not something we handled years ago and it’s taken care of; there are new requirements and penalties associated with HIPAA breaches.  HIPAA is a biggie and something that now infiltrates almost every facet of healthcare.

• ARRA Changes Rules for HIPAA – Did You Miss These Three February Deadlines?

8.  Employment Uncertainty – both for you and your staff – the aftermath of layoffs can be even more demoralizing to those who didn’t lose their jobs.  Also, many healthcare entities are still freezing raises.  If I hear one more time “we’ll just have to do more with less” I might just scream.

• My Take on “10 Ways to Keep Employees Happy” in Medical Practices
• Dear Mary Pat: Should Staff Be Allowed to Use The Internet on Their Smart Phones at Work?

7. Unrealistic Workloads – directly related to #9, most staff and managers have much more work to do than they did just two years ago. Couple that with the ability for managers to be available and work by computer, phone, text message, email or Skype 24/7 and you have fatique that you understand only when you truly, truly stop and wind down for more than three days at a time.

• Long Vacations are Good for Employees, the Company and Me!

6.  Hospitals Buying Practices – this could be a good thing or a bad thing, but as you and I know, change is completely unnerving to most people.  Hospitals have very different cultures than private practices and trying to marry the two takes skill, patience and excellent leadership.

• Change in the Group Medical Practice: Customers, Consequences, Control, and Culture

5.  Stimulus Money for Using EMRs – it’s a big decision and many practices are very nervous about purchasing an EMR.  Many think that meaningful use components are unrealistic and even more are fearful of the inevitable productivity drop when the EMR is implemented and for months afterwards.

• ARRA Eligible Providers: Who Is Eligible to Receive Stimulus Money and How Much is Available Per Provider?
• FAQ on HITECH, Meaningful Use, Eligible Providers, and the Stimulus Money
• Ten Reasons Why (Some) Physicians Aren’t Rushing to Adopt EMRs
• Electronic Medical Record Guru Rosemarie Nelson Reveals Best EMR Product on the Market Today

4. Unhappy Patients – lots of patients are also trying to do more with less (argghhh!) and are avoiding coming to the doctor whenever possible.  The front desk staff and the phone staff in particular are getting a lot more heat when they inform patients they’ll have to make an appointment.

• 50 Customer Service Ideas to Treat Your Patients to Friendly, Easy and Unexpected Service
• How To Be A Billing Advocate for Your Patients
• How to Apologize to a Patient
• A Memo to the Staff: The Preciousness of Patients

3.  PECOS – be glad if you don’t know what PECOS stands for, or be very, very afraid.

• Providers Without a PECOS Record Will Receive a Letter From Their Medicare Administrative Contractor (MAC)
• My Notes from the CMS Open Door Forum on May 19, 2010: PECOS, DMEPOS and Blue Ink on Paper Forms
• Is Your Practice Ready for the 60-Day PECOS Countdown?

2. Medicare Reimbursement – this year has been as exhausting as watching a single point of ping pong played for hours – there will be cuts, there won’t be cuts, there will be cuts, there won’t be cuts.  Gird your loins as the November 30 deadline looms for the next potential cuts.

• Deja Vu All Over Again: The Medicare Fee Cut is Pushed Back to November 30, 2010
• Attention Medical Practice Staff: Medicare Changes the Rules for Credentialing and Retro-Billing
• 91 Physician Organizations Sign Statement Naming Congress in “Mismanagement of the Medicare Program” and Imploring it to “Honor its Obligation”

1. The Bottom Line – we have RAC audits, more pre-certification and pre-authorization and pre-notification requirements, more denials, high deductible plans, formularies and 50 other things that are making it difficult to know which hoop to jump through to get paid.  Expenses continue to go up, reimbursement continues to go down, and the healthcare world spins faster and harder, making us all wonder when it will, or if it ever will slow down.

• There is No Such Thing as a 10-Minute Office Visit
• The ABN: The Most Misunderstood and Underutilized Document in Healthcare
• 101 Ideas for Increasing Revenue and Decreasing Expenses in Your Medical Practice
• How to Develop a New Financial Policy For Your Practice: A Short Course

Medicare Learning Network (MLN) just released MM6912, effective August 2, 2010: Mailing To All Individual Practitioners, Medical Groups and Clinics and Independent Diagnostic Testing Facilities (IDTF) Who Are Billing or Have Billed For The Technical Component of Advanced Diagnostic Imaging Services

What exactly is an IDTF?

Some suppliers that perform diagnostic tests, other than clinical laboratory or pathology tests, are required to enroll with Medicare as an Independent Diagnostic Testing Facility (IDTF). Not all suppliers that perform these diagnostic tests are required to enroll as an IDTF.  Generally, entities can bill for the technical component of the diagnostic tests without an IDTF enrollment if it has the following characteristics:

• A physician practice that is owned, directly or indirectly, by one or more physicians or by a hospital
• A facility that primarily bills for physician services and not for diagnostic tests
• A facility that furnishes diagnostic tests primarily to patients whose medical conditions are being treated or managed on an ongoing basis by one or more physicians in the practice
• The diagnostic tests are performed and interpreted at the same location where the practice physicians also treat patients for their medical conditions
• If a substantial portion of the facility’s business involves the performance of diagnostic tests, the diagnostic testing services may be a sufficient separate business to require enrollment as an IDTF. In that case, the physician or physician group practice can continue to be enrolled as a physician or physician group practice but are also required to enroll as an IDTF. The physician or group can bill for professional fees and the diagnostic tests they perform on their patients using their billing number. Therefore, the practice must bill as an IDTF for diagnostic tests furnished to Medicare beneficiaries who are not regular patients of the physician or group practice.

Who will receive a mailing?

Enrolled physicians, non-physician practitioners, including single and multi- specialty clinics, and IDTFs who have billed the Medicare program for the technical component of advanced diagnostic testing services within the preceding six month period and who continue to have Medicare billing privileges with Medicare contractors (carriers and Part A/B Medicare Administrative Contractors (A/B MACs)) are affected.

If you have billed the Medicare program for the technical component of advanced diagnostic testing services within the preceding six month period and continue to have Medicare billing privileges with Medicare contractors, you will receive a letter from your Medicare contractor advising you of the need to become accredited by January 1, 2012, in order to continue to provide these services and bill Medicare.

When more than one physician or non-physician practitioner is operating within a group, such as a single specialty or multispecialty clinic, only the group will receive the letter, not each of the individual physicians or non-physician practitioners working for the group.

What will the mailing say?

You must be accredited by one of the three Centers for Medicare & Medicaid
Services (CMS) approved national accreditation organizations by January 1, 2012,
in order to be eligible to continue to furnish the technical component of advanced
diagnostic testing services to Medicare beneficiaries and submit claims for those
services to your Medicare contractor.

Your contractor will be mailing the letter quarterly beginning with July 2010 through July 2011. If necessary, follow the instructions in the letter to become accredited by January 1, 2012, in order to continue billing for the technical component of advance diagnostic imaging services. Make sure that your office staffs are aware of these new accreditation requirements and begin the accreditation process as soon as possible to protect your Medicare billing rights for these services.

Why do IDTFs have to become accredited now?

Section 135(a) of the Medicare Improvements for Patients and Providers Act of
2008 (MIPPA) amended section 1834(e) of the Social Security Act and required
the Secretary, Health and Human Services, to designate organizations to accredit
suppliers, including but not limited to physicians, non-physician practitioners and
Independent Diagnostic Testing Facilities, that furnish the technical component
(TC) of advanced diagnostic imaging services.

What qualifies as an advanced diagnostic imaging procedure?

MIPPA specifically defines advanced diagnostic imaging procedures as including:
• Diagnostic magnetic resonance imaging (MRI),
• Computed tomography (CT), and
• Nuclear medicine imaging, such as positron emission tomography (PET).

MIPPA expressly excludes from the accreditation requirement x-ray, ultrasound,
and fluoroscopy procedures. The law also excludes from the CMS accreditation
requirement diagnostic and screening mammography, which are subject to quality oversight by the Food and Drug Administration under the Mammography Quality Standards Act.

How long does it take to become accredited?

Since CMS expects that it may take as much as nine months from the time you initiate the accreditation process to completion, you should begin the accreditation process for advanced diagnostic imaging services as soon as possible, but not later than March 2011.

Who are the accrediting organizations?

CMS approved three national accreditation organizations — the American College
of Radiology, the Intersocietal Accreditation Commission, and The Joint
Commission — to provide accreditation services for suppliers of the TC of advanced diagnostic imaging procedures. The accreditation will apply only to
the suppliers of the images themselves, and not to the physician interpreting
the image. All accreditation organizations have quality standards that address the safety of the equipment as well as the safety of the patients and staff.

If you have questions, contact your Medicare carrier and/or A/B MAC at
their toll-free number, which may be found here (zip file.)

Image via Wikipedia

The letter will look like this:

[DATE]

[Supplier Name and Address]

Dear Physician/Non-Physician Practitioner/IDTF owner:

In accordance with Section 135(a) of the Medicare Improvements for Patients and Providers Act of 2008 (MIPPA), suppliers, including but not limited to physicians, non-physician practitioners and Independent Diagnostic Testing Facilities that furnish the technical component (TC) of advanced diagnostic imaging services must be accredited by January 1, 2012 in order to continue to furnish these services to Medicare beneficiaries.

Our records indicate that you have furnished advanced diagnostic imaging procedures such as diagnostic magnetic resonance imaging (MRI), computed tomography (CT), and nuclear medicine imaging such as positron emission tomography (PET) within the last six months.  If you are not accredited by one of the organizations shown below by January 1, 2012, you will not be eligible to bill the Medicare program for advanced diagnostic imaging services.  This letter requests that you take the necessary action to become accredited by the January 1, 2012 deadline.  Since we expect it can take up to nine months from the time you initiate the accreditation process to completion, we urge you to begin the accreditation process for advanced diagnostic imaging services as soon as possible.

MIPPA expressly excludes from the accreditation requirement x-ray, ultrasound, and fluoroscopy procedures.  The law also excludes from the CMS accreditation requirement diagnostic and screening mammography which are already subject to quality oversight by the Food and Drug Administration under the Mammography Quality Standards Act.

The Centers for Medicare & Medicaid Services (CMS) approved three national accreditation organizations – the American College of Radiology, the Intersocietal Accreditation Commission, and The Joint Commission – to provide accreditation services for suppliers of the TC of advanced diagnostic imaging procedures.  The accreditation will apply only to the suppliers of the images themselves, and not to the physician interpreting the image.  All accreditation organizations have quality standards that address the safety of the equipment as well as the safety of the patients and staff.  The accrediting organization that issues your accreditation will notify Medicare once your accreditation is complete and approved.

To obtain additional information about the accreditation process, please contact the accreditation organizations shown below.

American College of Radiology (ACR)
1891 Preston White Drive
Reston, VA 20191-4326
1-800-770-0145

Intersocietal Accreditation Commission (IAC)
6021 University Boulevard, Suite 500
Ellicott City, MD 21043
1-800-838-2110

The Joint Commission (TJC)
Ambulatory Care Accreditation Program
One Renaissance Boulevard
Oakbrook Terrace, IL 60181
1-630-792-5286

If you have questions about this letter, contact [carrier or A/B MAC phone number/contact person].

Sincerely,

[Name of carrier or A/B MAC]

******************************************************************

Supplier Billed Advanced Medical Imaging CPT codes for Section 135 (a) of the MIPPA to Receive Accreditation Requirement Notification Letter

70336  70540  71250  72125  73200  74150
70450  70542  71260  72126  73201  74160
70460  70543  71270  72127  73202  74170
70470  70544  71275  72128  73206  74175
70480  70545  71550  72129  73218  74181
70481  70546  71551  72130  73219  74182
70482  70547  71552  72131  73220  74183
70486  70548  71555  72132  73221  74185
70487  70549    72133  73222
70488  70551    72141  73223
70490  70552    72142  73225
70491  70553    72146  73700
70492  70554    72147  73701
70496  70555    72148  73702
70498  70557    72149  73706

70558    72156  73718

70559    72157  7371972158  73720
72159  73721
72191  73722
72192  73723
72193  73725
72194
72195
72196
72197
72198
72200
75557  76360  77011  78000  78811
75559  76376  77012  78001  78812
75561  76377  77021  78003  78813
75563  76380  77058  78006  78814
76390  77059  78007  78815
76497  77078  78010  78816
76498  77079  78011  78891
78015
78016
78018
78020
78070
78075
78099

Report by Frank Cohen
Frank Cohen, MPA, MBB
The Frank Cohen Group, LLC

As many of you may already know, July 1, 2010 CMS released yet another RBRVS (Resource Based Relative Value Scale) data set that will be used to pay physicians under Medicare effective June 1, 2010. This data set includes the 2.2% increase in the CF. This puts the current conversion factor at $36.8729.

The link to the CMS file is here.

The good news is that the Conversion Factor (CF) increased by 2.2%.

The bad news is that for 2,226 procedure code/modifier groups within the database, the RVU (Relative Value Unit) values decreased by anywhere from 0.65% to 50% (or 0.01 to 2.04 RVUs). The median change was only 0.12 RVUs, which in and of itself doesn’t seem like much, but if you add them up, you get a total reduction of 492.95 RVUs for just these procedure codes.

This doesn’t consider frequency of use. For example, procedure code 75825 26 saw a reduction in RVUs of 1.16. In 2008, this procedure was reported to Medicare 60,864 times. That results in a net decrease in RVUs to those practices of 70,602 RVUs. At the current conversion factor, that is a payment reduction of $2.6 million.

In addition to the RVU changes, there were 180 non-RVU changes, including changes to the PC/TC (Professional Component/Technical Component) policies, new records, modified status, etc.

Note: Frank ran a side-by-side analysis of the changes for these procedure codes. If you would like a copy of his worksheet, go to his site and click on the Download tab. Even if you don’t want this file, he has lots of other goodies on his site for free.  As always, thanks Frank!

email Frank

visit Frank’s site