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September Medicare Transmittals and Other Updates
Published on Sep 29, 2020
20200929

MEDICARE TRANSMITTALS – RECURRING UPDATES

 

October 2020 Update of the Hospital Outpatient Prospective Payment System (OPPS)

  • Article Release Date: August 31, 2020
  • What You Need to Know: This article informs providers about changes to and billing instructions for various payment policies implemented in the October 2020 OPPS update.
  • MLN MM11905: https://www.cms.gov/files/document/mm11905.pdf

October 2020 Integrated Outpatient Code Editor (I/OCE) Specifications Version 21.3

  • Article Release Date: August 28, 2020
  • What You Need to Know: This article provides information about the October 2020 version of the I/OCE instructions and specifications that Medicare uses.
  • MLN MM11944: https://www.cms.gov/files/document/mm11944.pdf

Annual Clotting Factor Furnishing fee Update 2021

2021 Annual Update for the Health Professional Shortage Area (HPSA) Bonus Payments

  • Article Release Date: August 28, 2020
  • What You Need to Know: Section 413(b) of the Medicare Prescription Drug, Improvement and Modernization Act of 2003 mandated an annual update to the automated HPSA bonus payment file. This article lets providers know that CMS will provide MACs with files for the automated payments of HPSA bonuses for dates of service January 1, 2021 through December 31, 2021.
  • MLN MM11852: https://www.cms.gov/files/document/mm11852.pdf

October Quarterly Update for the 2020 Durable Medical Equipment, Prosthetics, Orthotics and Supplies (DMEPOS) Fee Schedule

  • Article Release Date: August 28, 2020
  • What You Need to Know: This article provides details about the changes to the DMEPOS fee schedules that Medicare updates quarterly, when necessary, to implement fee schedule amounts for new and existing codes, as applicable, and apply changes in payment policies. Specific to the ongoing Public Health Emergency (PHE) due to the COVID-19 pandemic, “the October 2020 DMEPOS and PEN fee files continue to include the non-rural contiguous non-CBA 75/25 blended fees required by Section 3712(b) of the CARES Act signed into law on March 27, 2020.
  • MLN MM11956: https://www.cms.gov/files/document/mm11956.pdf

Implement Operating Rules - Phase III Electronic Remittance Advice (ERA) Electronic Funds Transfer (EFT): Committee on Operating Rules for Information Exchange (CORE) 360 Uniform Use of Claim Adjustment Reason Codes (CARC), Remittance Advice Remark Codes (RARC) and Claim Adjustment Group Code (CAGC) Rule - Update from Council for Affordable Quality Healthcare (CAQH) CORE

  • Article Release Date: August 28, 2020
  • What You Need to Know: This article informs providers that Medicare will update its claims processing systems based on the Committee on Operating Rules for Information Exchange (CORE), Code Combination List, which will be published on or about October 1, 2020.
  • MLN Matters MM11881: https://www.cms.gov/files/document/mm11881.pdf

Update to Hospice Payment Rates, Hospice Cap, Hospice Wage Index and Hospice PRICER for FY 2021

  • Article Release Date: August 31, 2020 – Revised September 10, 2020
  • What You Need to Know: This article provides updates in Change Request (CR) 11876 to hospice payment rates, wage index, PRICER, and aggregate cap amounts for Fiscal Year (FY) 2021. Note, this article was revised on September 10th to correct two typos. All other information remained the same.
  • MLN Matters MM11876: https://www.cms.gov/files/document/mm11876.pdf

Claim Status Category and Claim Status Codes Updates

  • Article Release Date: August 28, 2020
  • What You Need to Know: This article informs providers of updates to the Claim Status and Claims Status Category Codes used for the Accredited Standards Committee (ASC) X12 276/277 Health Care Claim Status Request and Response and ASC X12 277 Health Care Claim Acknowledgement transactions. Code changes during the September/October 2020 National Code Maintenance Committee (NCMC) meeting will be posted on or about November 1, 2020.
  • MLN Matters MM11796: https://www.cms.gov/files/document/mm11796.pdf

2021 Annual Update of Healthcare Common Procedure Coding System (HCPCS) Codes for Skilled Nursing facility (SNF) Consolidated Billing (CB) Update

  • Article Release Date: September 16, 2020
  • What You Need to Know: This articles provides information regarding changes to HCPCS codes and Medicare Physician Fee Schedule (MPFS) designations that Medicare uses to revise Common Working File (CWF) edits to allow MACs to make appropriate payments.
  • MLN Matters MM11968: https://www.cms.gov/files/document/mm11968.pdf

Fiscal Year (FY) Inpatient Prospective Payment System (IPPS) and Long-Term Care Hospital (LTCH) PPS Changes

Quarterly Update to the National Correct Coding Initiative (NCCI) Procedure-to-Procedure (PTP) Edits, Version 27.0, Effective January 1, 2021

  • Article Release Date: September 25, 2020
  • What You Need to Know: CR 11984 provides quarterly updates to the NCCI PTP edits. A test file will be available around November 2, 2020 with a final file available on or about November 17, 2020.
  • MLN MM11984: https://www.cms.gov/files/document/mm11984.pdf

 

OTHER MEDICARE TRANSMITTALS

 

Updates to Chapter 23 – Fee Schedule Administration and Coding Requirements

Internet Only Manual Update to Pub. 100-04, Chapter 16, Section 60.1.2 and Pub. 100-04, Chapter 26, Section 10.4, Item 19

  • Article Release Date: September 4, 2020
  • What You Need to Know: CMS has removed the reference to Electrocardiogram (EKG) services in the Medicare Claims Processing Manual, Chapter 16, Section 60.1.2 and Chapter 26, Section 10.4, Item 19. This change only clarifies existing content.
  • MLN Matters MM11935: https://www.cms.gov/files/document/mm11935.pdf

Update to the Medicare Claims Processing Manual

  • Article Release Date: September 18, 2020
  • What You Need to Know: This article provides information regarding updated to the Medicare Claims Processing Manual, Chapters 12 and 23.
  • MLN Matters MM111958: https://www.cms.gov/files/document/mm11958.pdf

 

REVISED MEDICARE TRANSMITTALS

 

National Coverage Determination (NCD 30.3.3): Acupuncture for Chronic Low back Pain (cLPB)

  • Article Release Date: May 13, 2020 – Revised September 1, 2020
  • What You Need to Know: This MLN article was revised to reflect an updated Change Request (CR) 11755 that provides revised messaging (page 3 in the article). It also revised the Claims Processing Manual at Section 410.4.
  • MLN Matters MM11755: https://www.cms.gov/files/document/MM11755.pdf

Update to the Model Admission Questions for Providers to Ask Medicare Beneficiaries

  • Article Release Date: September 4, 2020 – Revised September 15, 2020
  • What You Need to Know: This article provides information about CMS modifying and streamlining the model admission questions for providers to ask Medicare beneficiaries or authorized representatives upon admission or start of care.
  • Note, this article was revised on September 15th to reflect the CR revision adding part of sentence that had been left out of manual Section 20.2.2 of the Medicare Secondary Payer Manual.
  • MLN Matters MM11945: https://www.cms.gov/files/document/mm11945.pdf

October 2020 Update of the Ambulatory Surgical Center (ASC) Payment System

  • Article Release Date: September 11, 2020 – Revised September 24, 2020
  • What You Need to Know: This article is based on Change Request (CR) 11963 which provides information about changes to and billing instructions for various payment policies implemented in the October 2020 ASC payment system update.
  • Note, this article was revised to reflect the updated CR revision to HCPCS code C9066 in Table 2 in the CR.
  • MLN MM11963: https://www.cms.gov/files/document/mm11963.pdf

Quarterly Update for Clinical Laboratory Fee Schedule and Laboratory Services Subject to Reasonable Charge Payment

  • Article Release Date: August 7, 2020 – Latest Revision September 24, 2020
  • What You Need to Know: This article informs laboratories of changes from the quarterly update to the clinical laboratory fee schedule. Now in its third iteration, this article was most recently updated to add new COVID-19 code (86413) and ADLT code (0090U).
  • MLN MM11937: https://www.cms.gov/files/document/mm11937.pdf

Change to the Payment of Allogeneic Stem Cell Acquisition Services

  • Article Release Date: July 13, 2020 – Revised September 24, 2020
  • What You Need to Know: This article was revised to reflect a revised CR issued on September 24, 2020. All other information remains the same.
  • MLN MM11729: https://www.cms.gov/files/document/mm11729.pdf

October 2020 Update of the Hospital Outpatient Prospective Payment System (OPPS)

  • Article Release Date: August 31, 2020 – Revised September 25, 2020
  • What You Need to Know: This article has been revised to reflect an updated CR 11960 that made several changes including adding a new COVID-19 CPT code, 86413, to Table 1.
  • MLN MM11960: https://www.cms.gov/files/document/mm11960.pdf

 

MEDICARE COVERAGE UPDATES

 

National Coverage Determination (NCD 90.2): Next Generation Sequencing (NGS) for Medicare Beneficiaries with Germline (Inherited) Cancer

  • Article Release Date: September 15, 2020
  • What You Need to Know: CMS “has determined that NGS, as a diagnostic laboratory test, is reasonable and necessary and covered nationally for patients with germline (inherited) cancer when performed in a CLIA-certified laboratory, when ordered by a treating physician, and when specific requirements are met.
  • NCD Implementation Date: November 13, 2020
  • NCD Effective Date: January 27, 2020
  • MLN MM11837: https://www.cms.gov/files/document/mm11837.pdf

 

OTHER MEDICARE UPDATES

 

August 27, 2020: OIG Report – Medicare Contractors Were Not Consistent in How They Reviewed Extrapolated Overpayments in the Provider Appeals Process

Proposed Rule: Medicare Program; Modernizing and Clarifying the Physician Self-Referral Regulations Extension of Timeline for Publication of Final Rule

Link to notice in Federal Register: https://www.govinfo.gov/content/pkg/FR-2020-08-27/pdf/2020-18867.pdf

September 2, 2020: FY 2021 IPPS Final Rule released.

September 3, 2020: Medicare Preventive Services Tool and Poster Revised

CMS noted in their September 3rd edition of MLNConnects that the Medicare Preventive Services Medicare Learning Network Educational Tool and Poster have been revised. The tool is extremely useful to understand Coding, Coverage, and Copayment/coinsurance and deductible requirements for Preventative Services covered by Medicare.

September 10, 2020: OIG Report: Billions in Estimated Medicare Advantage Payments from Diagnoses Reported Only on Health Risk Assessments Raise Concerns

The OIG performed this review due to concerns that Medicare Advantage Organizations may use Health Risk Assessments (HRAs) to inappropriately increase risk adjusted payments. The key takeaway highlighted in the Report Brief is that “billions in estimated risk-adjusted payments supported solely through HRAs raise concerns about the completeness of payment data, validity of diagnoses on HRAs, and quality of care coordination for beneficiaries.”

September 11, 2020: Community Health Access and Rural Transformation (CHART) Model CMS Fact Sheet

CMS announced the CHART Model in a Fact Sheet, indicating that “the approximately 57 million Americans living in rural communities, including millions of Medicare and Medicaid beneficiaries, face unique challenges when seeking health care services, such as limited transportation options, shortages of health care services, and an inability to fully benefit from technological and care-delivery innovations.” CMS goes on to highlight the following three items to be accomplished through this model:

  • “Increase financial stability for rural health care providers through multiple new funding approaches, including the use of up-front investments and predictable, capitated payments that pay for quality and patient outcomes over volume;
  • Provide the necessary operational and regulatory flexibilities to allow health care providers and CMS to test the Model in their local communities and successfully transform themselves; and
  • Support local rural communities’ transformation efforts by being directly engaged at CMS, offering real-time technical expertise and other learning when needed to foster success.”

New Understanding Your Remittance Advice Reports MLN Booklet (MLN8788099)

CMS has published a new MLN Booklet providing information to:

  • Help you learn which types of Remittance Advice (RA) are available,
  • What information is included in an RA,
  • How to view an RA, and
  • Frequently Asked Questions.

Checking Medicare Eligibility MLN Booklet (MLN8816413 September 2020)

CMS advises providers, in this MLN Booklet, “to ensure you are billing appropriately for Medicare-covered supplies and services, check for eligibility. Regularly review your patients’ eligibility information.” This booklet provides guidance on who may be eligible for Medicare and how to check for eligibility.

September 15, 2020: New Roadmap for States to Accelerate Adoption of Value-Based Care (VBC) through Medicaid

CMS sent a letter to State Medicaid Directors on September 15, 2020 “to provide information on how states can advance value-based care (VBC) across the healthcare systems, with a particular emphasis on Medicaid populations, and to share pathways for adoption of such approaches with interested states.

CMS noted in a related Fact Sheet, that just as they have made a “strong commitment to advancing VBC in Medicare for its 61.7 million enrollees” guidance released on September 15, 2020 “is designed to ensure that this same commitment can be made at the state level through Medicaid with its nearly 74 million beneficiaries.”

September 18, 2020: CMS Announces New Model of Care for Medicare Beneficiaries with Chronic Kidney Disease

CMS has finalized the End-Stage Renal Disease (ESRD) Treatment Choices (ETC) Model, “to improve or maintain the quality of care and reduce Medicare expenditures for patients with chronic kidney disease” (CKD). CMS notes in a Press Release that the model is set to be implemented January 1, 2021, will impact approximately 30 percent of kidney care providers, and the estimated savings from the model is $23 million over five and half years.

September 18, 2020: CMS Announced Radiation Oncology Model

CMS has finalized the Radiation Oncology (RO) Model which is “expected to improve the quality of care for cancer patients receiving radiotherapy and reduce Medicare expenditures through bundled payments that allow providers to focus on delivering high-quality treatments.” CMS notes in a Press Release that the RO Model is set to begin January 1, 2021 and the estimated savings is $230 million over five years.

September 21, 2020: OIG Report (A-07-17-01176) Incorrect Acute Stroke Diagnosis Codes Increased Payments to Medicare Advantage Organizations

In this audit, the OIG focused on Medicare eligible patients who were covered under traditional Medicare one year and the following year chose a Medicare Advantage Plan. Data mining enabled them to identify several diagnosis codes at high risk of being miscoded. Specifically for this audit, the OIG focused on the acute stroke diagnosis codes reported on one physician’s claim without being reported on the corresponding inpatient claim. The objective being to determine if selected acute stroke codes submitted by physicians under traditional Medicare were later used by CMS to make payments to MA organizations complied with Federal Requirements. The OIG found that in 580 of 582 claims, the record did not support the acute stroke diagnosis codes. In turn, this meant the ischemic stroke codes used as HCC’s were not valid. CMS estimated just over $14.4 million inaccurate payments were made to MA Plans.

September 22, 2020: CMS Expands Ambulance Program Integrity Model Nationwide

CMS announced the expansion of the Medicare Prior Authorization Model for Repetitive, Scheduled Non-Emergent Ambulance Transport (RSNAT) nationwide. CMS notes in the Press Release that the model has saved Medicare $650 million over four years.

The initial model began for transports on or after December 15, 2014 and is scheduled to end in all model states on December 1, 2020, based on date of service. You can read more about this model in Special Edition MLN article SE1514. Information is also available on the Prior Authorization of Repetitive, Scheduled Non-Emergent Ambulance Transport CMS webpage.

September 24, 2020: Importation of Prescription Drugs FDA Final Rule

This Final Rule was issued “to implement a provision of the Federal Food, Drug, and Cosmetic Act (FD&C Act) to allow importation of certain prescription drugs from Canada. Under this final rule, States and Indian Tribes, and in certain future circumstances pharmacists and wholesalers, may submit importation program proposals to the Food and Drug Administration (FDA, the Agency, or we) for review and authorization…The purpose of the final rule is to achieve a significant reduction in the cost of covered products to the American consumer while posing no additional risk to the public’s health and safety.”

Beth Cobb

COVID-19 in the News September 22nd - 28th
Published on Sep 29, 2020
20200929

MMP remains committed to continuing to monitor for COVID-19 updates specific to our reader base. This week we highlight key updates spanning from September 22nd through 30th.

 

Resource Spotlight: FDA Video – Beware of Fraudulent Coronavirus Tests, Vaccines and Treatments

The FDA announced in their September 21, 2020 COVID-19 Daily Roundup the release of a new video, Beware of Fraudulent Coronavirus Tests, Vaccines and Treatments, explaining “there are currently no FDA-approved drugs or vaccines to treat or prevent COVID-19. Products that fraudulently claim to cure, treat, diagnose, or prevent COVID-19 haven’t been evaluated by the FDA for safety and effectiveness for such use, and they might be dangerous to you and your family.”

 

September 22, 2020: Deaths in U.S. Tops 200,000

The American Hospital, American Medical Association and American Nurses Association released a joint statement marking this “somber milestone” and urging everyone to get their flu shot early.

 

September 23, 2020: $200 Million from Centers for Disease Control and Prevention (CDC) to Jurisdictions for COVID-19 Vaccine Preparedness

The Department of Health and Human Services (HHS) announced the CDC’s action of providing $200 million to 64 jurisdictions for COVID-19 vaccine preparedness to help states prepare for the COVID-19 vaccine.  “Notices of Awards will be issued on September 23, 2020, and all 64 jurisdictions will receive funding, with the amount each jurisdiction receives determined by a population-based formula.”

 

September 23, 2020: CMS Call to Action – Drastic Decline in Care for Children in Medicaid and CHIP due to COVID-19

CMS preliminary Medicaid and Children’s Health Insurance Program (CHIP) data analysis reveals that, during the COVID-19 public health emergency (PHE), rates for vaccinations, primary and preventative services have steeply declined. Specifically, compared to the same time period in 2019:

  • 22% fewer (1.7 million) vaccinations received by beneficiaries up to age 2,
  • 44% fewer (3.2 million) child screening services assessing physical and cognitive development, and
  • 69% fewer (7.6 million) dental services.

CMS indicates in a Press Release that they are “releasing this preliminary data to raise awareness of the vital services Medicaid and CHIP provides, and calling on stakeholders to take action to make services more readily available so that we can begin closing the gap in care for children.”

 

September 23, 2020: FDA Authorizes First Point-of-Care Antibody Test for COVID-19

First authorized for emergency use by certain labs in July, the FDA reissued the Emergency Use Authorization (EUA) for the Assure COVID-19 IgG/IgM Rapid Test Device for Point of Care (POC) use using finger stick blood samples. FDA Commissioner Stephen M. Hahn, M.D. noted in the FDA

News Release that “Authorizing point-of-care serology tests will enable more timely and convenient results for individuals who want to understand if they have previously been infected with the virus that causes COVID-19.”

 

September 24, 2020: MLNConnects COVID-19 Resources

CMS announced in the September 24th MLNConnects newsletter that “the Office of the Assistant Secretary for Preparedness and Response (ASPR) Technical Resources, Assistance Center, and Information Exchange (TRACIE) released an Express message with new resources:  

 

September 25, 2020: New Tools to Streamline Certification for Labs Testing for COVID-19

CMS announced the release of new tools for labs seeking Clinical Laboratory Improvement Amendments (CLIA) certification to test for COVID-19. The announcement includes a link to a quick-start guide outlining the steps that must be followed to apply for and receive CLIA certification.

 

CDC COVID Data Tracker – United States COVID-19 Cases

Data DateTotal CasesTotal DeathsDeaths per 100,000 PeopleCases in Last 7 Days
September 8, 20206,287,362188,68857282,919
September 14, 20206,503,030193,70559241,814
September 20, 20206,748,935198,75460281,490
September 28, 20207,095,422204,32862310,020
Resource: CDC COVID Data Tracker at https://covid.cdc.gov/covid-data-tracker/?deliveryName=USCDC_2067-DM37553#cases_totalcases

Beth Cobb

COVID-19 in the News September 15th - 22nd
Published on Sep 23, 2020
20200923

MMP remains committed to continuing to monitor for COVID-19 updates specific to our reader base. This week we highlight key updates spanning from September 15th through 22nd.

Resource Spotlight: Billing Guidance for Hospitalization without a Positive COVID-19 Test

CMS first released MLN SE20015 on April 15, 2020. This article was revised for the third time on September 11, 2020 to add guidance on how providers notify their MAC when there is no evidence of a positive laboratory test documented in the patient’s medical record.

As a reminder, for admissions on or after September 1, 2020 to be eligible for the 20 percent increase in the MS-DRG weighting factor there must be a positive COVID-19 laboratory test documented in the patient’s medical record. The following guidance was added to the September 11th update:

“To notify your MAC when there is no evidence of a positive laboratory test documented in the patient’s medical record, enter a Billing Note NTE02 “No Pos Test” on the electronic claim 837I or a remark “No Pos Test” on a paper claim.”

A word of caution, CMS also indicates in the MLN article that they may conduct post-payment medical review and if no documentation is in the medical record they will recoup the additional payment. In fact, in late August, the OIG added auditing whether payments made by Medicare for COVID-19 inpatient discharges billed by hospitals complied with Federal requirements to their Active Work Plan Items

September 15, 2020: Bipartisan COVID Relief Framework

The Problem Solvers Caucus (PSC), a group of 25 Democrats and 25 Republicans, released their "March to Common Ground" Bipartisan COVID Relief Framework. With an objective of inspiring negotiators to return to the table, this document addresses the following topics related to COVID-19 by indicating the problem and providing solutions:

  • Testing and Healthcare,
  • Support for individuals and Families,
  • Unemployment Assistance,
  • Small Business & Non-Profits,
  • Schools and Child Care,
  • State and Local Aid,
  • Election Aid,
  • Broadband, Agriculture, USPS, & Census; and
  • Worker and Liability Protections.

 

September 16, 2020: Report from the Independent Coronavirus Commission for Safety and Quality in Nursing Homes (Commission)

CMS announced they had received the final report from the Commission. “To help CMS inform immediate and future actions as well as identify opportunities for improvement, the Commission was created to conduct an independent review and comprehensive assessments of confronting COVID-19. The Commission’s report contains best practices that emphasize and reinforce CMS strategies and initiatives to ensure nursing home residents are protected from COVID-19.”

September 16, 2020: COVID-19 Vaccine Distribution Strategy Released

HHS and the Department of Defense (DoD) announced the release of two documents “outlining the Trump Administration’s detailed strategy to deliver safe and effective COVID-19 vaccine doses to the American people as quickly and reliably as possible.” The Operation Warp Speed, “From the Factory to the Frontlines” document details requirements for vaccine distribution, administration, monitoring, and engagement with a nationwide network of partners. 

September 17, 2020: COVID-19 Lessons Learned & Infectious Disease Surge Annex Template

CMS indicated in the Thursday September 17 edition of MLNConnects that the Office of the Assistant Secretary for Preparedness and Response (ASPR) Technical Resources, Assistance Center, and Information Exchange (TRACIE) have released the following resources related to COVID-19 lessons learned as well as an infectious disease surge annex template:

For More Information: 

September 17, 2020: New Guidance for Safe Visitation in Nursing Homes During COVID-19 Public Health Emergency

CMS has issued revised guidance on ways for nursing homes to safely facilitate visitation during the ongoing COVID-19 pandemic. “CMS recognizes that physical separation from family and other loved ones has taken a significant toll on nursing home residents. In light of this, and in combination with increasingly available data to guide policy development, CMS is issuing revised guidance to help nursing homes facilitate visitation in both indoor and outdoor settings and in compassionate care situations.”

CDC COVID Data Tracker – United States COVID-19 Cases

Data DateTotal CasesTotal DeathsDeaths per 100,000 PeopleCases in Last 7 Days
September 8, 20206,287,362188,68857282,919
September 14, 20206,503,030193,70559241,814
September 20, 20206,748,935198,75460281,490
Resource: CDC COVID Data Tracker at https://covid.cdc.gov/covid-data-tracker/?deliveryName=USCDC_2067-DM37553#cases_totalcases

Beth Cobb

CMS Care Compare
Published on Sep 15, 2020
20200915

In a September 3, 2020 Press Release, CMS announced the launch of a new website call Care Compare. “Care Compare provides a single user-friendly interface that patients and caregivers can use to make informed decisions about healthcare based on cost, quality of care, volume of services, and other data. With just one click, patients can find information that is easy to understand about doctors, hospitals, nursing homes, and other health care services instead of searching through multiple tools.”

Care Compare Features:

  • One click to find information about doctors, hospitals, nurses, nursing homes, home health service, hospice care, inpatient rehabilitation facilities, long-term care hospitals and dialysis facilities,
  • Tool is optimized for mobile and tablet use,
  • Updated maps,
  • New filters to help you identify the providers right for you, and
  • “Consistent design that makes it easier to compare providers and find the information that’s most important to you.”

CMS Administrator Seema Verma noted in the Press Release that “By aggregating all eight of CMS’ quality tools into a single interface, patients can easily research different providers and facilities before they entrust themselves to their care. Today’s launch of Care Compare is the next step in fulfilling our eMedicare promise. Our Administration is committed to ensuring our tools are robust and beneficial to patients.”

While CMS gathers feedback and considers additional improvements to the tool, you will still be able to use the original eight compare tools.

Beth Cobb

COVID-19 in the News September 8th - 15th
Published on Sep 15, 2020
20200915

MMP remains committed to continuing to monitor for COVID-19 updates specific to our reader base. This week we highlight key updates spanning from September 8th through the 15th.

Resource Spotlight: COVID-19 Public Reporting Tip Sheets

CMS has created COVID-19 public reporting tip sheets to explain the strategy for CMS quality data exempted from public reporting due to COVID-19 and the impact on Compare website refreshes. Tip Sheets are available for:

 

September 8, 2020: AMA Announces New COVID-19 Related CPT Codes

The American Medical Association (AMA) announced in a Press Release that they have published an update to the CPT® Code Set which “includes two code additions for reporting medical services sparked by the public health response to the COVID-19 pandemic.”

New Category I CPT codes and long descriptors

  • CPT 99072: Additional supplies, materials, and clinical staff time over and above those usually included in an office visit or other non-facility service(s), when performed during a Public Health Emergency as defined by law, due to respiratory-transmitted infectious disease
  • 86413: Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]) antibody, quantitative

The AMA notes that they have worked with “50 national medical societies and other organizations” to compile data regarding the costs involved in maintaining a safe medical office during the public health emergency and have provided this information to CMS “to inform payment of code 99072.”

Both codes are effective immediately. In addition to the Press Release you can find additional information about the two new codes, including a clinical example in a CPT® Assistance Special Edition: September Update.  

 

September 9, 2020: Expanding Access to COVID-19 Vaccines

The U.S. Department of Health and Human Services issued a Press Release highlighting the issuance of guidance under the Public Readiness and Emergency Preparedness Act (PREP Act) to expand access to safe and effective COVID-19 vaccines. “This guidance authorizes state-licensed pharmacists to order and administer, and state-licensed or registered pharmacy interns acting under the supervision of the qualified pharmacist to administer, COVID-19 vaccinations to persons ages 3 or older, subject to certain requirements.”

 

September 17 CDC Call: Testing and Treatment of 2020-2021 Seasonal Influenza During the COVID-19 Pandemic

The CDC is hosting a Clinician Outreach and Communication Activity (COCA) Call on Thursday, September 17th from 2:00 pm – 3:00 pm (ET). In the announcement, the CDC indicated the following four objectives that participants will be able to accomplish at the conclusion of the call:

  • Review influenza activity since the onset of the COVID-19 pandemic.
  1. Provide background on influenza tests and antivirals for influenza.
  2. Describe influenza testing guidance for patients with acute respiratory illness for the 2020-2021 season, including during community co-circulation of influenza viruses and SARS-CoV-2.
  3. Describe antiviral treatment recommendations for patients with suspected or confirmed influenza for the 2020-2021 season, including during community co-circulation of influenza viruses and SARS-CoV-2.

Additional information about the call and how to join in the session can be found on the CDC website at https://emergency.cdc.gov/coca/calls/2020/callinfo_091720.asp?deliveryName=USCDC_1052-DM37672.

 

September 8, 2020: CDC COVID Data Tracker – United States COVID-19 Cases

  • Total Cases: 6,287,362,
  • Total Deaths: 188,688
  • Deaths per 100,000 people: 57
  • Cases in last 7 days: 282, 919

September 14, 2020: CDC COVID Data Tracker – United States COVID-19 Cases

  • Total Cases: 6,503,030
  • Total Deaths: 193,705
  • Deaths per 100,000 people: 59
  • Cases in last 7 days: 241,814

Link to CDC COVID Data Tracker: https://covid.cdc.gov/covid-data-tracker/?deliveryName=USCDC_2067-DM37553#cases

Beth Cobb

Medicare Transmittals Effective October 2020
Published on Sep 09, 2020
20200909

To paraphrase a Barbara Mandrell song, I was a pumpkin spice latte fan before pumpkin spice was cool. In fact, two weeks ago I drank my first pumpkin spice latte for 2020. Did you know that one grande pumpkin spice latte from Starbucks has about 150mg of caffeine? That is enough caffeine to be equivalent to about two shots of expresso. To keep with musical references, Amy Grant once referred to expresso as being a “nap in a can” on one of her live albums. 

So why the focus on caffeine? The October 1st start date of the 2021 CMS Fiscal Year is just 22 days from today and CMS has been publishing updates effective October 1st at a pace worthy of a shot or two of expresso to keep you energized as you prepare for these changes. This article highlights recently released MLN articles providing guidance on updates effective October 1st.

Modify Edits in the Fee for Service (FFS) System when a Beneficiary has a Medicare Advantage (MA) Plan

  • Article Release Date: July 21, 2020 – Revised July 21, 2020
  • What You Need to Know: This article is “for providers, especially hospitals, submitting claims to Medicare Administrative Contractors (MACs) for Part A services provided to Medicare beneficiaries when a beneficiary’s Medicare Advantage (MA) plan becomes effective during the inpatient admission.”
  • MLN MM11580: https://www.cms.gov/files/document/mm11580.pdf
  • Change Request 11580: https://www.cms.gov/files/document/r10229CP.pdf
  • Effective Date: October 1, 2020
  • Implementation Date: October 5, 2020

Addition of the QW Modifier to Healthcare Common Procedure Coding System (HCPCS) Code 87426

New Waived Tests

  • Article Release Date: July 28, 2020
  • What You Need to Know: This article provides information about five new Clinical Laboratory Improvement Amendments of 1988 (CLIA) waived tests that have been approved by the FDA. These tests are marketed immediately after approval so CMS must notify the MACs of the new tests for accurate claims processing. “Note: MACs will not search their files to either retract payment or retroactively pay claims. However, MACs should adjust claims if you bring those claims to their attention.
  • MLN Matters MM11916: https://www.cms.gov/files/document/mm11916.pdf
  • Change Request 11916: https://www.cms.gov/files/document/r10230CP.pdf
  • Effective Date: October 1, 2020
  • Implementation Date: October 5, 2020

July 31, 2020: CMS Releases Inpatient Psychiatric Facility (IPF), Skilled Nursing Facilities (SNF), and Hospices FY 2021 Final Rules

CMS announced in a News Alert that they are “finalizing three Medicare payment rules that further advance our efforts to strengthen the Medicare program by better aligning payments for inpatient psychiatric facilities (IPF), skilled nursing facilities (SNF) and hospices.”   For fact sheets on each final rule, visit:

Inpatient Psychiatric Facilities Prospective Payment System (IPF PPS) Updates for Fiscal Year 2021

  • Article Release Date: August 21, 2020
  • What You Need to Know: This article provides updates related to the IPF PPS FY 2021 Final Rule including information about:
  • Market Basket Update,
  • FY 2021 Wage Index Update,
  • IPF Quality Reporting Program,
  • PRICER Updates,
  • ICD-10 CM/PCS Updates,
  • Cost of Living Adjustment (COLA) Adjustment, and
  • Rural Adjustment.
  • MLN MM11949: https://www.cms.gov/files/document/mm11949.pdf
  • Change Request 11949: https://www.cms.gov/files/document/r10312CP.pdf
  • Effective Date: October 1, 2020
  • Implementation Date: October 5, 2020

Quarterly Update for Clinical Laboratory Fee Schedule and Laboratory Services Subject to Reasonable Charge Payment

  • Article Release Date: August 7, 2020 – Revised August 24, 2020
  • What You Need to Know: This article provides information about the quarterly update to the clinical laboratory fee schedule. On August 24th it was updated to reflect changes to Change Request (CR) 11937 that includes additional COVID-19 codes 86408, 86409, 0225U, 0226U, effective August 10, 2020. This CR also added codes 0015M and 0016M, effective October 1, 2020.
  • MLN MM11937: https://www.cms.gov/files/document/mm11937.pdf
  • Change Request 11937: https://www.cms.gov/files/document/r10318CP.pdf
  • Effective Date: October 1, 2020
  • Implementation Date: October 5, 2020

Quarterly Update to the Medicare Physician Fee Schedule Database (MPFSDB) – October 2020 Update

October 2020 Quarterly Average Sales Price (ASP) Medicare Part B Drug Pricing Files and Revisions to Prior Quarterly Pricing Files – REVISED

Medicare Part A Skilled Nursing Facility (SNF) Prospective Payment System (PPS) Pricer Update FY 2021

  • Article Release Date: July 2, 2020 – Revised August 19, 2020
  • What You Need to Know: This article was revised to reflect a revised CR 11859 which “shows that effective for Fiscal Year (FY) 2021, a 5 percent cap will be adopted and applied to all Skilled Nursing Facility providers on any decrease to a provider’s FY 2021 final wage index from that provider’s final wage index of the prior fiscal year (FY 2020).”
  • MLN MM11859: https://www.cms.gov/files/document/MM11859.pdf
  • Change Request 11859: https://www.cms.gov/files/document/r10314CP.pdf
  • Effective Date: October 1, 2020
  • Implementation Date: October 5, 2020

October 2020 Update of the Hospital Outpatient Prospective Payment System (OPPS)

October 2020 Integrated Outpatient Code Editor (I/OCE) Specifications Version 21.3

October Quarterly Update for the 2020 Durable Medical Equipment, Prosthetics, Orthotics and Supplies (DMEPOS) Fee Schedule

  • Article Release Date: August 28, 2020
  • What You Need to Know: This article provides details about the changes to the DMEPOS fee schedules that Medicare updates quarterly, when necessary, to implement fee schedule amounts for new and existing codes, as applicable, and apply changes in payment policies. Specific to the ongoing Public Health Emergency (PHE) due to the COVID-19 pandemic, “the October 2020 DMEPOS and PEN fee files continue to include the non-rural contiguous non-CBA 75/25 blended fees required by Section 3712(b) of the CARES Act signed into law on March 27, 2020.
  • MLN MM11956: https://www.cms.gov/files/document/mm11956.pdf
  • Change Request 11956: https://www.cms.gov/files/document/r10334CP.pdf
  • Effective Date: October 1, 2020
  • Implementation Date: October 5, 2020

Update to Hospice Payment Rates, Hospice Cap, Hospice Wage Index and Hospice PRICER for FY 2021

Inpatient Rehabilitation Facility (IRF) Annual Update: Prospective Payment System (PPS) PRICER Changes for FY 2020

As if all of this isn’t expresso worthy, the FY 2021 Inpatient Prospective Payment System Final Rule was released last Wednesday September 2nd. So grab yourself a pumpkin spice latte and enjoy while reading about MS-DRGs changes in the IPPS Final Rule discussed in a related article in this week’s edition of Wednesday@One.

Beth Cobb

IPPS FY 2021 Final Rule: MS-DRG Changes
Published on Sep 09, 2020
20200909

CMS released the display copy of the Fiscal Year (FY) 2021 Inpatient Prospective Payment System (IPPS) Final Rule last Wednesday September 2, 2020. As of the release of this article, you have twenty-one days to read and absorb the information as you prepare for the October 1, 2020 start of the 2021 CMS FY.  

At least annually, MS-DRG classifications and relative weights are adjusted to reflect changes in treatment patterns, technology, and other factors that may change the relative use of hospital resources. This week highlights finalized changes to specific MS-DRG Classifications.

 

Pre-MDC: Bone Marrow Transplants

Surgical vs. Medical MS-DRGs

Currently, the Bone Marrow Transplant (BMT) MS-DRGs (MS-DRG 014 (Allogeneic Bone Marrow Transplant), MS-DRG 016 (Autologous Bone Marrow Transplant with CC/MCC or T-Cell Immunotherapy), and MS-DRG 017 (Autologous Bone Marrow Transplant without CC/MCC) are designated as surgical MS-DRGs.

In the proposed rule, a request was made to re-designate these three MS-DRGs as medical MS-DRGs as a Bone Marrow Transplant does not involve a surgical procedure or require the use of an O.R. The requestor noted that this change “would clinically align with the resources utilized in the performance of these procedures.”

Clinical advisors agreed and CMS finalized their proposal to re-designate MS-DRGs 014, 016, and 017 as medical MS-DRGs effective October 1, 2020.

BMT Procedures Designation O.R. vs. Non-O.R.

The requestor also noted that MS-DRGs 016 and 017 includes ICD-10-PCS procedures codes designated as Non-O.R. while the following eight procedures are designated as O.R. Procedures:

  • 30230AZ: Transfusion of embryonic stem cells into peripheral vein, open approach
  • 30230G0: Transfusion of autologous bone marrow into peripheral vein, open approach
  • 30230X0: Transfusion of autologous cord blood stem cells into peripheral vein, open approach
  • 30230Y0: Transfusion of autologous hematopoietic stem cells into peripheral vein, open approach
  • 30240AZ: Transfusion of embryonic stem cells into central vein, open approach
  • 30240G0: Transfusion of autologous bone marrow into central vein, open approach
  • 30240X0: Transfusion of autologous cord blood stem cells into central vein, open approach
  • 30240Y0: Transfusion of autologous hematopoietic stem cells into central vein, open approach.

CMS finalized the re-designation of these codes from O.R. to Non-O.R. procedures affecting their current MS-DRG assignment.  

Chimeric Antigen Receptor (CAR) T-Cell Therapies: New MS-DRG

In the FY 2020 IPPS Proposed Rule, a request was made to create new MS-DRGs for CAR T-cell therapy. The requestor noted this would improve payment in the inpatient setting. CMS did not believe enough data was available to make a change at that time. However, CMS did seek comments on payment alternatives for CAR-T cell therapies.

In the FY 2020 Final Rule CMS finalized the continuation of the new technology status and add-on payments for FY 2020 for this therapy.

In the FY 2021 proposed rule, the request was again made to create a new MS-DRG as this therapy will no longer be eligible for the new technology add-on payment (NTAP) for FY 2021. CMS responded by noting they now have enough data to consider the development of a new MS-DRG. Further, CMS clinical advisors found a vast discrepancy in resource consumption and clinical differences warranting the creation of new MS-DRG.

In the Final Rule, CMS finalized their proposal to:  

  • Assign cases reporting ICD-10-PCS procedure codes XW033C3 or XW043C3 to a new MS-DRG 018 (Chimeric Antigen Receptor (CAR) T-cell immunotherapy, and
  • Revise the MS-DRG 016 title to “Autologous Bone Marrow Transplant with CC/MCC.”

The following table highlights the MS-DRG relative weight (RW) and geometric mean length of stay (GMLOS) for the BMT MS-DRGs and the new CAR T-Cell MS-DRG:

MS-DRGMS-DRG DescriptionFY 2021 R.W.FY 2021 GMLOS
014Allogeneic Bone Marrow Transplant12.77824.1
016Autologous Bone Marrow Transplant with CC/MCC6.726217.1
017Autologous Bone Marrow Transplant without CC/MCC4.83028.9
018Chimeric Antigen Receptor (CAR) T-Cell Immunotherapy37.329015.6
Table 5. – List of Medicare Severity Diagnosis-Related Groups (MS-DRGs), Relative Weighting Factors, and Geometric and Arithmetic Mean Length of Stay – FY 2021 Final Rule

MDC 1: Diseases and Disorders of the Nervous System

Carotid Artery Stent Procedures: Background

In FY 2020 CMS finalized their proposal to reassign 96 ICD-10-PCS procedures describing dilation of carotid artery with an intraluminal device(s):

  • From MS-DRGs 037, 038, and 039 (Extracranial Procedures with MCC, with CC, and without CC/MCC respectively)
  • To MS-DRGs 034, 035, and 036 (Carotid Artery Stent Procedures with MCC, with CC, and without CC/MCC respectively)

Carotid Artery Stent Procedures: FY 2021 Proposals

In response to a request, CMS proposed to reassign the following six ICD-10-PCS codes describing dilation of carotid artery with drug eluting intraluminal device(s) using an open approach from MS-DRGs 037, 038, and 039 to MS-DRGs 034, 035, and 036:

  • 037H04Z: Dilation of right common carotid artery with drug-eluting intraluminal device, open approach
  • 037J04Z: Dilation of left common carotid artery with drug-eluting intraluminal device, open approach
  • 037K04Z: Dilation of right internal carotid artery with drug-eluting intraluminal device, open approach
  • 037L04Z: Dilation of left internal carotid artery with drug-eluting intraluminal device, open approach
  • 037M04Z: Dilation of right external carotid artery with drug-eluting intraluminal device, open approach
  • 037N04Z: Dilation of left external carotid artery with drug-eluting intraluminal device, open approach

CMS further reviewed to see if any of the six codes were included in MS-DRGs outside of MDC 1. They found a total of 36 ICD-10 PCS codes for procedures describing dilation of the carotid artery with an intraluminal device with an open approach that are currently assigned to MS-DRG 252 (Other Vascular Procedures with MCC) in MDC 5 (Diseases and Disorders of the Circulatory System). Interestingly, they found 8 claims with one of these 36 ICD-10-PCS codes and a Principal Diagnosis in MDC 1 causing the claims to group to the Extensive O.R. Procedure Unrelated to Principal Diagnosis MS-DRG Group (981, 982, and 983).

CMS finalized the proposal to add the 6 codes as requested and the additional 36 ICD-10-PCS codes they identified as currently being in MDC 5 to the GROUPER logic for MS-DRGs 034, 035, 036 in MDC 1.

As an instructor told me when first learning about the MS-DRG system, this change permits cases with a Principal Diagnosis in MDC 1 to “remain in the family.”

 

MDC 3: Diseases and Disorders of Ear, Nose, and Throat

Temporomandibular Joint Replacements

A request was made to reassign ICD-10-PCS procedures 0RRC0JZ (Replacement of right temporomandibular joint with synthetic substitute, open approach), and 0RRD0JZ (Replacement of left temporomandibular joint with synthetic substitute, open approach):

  • From MS-DRGs 133 and 134 (Other Ear, Nose, Mouth and Throat O.R. Procedures with and without CC/MCC, respectively)
  • To MS-DRGs 131 and 132 (Cranial and Facial Procedures with and without CC/MCC, respectively) in MDC 03.

The requestor stated that it is inaccurate for these two codes that involve the excision of the TMJ and replacement with a prosthesis to Group to MS-DRGs 133 and 134 when the codes for the TMJ excision alone (0RBC0ZZ (Excision of right temporomandibular joint, open approach) and 0RBD0ZZ (Excision of left temporomandibular joint, open approach) group to the higher weighted MS-DRGs 131 and 132.

CMS undertook a comprehensive review of all procedures currently assigned to MS-DRGs 129, 130, 131, 132, 133, and 134. Based on data analysis and this comprehensive review, CMS Clinical Advisors supported restructuring of these MS-DRGs by assigning procedures based on clinical intensity, complexity of service and resource utilization.

CMS finalized their proposals to:  

  • Delete the three MS-DRGs groups with a two-way severity level subgroup (129 & 130, 131 & 132, and 133 & 134)
  • Create two new base MS-DRGs with a three-way severity level split:
  • MS-DRGs 140, 141, and 142 (Major head and Neck Procedures with MCC, with CC, without CC/MCC respectively), and
  • MS-DRGs 143, 144, and 145 (Other Ear, Nose, Mouth, and Throat O.R. Procedures with MCC, with CC, without CC/MCC respectively).

Note, CMS refers readers to Tables 6P.2a, 6P.2b, and 6P.2.c associated with the final rule for the finalized list of procedure codes that define the logic for the finalized MS-DRGs.

 

MDC 5: Diseases and Disorders of the Circulatory System

Left Atrial Appendage Closure (LAAC)

Requests were made to create a new MS-DRG for the LAAC procedure or to map all LAAC procedures to a different MS-DRG with payment rates aligned with procedural costs.  The following table details the current corresponding MS-DRGs for the 9 ICD-10-PCS codes describing LAAC Procedures. Note that currently the procedure map to an MS-DRG based on the approach.

ICD-10-PCS CodeMS-DRGDescription
02L70CK250-251Occlusion of left atrial appendage with extraluminal device, open approach
02L70DK250-251Occlusion of left atrial appendage with intraluminal device, open approach
02L70ZK250-251Occlusion of left atrial appendage, open approach
02L73CK273-274Occlusion of left atrial appendage with extraluminal device, percutaneous approach
02L73DK273-274Occlusion of left atrial Appendage with intraluminal device, percutaneous approach
02L73ZK273-274Occlusion of left atrial appendage, percutaneous approach
02L74CK273-274Occlusion of left atrial appendage with extraluminal device, percutaneous endoscopic approach
02L74DK273-274Occlusion of left atrial appendage with intraluminal device, percutaneous endoscopic approach
02L74ZK273-274Occlusion of left atrial appendage, percutaneous endoscopic approach
Source: IPPS Final Rule for FY 2021

CMS finalized their proposal to reassign the ICD-10-PCS procedure codes for an open approach to MS-DRGs 273 and 274. “Clinical advisors stated this reassignment would allow all LAAC procedures to be grouped to the same MS-DRGs and improve clinical coherence.” The following table highlights the difference in R.W. and GMLOS for FY 2021 for the four MS-DRGs as well the MS-DRG title changes for MS-DRGs 273 and 274:

MS-DRGMS-DRG DescriptionR.W.GMLOS
250Percutaneous Cardiovascular Procedure without Coronary Artery Stent with MCC2.52283.7
251Percutaneous Cardiovascular Procedure without Coronary Artery Stent without MCC1.65982.1
273Percutaneous and other Intracardiac Procedures with MCC3.83724.3
274Percutaneous and Other Intracardiac Procedures without MCC3.28541.6
Table 5. – List of Medicare Severity Diagnosis-Related Groups (MS-DRGs), Relative Weighting Factors, and Geometric and Arithmetic Mean Length of Stay – FY 2021 Final Rule

Insertion of Cardiac Contractility Modulation Device

A request was made to review the MS-DRG assignment for cases identifying patients receiving a cardiac contractility modulation (CCM) device system for CHF. “CCM is indicated for patients with moderate to severe heart failure resulting from either ischemic or non-ischemic cardiomyopathy. CCM utilizes electrical signals which are intended to enhance the strength of the heart and overall cardiac performance. CCM delivery device systems consist of a programmable implantable pulse generator (IPG) and three leads which are implanted in the heart. One lead is implanted into the right atrium and the other two leads are inserted into the right ventricle.”

Reasons for this request:

  • MS-DRGs 222, 223, 224, 225, 226, and 227 (Cardiac Defibrillator Implant with and without Cardiac Catheterization with and without AMI/HF/Shock with and without MCC, respectively include “code pairs” describing the insertion of contractility modulation devices.
  • Currently, GROUPER logic requires the combination of the CCM device codes and a left ventricular lead to map to this group of MS-DRGs.
  • Per the requestor, a CCM device is contraindicated in patients with a left ventricular lead. Consequently, no case involving insertion of the CCM system can be appropriately mapped to this group of MS-DRGs.
  • Currently, CCM system insertion maps to MS-DRG 245 (AICD Generator Procedures).
  • Requester noted to date this procedure has been performed on an outpatient bases but expects that some Medicare patients will receive CCM devices as an inpatient.

CMS analysis found that the ICD-10-PCS procedure code combinations for right ventricular and/or right atrial lead insertion with insertion of CCM devices were inadvertently excluded from this group of MS-DRGs as a result of replicating the ICD-9 based MS-DRGs.

CMS has finalized the following two proposals:

  • Add 24 ICD-10-PCS code combinations for CCM devices to this group of MS-DRGs, and
  • Delete 12 clinically invalid code combinations from the GROUPER logic of this MS-DRG group describing the insertion of CCM device and the insertion of a cardiac lead into the left ventricle.

 

MDC 8: Diseases and Disorders of the Musculoskeletal System and Connective Tissue

Hip and Knee Joint Replacements

A requestor recommended restructuring MS-DRGs for total joint arthroplasty that utilize oxidized zirconium bearing surface implants in total hip and total knee replacements. They went on to offer three options for restructuring the MS-DRGs.

Based on the request and lengthy data analysis by CMS, CMS proposed and has finalized two new MS-DRGs for hip replacements due to a hip fracture.  The following table highlights the difference in R.W. and GMLOS for FY 2021:

MS-DRGMS-DRG DescriptionR.W.GMLOS
469Major Hip and Knee Joint Replacement or Reattachment of Lower Extremity with MCC or Total Ankle Replacement3.08443.1
470Major Hip and Knee Joint Replacement or Reattachment of Lower Extremity without MCC1.89991.8
New MS-DRG 521Hip Replacement with Principal Diagnosis of Hip Fracture with MCC3.06346.2
New MS-DRG 522Hip Replacement with Principal Diagnosis of Hip Fracture without MCC2.18914.1
Table 5. – List of Medicare Severity Diagnosis-Related Groups (MS-DRGs), Relative Weighting Factors, and Geometric and Arithmetic Mean Length of Stay – FY 2021 Final Rule

Impact on the Comprehensive Care for Joint Replacement (CJR) Model

In the proposed rule CMS acknowledged that the CJR model includes episodes triggered by MS-DRG 469 with hip fracture and MS-DRG 470 with hip fracture. Given the proposal for new MS-DRGs for hip fracture, CMS requested comments on the effect this proposal would have on the CJR model and whether to incorporate the new MS-DRGs into the model if finalized.

CMS notes in the Final Rule that “an interim final rule published in April 6, 2020 extended the CJR model through March 31, 2021, in light of the COVID-19 pandemic, to ensure the continuity of the CJR model operations in participant hospitals during the public health emergency so that we did not create any additional disruptions to the standard of care procedures hospitals have in place during this challenging time. Because the model will continue until at least March 31, 2021, we intend to adopt a policy in the CJR final rule that incorporates MS-DRG 521 and MS-DRG 522 into the CJR model as of the effective date of these new MS-DRGs. We believe such an approach would avoid disruption to the model for the remainder of PY5 (as extended) and thereafter, if our proposal to extend the CJR model to December 31, 2023 is finalized.”

 

MDC 11: Diseases and Disorders of the Kidney and Urinary Tract

Kidney Transplants

Currently, Kidney Transplants group to MS-DRG 652 (Kidney Transplant) in MDC 11. There was a request to re-designate kidney transplants as Pre-MDC MS-DRGs similar to other organ transplants. CMS analysis found that all kidney transplants in MS-DRGs 981 and 982 reported a principal diagnosis in MDC 5 (Diseases and Disorders of the Circulatory System).

Instead of proposing a move to a Pre-MDC MS-DRG, CMS proposed and has now finalized an alternate option “to modify the GROUPER logic for MS-DRG 652 by allowing the presence of a procedure code describing transplantation of the kidney to determine the MS-DRG assignment independent of the MDC of the principal diagnosis in most instances.”

Of note, CMS discussed in the proposed rule how the Pre-MDCs came into existence and that the proposal for kidney transplant procedure code to determine the MS-DRG assignment represent a “first step in investigating” how they may consider shifting transplants out of Pre-MDCs as their clinical advisors have noted that while once considered as being very resource intensive, “treatment practices have shifted since the inception of Pre-MDCs.”

Kidney Transplants and Dialysis during an Inpatient Stay

An additional request was made to create a new MS-DRG for kidney transplant cases where a patient receives dialysis during the inpatient stay and after the date of the transplant. The following three ICD-10-PCS procedure codes identify the performance of hemodialysis:

  • 5A1D70Z: Performance of urinary filtration, intermittent, less than 6 hours per day
  • 5A1D80Z: Performance of urinary filtration, prolonged intermittent, 6-18 hours per day
  • 5A1D90Z: Performance of urinary filtration, continuous, greater than 18 hours per day

CMS indicated in the proposed rule that they believe that creating separate MS-DRGs when hemodialysis is performed either before or after a kidney transplant or simultaneous pancreas/kidney transplant “would appropriately address the differential in resource consumption consistent with the President’s Executive Order on Advancing American Kidney Health (see https://www.whitehouse.gov/presidential-actions/executive-order-advancing-american-kidney-health/).”

CMS has finalized the proposed three new MS-DRGs:

  • Pre-MDC MS-DRG 019 (Simultaneous Pancreas/Kidney Transplant with Hemodialysis) for cases describing the performance of hemodialysis during an admission where the patient received a simultaneous pancreas/kidney transplant, and
  • MS-DRGs 650 and 651 (Kidney Transplant with Hemodialysis with MCC and without MCC respectively) for cases describing the performance of hemodialysis in an admission where the patient received a kidney transplant in MDC 11.

As part of the logic for the new MS-DRGs, CMS finalized their proposal to change the designation of the above hemodialysis codes from non-O.R. procedures to non-O.R. procedures affecting the MS-DRG.

 

MDC 17: Myeloproliferative Diseases and Disorders, Poorly Differentiated Neoplasms

Inferior Vena Cava Filters

A requestor noted that currently when the procedure code describing the placement of an inferior vena cava (IVC) filter (06H03DZ – Insertion of intraluminal device into inferior vena cava, percutaneous approach) is also reported with the codes describing the introduction of a high dose chemotherapy agent or report a chemotherapy principal diagnosis with a secondary diagnosis describing acute leukemia, the cases are assigned to a lower weighted MS-DRG group than when the IVC filter code is not on the claim.

CMS noted in the proposed rule that “our clinical advisors believe that, given the similarity in factors such as complexity, resource utilization, and lack of a requirement for anesthesia administration between all procedures describing insertion of a device into the inferior vena cava, it would be more appropriate to designate these three ICD-10-PCS codes describing the insertion of an intraluminal device into the inferior vena cava as Non-O.R. procedures. Therefore, we are proposing to remove ICD-10-PCS procedure codes 06H00DZ, 06H03DZ, and 06H04DZ from the FY 2021 ICD-10 MS-DRG Version 38 Definitions Manual in Appendix E--Operating Room Procedures and Procedure Code/MS-DRG Index as O.R. procedures. Under this proposal, these procedures would no longer impact MS-DRG assignment.”

In the Final Rule, CMS clinical advisors concurred with commenters “that while the procedure to insert an IVC filter is not surgical in nature, procedures describing the insertion of an intraluminal device into the inferior vena cava performed via an open or percutaneous endoscopic approach could require greater resources than a procedure describing insertion of an intraluminal device into the inferior vena cave performed via a percutaneous approach.”

For this reason, CMS has indicated they will further examine relevant clinical factors and similarities in resource consumption between procedures describing the insertion of an intraluminal device into the inferior vena cava performed via an open or a percutaneous endoscopic approach.”

CMS finalized the following proposals for FY 2021: 

  • ICD-10-PCD procedure code 06H03DZ designation is changing from O.R. to non-O.R. procedure, and
  • For now, ICD-10-PCS procedures codes 06H00DX and 06H04DZ will maintain the O.R. designation and continue to impact MS-DRG assignment.

 

Moving Forward

The FY 2021 IPPS Final Rule is scheduled to be published in the Federal Register on September 18, 2020. Until then, you can access the display copy available on the FY 2021 IPPS Final Rule Home Page and watch for additional articles in the Wednesday@One.

 

Resources:

FY 2021 IPPS Final Rule Home Page on CMS website: https://www.cms.gov/medicare/acute-inpatient-pps/fy-2021-ipps-final-rule-home-page#1735

CMS Fact Sheet: Fiscal Year (FY) 2021 Medicare Hospital Inpatient Prospective Payment System (IPPS) and Long Term Acute Care Hospital (LTCH) Final Rule (CMS-1735-F): https://www.cms.gov/newsroom/fact-sheets/fiscal-year-fy-2021-medicare-hospital-inpatient-prospective-payment-system-ipps-and-long-term-acute-0

Beth Cobb

COVID-19 in the News September 1st through 8th
Published on Sep 09, 2020
20200909

MMP remains committed to continuing to monitor for COVID-19 updates specific to our reader base. This week we highlight key updates spanning from September 1st through the 8th.

 

Resource Spotlight: Travel during the COVID-19 Pandemic

The CDC’s Travel during the COVID-19 Pandemic webpage provides information about:

  • Reasons you should not travel,
  • Considerations prior to travel,
  • What to do if you do travel,
  • Considerations for types of travel (i.e., air, bus, care, RV),
  • Tips to avoid getting and spreading COVID-19 in common travel situations (i.e., bathrooms and rest stops),
  • Anticipating your travel needs, and
  • What to do after you have traveled.

 

September 1, 2020: Provider Relief for Assisted Living Facilities (ALFs)

HHS announced that ALFs may now apply for funding under the Provider Relief Fund Phase 2 General Distribution allocation. This funding was made possible through the CARES Act and the Paycheck Protection Program and Healthcare Enforcement Act.

 

September 3, 2020: $2 Billion Provider Relief Fund Nursing Home Incentive Payment Plans

HHS announced “details of a $2 billion Provider Relief Fund (PRF) performance-based incentive payment distribution to nursing homes. This distribution is the latest update in the previously announced $5 billion in planned support to nursing homes grappling with the impact of COVID-19. Last week, HHS announced it had delivered an additional $2.5 billion in payments to nursing homes to help with upfront COVID-19-related expenses for testing, staffing, and personal protective equipment (PPE) needs. Other resources are also being dedicated to support training, mentorship and safety improvements in nursing homes.”

The Press Release provides details regarding:

  • Qualifications to participate in the Program,
  • The performance and payment cycle, and
  • Methodology to measure a facilities performance. Specifically, nursing homes will have their performance measured on their ability to keep new COVID infection rates low among residents and ability to keep COVID mortality low among residents.

 

September 3, 2020: Reported Cases of Multisystem Inflammatory Syndrome in Children (MIS-C) in the United States

The CDC has been tracking reports of MIS-C since mid-May 2020. According to the CDC, this is “a rare but serious condition associated with COVID-19. MIS-C is a new syndrome, and many questions remain about why some children develop it after a COVID-19 illness or contact with someone with COVID-19, while others do not.”

 

MIS-C Cases as of September 3, 2020:

  • 792 confirmed cases and 16 deaths in 42 states,
  • Most cases are in children between 1 and 14 years old with an average age of 8,
  • More than 70% of reported cases have occurred in children who are Hispanic/Latino (276 cases) or Non-Hispanic Black (230 cases),
  • 99% of cases (783) tested positive for COVID-19 while the remaining 1% were around someone with COVID-19,
  • Most children developed MIS-C 2-4 weeks after COVID-19 infection, and
  • 54% of reported cases have been male.

The CDC MIS-C webpage provides additional information about the disease, what they are doing, and information for healthcare professionals.

 

September 8, 2020: CDC COVID Data Tracker – United States COVID-19 Cases

Beth Cobb

COVID-19 in the News August 25th - 31st
Published on Sep 01, 2020
20200901

MMP remains committed to continuing to monitor for COVID-19 updates specific to our reader base. This week we highlight key updates spanning from August 25th through the 31st.

Resource Spotlight: How to Select, Wear, and Clean Your Mask

Alabama Governor Kay Ivey has extended the state’s safer-at-home order through October 2, 2020. This order includes the following mask mandate:

  • “Each person shall wear a mask or other facial covering that covers his or her nostrils and mouth at all times when within six feet of a person from another household in any of the following places: an indoor space open to the general public, a vehicle operated by a transportation service, or an outdoor public space where ten or more people are gathered.” Note, there are exceptions to the mandate, for example, the requirement does not apply when seated at a restaurant to eat or drink.
  • You can read the entire Safer at Home order on the Alabama.Gov website at https://governor.alabama.gov/newsroom/covid-19/.

This week’s Resource Spotlight is on the CDC’s new COVID-19 webpage How to Select, Wear, and Clean Your Mask. Included on this page are seven ways to NOT wear a mask. If you are like me, you have been witness to each of the following ways NOT to wear a mask:

  • Around your neck,
  • On your forehead,
  • Under your nose,
  • Only on your nose,
  • On your chin,
  • Dangling from one ear,
  • On your arm.

 

August 25, 2020: FDA’s Guide to Search Hand-Sanitizer Do-Not-Use List

The FDA has been urging consumers to not use certain hand sanitizer products since mid-June. Initially, the concern was methanol contamination in certain hand sanitizers. On August 12th they expanded their warning to include e 1-propanol contamination. In their guidance, the FDA indicates “1-propanol, not to be confused with 2-propanol/isopropanol/isopropyl alcohol, is not an acceptable ingredient for hand sanitizer products marketed in the United States and can be toxic and life-threatening when ingested. The agency urges consumers not to use these 1-propanol-contaminated products and has expanded its do-not-use list of hand sanitizers at www.fda.gov/unsafehandsanitizers to include hand sanitizers that are or may be contaminated with 1-propanol, in addition to other hand sanitizers the agency is urging consumers not to use.”

Most recently, on August 25th, the FDA published the consumer update Is Your Hand Sanitizer on FDA’s List of Products You Should Not Use? This update includes a “Step-by-step Search Guide” to assist consumers in accessing their Hand Sanitizer Do-Not-Use List which as of August 26th include 165 hand sanitizer products.

 

August 24, 2020: OCR Issues Amends June 2020 Plasma Donation Guidance

HHS announced the Office of Civil Rights (OCR) at HHS has issued amended guidance on how the HIPAA Privacy Rule permits covered health care providers and health plans to contact patients who have recovered from COVID-19 to inform them about donating their plasma containing antibodies (known as “convalescent plasma”) to help treat patients being actively treated for COVID-19.

“OCR added health plans to the June 2020 guidance that explains how HIPAA permits covered health care providers and health plans to identify and contact patients and beneficiaries who have recovered from COVID-19 for individual and population-based case management or care coordination. The guidance also emphasizes that, without individuals' authorization, the providers and health plans cannot receive any payment from, or on behalf of, a plasma donation center in exchange for such communications with recovered individuals.”

 

August 25, 2020: New Interim Final Rule: Impact on Nursing Homes Testing and Hospitals Reporting COVID-19 Data

CMS issued an Interim Final Rule on August 25th. In a related CMS Press Release, CMS Administrator Seema Verma noted that “These new rules represent a dramatic acceleration of our efforts to track and control the spread of COVID-19…Reporting of test results and other data are vitally important tools for controlling the spread of the virus and give providers on the front lines what they need to fight it.” Following are specific requirements specific to Nursing Homes and Hospitals.

Nursing Homes

  • Revisions to infection-control regulations for long-term care facilities to no longer recommend but make it a requirement for participation in Medicare and Medicaid programs that nursing homes test their staff for COVID-19.
  • Frequency of Nursing Home Staff testing will be based on community spread and CMS indicated guidance will be announced shortly.
  • Nursing Homes will now be required to offer tests to residents when there is an outbreak or residents show symptoms.
  • Surveyors will inspect nursing home for adherence to new testing requirements.
  • Nursing Homes that do not comply will be cited for non-compliance, may face enforcement actions based on the severity of noncompliance, such as civil monetary penalties in excess of $400 per day.

Hospitals and Critical Access Hospitals

Will be required to report daily data, including, but not limited to:

  • The number of confirmed or suspected COVID-19 positive patients,
  • ICU beds occupied, and
  • Availability of essential supplies and equipment such as ventilators and PPE.

Currently many hospitals are reporting this information voluntarily. The Interim Final Rule makes reporting data a condition of participation in Medicare and Medicaid programs. “Hospitals will face possible termination of Medicare and Medicaid payment if unable to correct reporting deficiencies.”

Note, the Interim Final Rule is applicable for the duration of the PHE for COVID-19 and addresses several other issues. For example, “this IFC also announces that with respect to the Hospital VBP Program, HRRP, HAC Reduction Program, SNF VBP Program and the ESRD QIP, if, as a result of a decision to grant a new nationwide ECE without request or a decision to grant a substantial number of individual ECEs, we do not have enough data to reliably compare national performance on measures, we may propose to not score facilities based on such limited data or make the associated payment adjustments for the affected program year.” I strongly encourage key stakeholders take the time to read this document.

 

August 25, 2020: American Hospitals Association Statement on the Interim Final Rule

Rick Pollack, President and CEO of the American Hospital Association (AHA), released a statement in response to the release of the CMS Interim Final Rule on behalf of the AHA. Mr. Pollack indicated the “new heavy-handed regulatory approach put forward by the Administration threatens to expel hospitals from the Medicare program.”

The statement goes on to note that the government has made at least six changes to how they want hospitals to report data since February and in spite of this “94 percent – are reporting information, according to the federal government.”

 

August 25, 2020: CMS Launches National Training Program to Strengthen Nursing Home Infection Control Practices

CMS announced efforts to train frontline nursing home staff and nursing home management in a Press Release. These efforts will focus on the following topics that are critical to stopping the spread of COVID-19:

  • Infection control and prevention,
  • Appropriate screening of visitors,
  • Effective cohorting of residents,
  • Safe admission and transfer of residents, and
  • The proper use of personal protective equipment.

In addition to the scenario-based training called the “CMS Targeted COVID-19 Training for Frontline Nursing Home Staff and Management,” CMS and the CDC will also have subject matter experts available on biweekly webinars through January 7 from 4 to 5 pm ET, to answer questions.

 

August 26, 2020: Medicare Fee-For-Service (FFS) Response to the Public Health Emergency on COVID-19 MLN Matters Article SE20011 Revised

MLN SE20011 was most revised again for the fourteenth time since its initial release in March of this year. This revision was made to add information about the HCPCS codes for OPPS, Rural Health Clinics (RHCs), FQHC, and Critical Access Hospital (CAH) billers in the Families First Coronavirus Response Act Waives Coinsurance and Deductibles for Additional COVID-19 Related Services section.

 

August 26, 2020: Abbott’s 15-Minute, Easy to Use COVID-19 Test Received FDA Emergency Use Authorization (EUA)

Abbott announced the EUA authorization in a Press Release. The test approved is the BinaxNOW™ COVID-19 Ag Card rapid test which will sell for $5, “is highly portable (about the size of a credit card), affordable and provides results in 15 minutes. BinaxNOW uses proven Abbott lateral flow technology, making it a reliable and familiar format for frequent mass testing through their healthcare provider. With no equipment required, the device will be an important tool to manage risk by quickly identifying infectious people so they don't spread the disease to others.”

Along with the test, Abbott plans to launch a complimentary mobile app for iPhone and Android devices named NAVICA™. This app will:  

  • Be available at no charge,
  • Allow people testing negative to display the results, and
  • Organizations will be able to verify the negative test result to facilitate entry into their facility.

In a related FDA News Release, the FDA likens the design of the testing card to the design of some pregnancy tests and goes on to note the “simple design is fast and efficient for healthcare providers and patients and does not need the use of an analyzer.”

 

August 27, 2020: 150 Million Rapid COVID-19 Tests to be Deployed in 2020

One day after the FDA granted EUA for Abbott’s BinaxNow™ COVID-19 Ag Card, HHS posted a Press Release indicating that “the Administration awarded a contract for $760 million to Abbott for delivery of 150 million rapid, Abbott BinaxNOW COVID-19 Ag Card Point of Care (POC) SARS-CoV-2 diagnostic tests to expand strategic, evidence-based testing in the United States.  Testing will be potentially deployed to schools and to assist with serving other special needs populations.”

 

August 27, 2020: FDA Warns Consumers about Hand Sanitizer Packaged in Food and Drink Containers

The FDA notes in a News Release , “in one recent example of consumer confusion, the FDA received a report that a consumer purchased a bottle they thought to be drinking water but was in fact hand sanitizer. The agency also received a report from a retailer about a hand sanitizer product marketed with cartoons for children that was in a pouch that resembles a snack. Drinking only a small amount of hand sanitizer is potentially lethal to a young child, who may be attracted by a pleasant smell or brightly colored bottle of hand sanitizer.”

 

August 27, 2020: CMS Offers Comprehensive Support for Louisiana and Texas with Hurricane Laura

The CMS announced efforts to support Louisiana and Texas in response to Hurricane Laura. CMS notes that they have “provided numerous waivers to health care providers during the current coronavirus disease 2019 (COVID-19) pandemic to meet the needs of beneficiaries and providers. The waivers already in place will be available to health care providers to use during the duration of the COVID-19 PHE determination timeframe and for the Hurricane Laura PHE.  CMS may waive certain additional Medicare, Medicaid, and Children’s Health Insurance Program (CHIP) requirements, create special enrollment opportunities for individuals to access healthcare quickly, and take steps to ensure dialysis patients obtain critical life-saving services.”

 

August 28, 2020: Remdesivir Emergency Use Authorization Broadened to include All Hospitalized COVID-19 Patients

The FDA announced they have “broadened the scope of the existing emergency use authorization (EUA) for the drug Veklury (remdesivir) to include treatment of all hospitalized adult and pediatric patients with suspected or laboratory-confirmed COVID-19, irrespective of their severity of disease.” This announcement includes links to Fact Sheets for health care providers and patients regarding this use of remdesivir in treating COVID-19 patients.

Beth Cobb

COVID-19 in the News August 17th - 24th
Published on Aug 25, 2020
20200825

MMP remains committed to continuing to monitor for COVID-19 updates specific to our reader base. This week we highlight key updates spanning from August 17th through the 24th.

Resource Spotlight: OSHA Guidance on Preparing Workplaces for COVID-19

The Occupational Safety and Health Administration has published Guidance on Preparing Workplaces for COVID-19. This guide provides information about how a COVID-19 outbreak could affect workplaces, classifying worker exposure to SARS-CoV-2 and what to do to protect workers at low, medium and high or very high risk of exposure.

You can find additional guides made available by OSHA on their COVID-19 webpage at  https://www.osha.gov/SLTC/covid-19/.

 

August 17, 2020: Resumption of Routine Inspections, Updated Enforcement Guidance to States, and Toolkit for Nursing Homes

CMS announced in a Press Release that routine inspections of all Medicare and Medicaid certified providers and suppliers is set to resume. Inspections had been suspended in response to the COVID-19 pandemic. CMS directed the resumption of the following as soon as resources are available: 

  • Onsite revisit surveys,
  • Non-immediate jeopardy complaint surveys, and
  • Annual recertification surveys.

Additional actions included in the press release:

  • Guidance provided on resolving enforcement cases previously on hold because of survey prioritization changes, and
  • Temporary expansion of the desk review policy,
  • Guidance on the re-prioritization of routine state survey agency activities on Clinical Laboratory Improvement Amendments (CLIA),
  • Updates to the “Toolkit on State Actions to Mitigate COVID-19 Prevalence in Nursing Homes.”

 

August 19, 2020: HHS Expands Access to Childhood Vaccines during COVID-19 Pandemic

In an August 19th Press Release, HHS announced that a third amendment to the Declaration under the Public readiness and Emergency Preparedness Act (PREP Act) has been issued to increase access to childhood vaccines by authorizing State-licensed pharmacists (and pharmacy interns acting under their supervision to administer vaccines to individuals ages three through eighteen years. There are several requirements the pharmacist must meet. For example, “the licensed pharmacist must complete a minimum of two hours of ACPE-approved, immunization-related continuing pharmacy education during each State licensing period.”

HHS Secretary Alex Azar states in the announcement that “today’s action means easier access to lifesaving vaccines for our children, as we seek to ensure immunization rates remain high during the COVID-19 pandemic.”

 

August 19, 2020: FDA COVID-19 Daily Roundup: UV Lights and Lamps FAQs

In their August 19th COVID-19 Daily Roundup, the FDA announced the posting of FAQs for consumers about UV lights and lamps. The FAQs answer questions about the use of lamps for disinfection during the COVID-19 pandemic.

 

August 20, 2020: Kaiser Health News Article: Scam Alert: Things a COVID Contract Tracer Wouldn’t Say

This Kaiser Health News (KHN) article by Julie Appleby opens with letting readers know that, “State officials and federal agencies warn there’s a new phone scam circulating: Some callers posing as COVID-19 contact tracers try to pry credit card or bank account information from unsuspecting victims. This article provides examples of what scammers are trying and links to consumer alerts from several sources include the Federal Trade Commission and the Better Business Bureau among others.

 

August 21, 2020: Update to the ICD-10 Diagnosis Codes for Vaping Related Disorder and Diagnosis and Procedure Codes for the 2019 Novel Coronavirus (COVID-19) - MLN Article Revised

CMS first released MLN Matters article MM11623 on January 24, 2020. CMS revised this article on August 21, 2020. Now in its further iteration, the article has been revised to reflect an updated Change Request (CR) 11623 which updated the title, Background section and includes new procedure codes in Version 37.2 of the ICD-10 Medicare Severity - Diagnosis Related Groups (MS-DRG) Grouper and ICD-10 Medicare Code Editor (MCE). The CR release date, transmittal number and link to the transmittal also changed.

 

August 23, 2020: FDA Issues Emergency Use Authorization (EUA) for Investigational Convalescent Plasma to Treat COVID-19

The FDA indicated in a news release that “today’s action follows the FDA’s extensive review of the science and data generated over the past several months stemming from efforts to facilitate emergency access to convalescent plasma for patients as clinical trials to definitively demonstrate safety and efficacy remain ongoing.” The EUA requires that fact sheets providing information regarding the use of convalescent plasma in COVID-19 treatment be available to health care providers and patients

 

August 24, 2020: HHS Press Release – Health Plans added to June 2020 Plasma Donation Guidance

HHS announced in a Press Release that the Office of Civil Rights (OCR) has “issued amended guidance on how the Health Insurance Portability and Accountability Act of 1996 (HIPAA) Privacy Rule permits covered health care providers (e.g., hospitals, pharmacies, laboratories) and health plans to contact their patients and beneficiaries who have recovered from COVID-19 to inform them about how they can donate their plasma containing antibodies (known as "convalescent plasma") to help treat others with COVID-19.” This announcement includes a link to the amended guidance.

 

August 24, 2020: Quarterly Update for Clinical Laboratory Fee Schedule and Laboratory Services Subject to Reasonable Charge Payment – MLN Article Revised

CMS first released MLN Matters article MM11937 on August 7, 2020. This article was revised on August 24, 2020 to reflect an updated CR 11937 that includes additional COVID-19 codes 86408, 86409, 0225U and 0226U, effective August 10, 2020. CR 11937 also added codes 0015M and 0016M, effective October 1, 2020. The CR release date, transmittal number and link to the transmittal also changed.

Beth Cobb

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