Knowledge Base Category -

February 5, 2024: MLN MM13507: ICD-10 & Other Coding Revisions to National Coverage Determinations: July 2024 Update

Make sure your staff knows about newly available codes, recent code changes, and NCD coding information. https://www.cms.gov/files/document/mm13507-icd-10-other-coding-revisions-national-coverage-determinations-july-2024-update.pdf

February 5, 2024: MLN SE19007: Activation of Validation Edits for Providers with Multiple Service Locations – Revised

This special edition MLN article was originally released March 26, 2019. With this latest revision, CMS clarified how to hand certain off-campus provider-based departments excepted from Section 603 payment policy. https://www.cms.gov/outreach-and-education/medicare-learning-network-mln/mlnmattersarticles/downloads/se19007.pdf

February 12, 2024: MLN MM13513: Pulmonary Rehabilitation, Cardiac Rehabilitation, & Intensive Cardiac Rehabilitation Expansion of Supervising Practitioners

Make sure your billing staff knows about updates to the above-mentioned rehabilitation services effective January 1, 2024, including expanding the types of practitioners who may supervise these services. https://www.cms.gov/files/document/mm13513-pulmonary-rehabilitation-cardiac-rehabilitation-intensive-cardiac-rehabilitation-expansion.pdf

February 15, 2024: Limitation on Recoupment of Medicare Overpayments

Limitation on recoupment of Medicare overpayments is during the first and second level of appeal only. Make sure your staff knows about this limit, when to request an extended repayment plan (ERS) or choose immediate recoupment, and how CMS pays interest on overpayments. https://www.cms.gov/files/document/mm11808-limitation-recoupment-medicare-overpayments.pdf

February 21, 2024: MLN MM13485: Appropriate Use Criteria (AUC) for Advanced Diagnostic Imaging: CY 2024 Update

Make sure your billing staff knows about CMS rescinding the AUC program regulations, the program has been paused for reevaluation, and elimination of AUC consultation information on Medicare Fee-for-Service claims. https://www.cms.gov/files/document/mm13485-appropriate-use-criteria-advanced-diagnostic-imaging-cy-2024-update.pdf

February 22, 2024: MLN MM13451: Clinical Laboratory Fee Schedule & Laboratory Services Reasonable Charge Payment: Quarterly Update

Make sure your billing staff knows when the next private payor data reporting period is and new and deleted HCPCS codes. https://www.cms.gov/files/document/mm13541-clinical-laboratory-fee-schedule-laboratory-services-reasonable-charge-payment-quarterly.pdf

January 17, 2024: Acute Care Hospitals Required to join Joint Commission NHSN Group

Effective July 1, 2024, acute care hospitals with ORYX® performance measurement requirements and that are required through a CMS program to participate in the CDC National Healthcare Safety Network (NHSN) system will be required to join the Joint Commission NHSN Group.

The Joint Commission indicated in their announcement that “In April 2024 The Joint Commission will e-mail the primary accreditation contact on file for the organization to determine the appropriate contact person to correspond with regarding the Joint Commission NHSN Group. After the contract has been identified, detailed instructions for joining the Group will be provided, and onboarding will take place May through June 2024.”

February 1, 2024: April 1, 2024 ICD-10-CM Updates

CMS notes the ICD-10-CM April 1, 2024 update addresses typographical errors and there are no new diagnosis codes being implemented. You will find downloads for discharges on and after April 1, 2024 on the 2024 ICD-10-CM webpage including an update ICD-10-CM Official Guidelines for Coding and Reporting that includes a few updates, for example on page 29 of this document a new subsection (f) Screening for COVID-19 has been added which provides the following guidance “for screening for COVID-19, including preoperative testing, assign code Z11.52, Encounter for screening for COVID-19.”

February 7, 2024: New Steps to Transform the Organ Transplant System

HHS issued a Press Release announcing that the Health Resource and Services Administration (HRSA) “is taking historic steps as part of its Organ Procurement and Transplantation Network (OPTN) Modernization Initiative, leveraging new legal authority…signed into law as part of the Securing the U.S. Organ Procurement and Transplantation Network Act in September 2023.  HRSA actions include:  

• Releasing a contract solicitation to break up the OPTN monopoly and create an independent OPTN Board of Directors,
• Issuing a multi-vendor contract solicitation to support broad competition and best-in-class vendors for critical OPTN functions,
• Launching the discovery and development phase of the transition to a modernized OPTN IT matching system, and
• Taking action to address “pre-waitlist” inequities in the organ waitlist process and reduce variations in referrals to transplant and in organ procurement practices.

February 8, 2024: CMS Reminds Providers about the Jimmo Settlement Agreement

CMS reminded providers in the Thursday, February 8, 2024 edition MLN Connects that “Medicare covers skilled nursing care and skilled therapy services under skilled nursing facility, home health, and outpatient therapy benefits when a beneficiary needs skilled care to maintain function or to prevent or slow decline, as long as:

• The beneficiary requires skilled care for the services to be provided safely and effectively.
• An individualized assessment of the patient's condition demonstrates that the specialized judgment, knowledge, and skills of a qualified therapist are needed for a safe and effective maintenance program.

Note, on February 13, 2024, CMS sent a letter to all Medicare Advantage Organizations reminding them about the Jimmo Settlement Coverage and Training Policies. https://leadingage.org/wp-content/uploads/2024/02/HPMS-Memo_-Jimmo-Settlement_508.pdf

February 8, 2024: Accrediting Organization (AO) Proposed Rule

CMS published a proposed rule and related Fact Sheet noting that “CMS’s annual AO oversight Reports to Congress (RTCs) highlight the agency’s significant concerns regarding AO performance that need to be addressed.” Comments can be submitted until April 15, 2024.

February 8, 2024: Texting of Patient Information and Orders for Hospitals and CAHs Memorandum

Did You Know?

Through the Medicare Learning Network (MLN), CMS has developed an interactive education tool titled Medicare Preventive Services (MLN006559 January 2024). This tool is meant to help providers properly provide and bill Medicare prevention services (i.e., bone mass measurement, colorectal screening, lung cancer screening).

For each Preventive Service listed in the tool, you will find the following information as applicable to the service:

• National Coverage Determination (NCD),
• HCPCS and CPT codes specific to the service provided,
• ICD-10-CM diagnosis codes,
• Telehealth eligibility,
• Coverage requirements,
• Frequency requirements, and
• Medicare Beneficiary (patient) cost sharing.

   

  You will also find answers to the following questions:

• How do I determine the last date a patient got a preventive service, so I know if they’re eligible to get the next service and it won’t deny due to frequency edits?
• When can CMS add new Medicare preventive services?
• My patients don’t follow up on routine preventive care. How can I help them remember when they’re due for their next preventive service?
  • CMS provides a link to a Preventive Services Checklist that you can give your patients.
  • Note, CMS also highlights preventive services with an apple in the official U.S. government Medicare Handbook, Medicare and You. You will find information about preventive services in the 2024 Edition of this handbook on pages 30-55.
• What’s a primary care setting?

   

  Why It Matters?

  This tool was revised in January 2024. Following are two examples of what has been revised:  

   

  Annual Wellness Visit

  New HCPCS code G0136 (Administration of a standardized, evidence-based social determinants of health risk assessment tool, 5-15 minutes) has been added as well as the following “Other Notes:”

• The implementation date for SDOH Risk Assessment claims is July 1, 2024,
• The billing HCPCS code is G0136,
• Add modifier 33 to an SDOH, G0136, performed on the same day as the Annual Wellness Visit to waive copayment and deductible,
• G0136 is covered once a year with copayment and deductible waived, and
• The AWV can be an optional community health integration (CHI) initiating visit when the provider identifies any unmet SDOH needs that prevent the patient from doing the recommended personalized prevention plan.

Flu Shot

Starting January 1, 2024, Medicare pays an additional payment for in-home flu shot administration under certain circumstances.

What Can You Do?

• Read all the revisions made to this tool in January in the February 15, 2024 edition of MLN Connects,
• Use this tool to identify service specific applicable coverage requirements (NCD), HCPCS/CPT codes, and ICD-10-CM diagnosis codes, and
• Share this tool with key stakeholders at your facility.

Did You Know?

Livanta, the National Medicare Claim Review Contractor, samples claims for review monthly for short stay reviews (SSRs) and higher weighted DRG (HWDRG) reviews. As part of their Provider Education efforts, they publish a monthly newsletter called The Livanta Claims Review Advisor.

The first Claims Review Advisor newsletter was published two years ago this month in February 2022. Livanta noted in that newsletter that it is meant “to share its review findings and provide guidance to healthcare organizations…each month’s content will highlight areas of interest for medical coders, billing professionals, clinical documentation improvement (CDI) professionals, physicians, and other practitioners.” Topics alternate between SSRs and HWDR reviews each month.

Why It Matters?

Livanta recently released the January 2024 edition of The Livanta Claims Review Advisor with a focus on SSRs for electrolyte abnormalities. You will find error rates by MS-DRG, example scenarios of specific electrolyte abnormalities (i.e., hyperglycemic emergencies), and guidance for documenting “the reasonableness of a two-midnight expectation at the time of inpatient admission: regardless of the MS-DRG.

Error Rates

Overall, Livanta completed 1,985 reviews for dates of service from October 2021 through December 2023 for the following MS-DRGs:

• MS-DRG 637: Diabetes with MCC,
• MS-DRG 638: Diabetes with CC,
• MS-DRG 639: Diabetes without CC/MCC,
• MS-DRG 640: Miscellaneous Disorders of Nutrition, Metabolism, Fluids and Electrolytes with MCC (error rate 10.20%), and
• MS-DRG 641: Miscellaneous Disorders of Nutrition, Metabolism, Fluids and Electrolytes without MCC.

MS-DRG 641 had the highest reported error rate at 11.60%.

How Big is the Pool of Claims?

Based on claims data provided by our sister company RealTime Medicare Data (RTMD), in the CMS FY 2023 (October 1, 2022 through September 30, 2023) for all fifty states and Washington D.C. combined, there were 73,497 claims that grouped to one of the above MS-DRGs. The total payment made to providers for this group of claims was $481,535,832.43.

Note, claims with a discharge disposition of expired (20), transfer to another acute care facility (02), transfer to a short-term general hospital with planned acute hospital inpatient readmission (82), left against medical advice (07), and hospice election (50 & 51) have been excluded from this data as CMS considers these to be “unforeseen circumstances.” I have included MS-DRG specific claims data in the table at the end of this article.

What Can You Do?

• Read the January 2024 of The Livanta Claims Review Advisor and share with key stakeholders at your facility.
• Review a sample of short stay claims to determine if documentation supported the inpatient admission or if care could have been provided on an outpatient basis.
• View past editions of this newsletter at https://www.livantaqio.cms.gov/en/ClaimReview/Provider/provider_education.html, and
• If you have not signed up to received Livanta’s publications, I encourage you to do so at https://www.livantaqio.cms.gov/en/ClaimReview/Provider/bulletin.html.

Resources

Change Request CR10080 and related MLN MM10080: Clarifying Medical Review of Hospital Claims for Part A Payment

Question

Documentation in the record revealed the patient had Celiac Artery Stenosis. The encoder assigned Celiac Artery Compression Syndrome (I77.4) which was not documented in the record. Is code I77.4 the correct code for Celiac Artery Stenosis?

Answer

No, because Celiac Artery Compression Syndrome is compression caused by a fibrous band of the diaphragm and is not the same as Celiac Artery Stenosis.  The appropriate code for Celiac Artery Stenosis is Stricture of an Artery (I77.1). Coding Clinic advises to search for the more appropriate code if the code title assigned from the Index does not correctly describe the condition.

Resources:

National Library of Medicine

Coding Clinic, 3Q 2021, page 12

Compliance Education Updates

December 2023: MLN Booklet: Global Surgery

CMS has updated this MLN booklet to include the instructions for critical care visits that are unrelated to the surgical procedure and performed post-operatively, report modifier -FY. https://www.cms.gov/files/document/mln907166-global-surgery-booklet.pdf

Other Updates

January 18, 2024: CMS Adds Utilization Data on Medicare.gov for the First Time

CMS noted in the Friday January 26 edition of CMS Roundup that they have “added utilization data, specifically procedure volume, for the first time on the Medicare.gov compare tool’s profile pages for doctors and clinicians…this is the latest example of CMS’ transparency efforts to ensure the compare tool on Medicare.gov provides patients and caregivers with information about services they may value as they search for clinicians.”

The dataset is currently published in the Provider Data Catalog. The initial list of procedures includes hip and knee replacement, spinal fusion, cataract surgery, colonoscopy, open hernia repair of the groin, minimally invasive hernia repair, mastectomy, CABG, pacemaker insertion or repair, coronary angioplasty and stenting, and prostate resection.

You can read more about this data release in a CMS Fact Sheet at https://www.cms.gov/files/document/utilization-procedure-volume-data-published-compare-tool-medicaregov-fact-sheet-195-kb.pdf.

January 22, 2024: New EMTALA Resources

CMS announced in a Press Release that they are launching “a series of actions to educate the public about their rights to emergency medical care and to help support the efforts of hospitals to meet their obligations under the Emergency Medical Treatment and Labor Act (EMTALA).” One action CMS has taken is to publish new informational resources on their website at https://www.cms.gov/priorities/your-patient-rights/emergency-room-rights. You can read the entire press release at https://www.cms.gov/newsroom/press-releases/cms-announces-new-actions-help-hospitals-meet-obligations-under-emtala.

New Kepro Email Addresses

In the January 2024 edition of Case Review Connections, Kepro lets providers know that Kepro recently became a part of the Acentra health family, and you may notice some changes in email addresses, moving to acentra.com. They do not anticipate any other changes at this time and will provide guidance in the future of any potential required changes. You can sign up for this newsletter on the Kepro website at https://www.keproqio.com/newsletters.

January 24, 2024: HHS Releases Voluntary Cybersecurity Goals for the Health Sector & New Gateway Website

HHS announced the release of “voluntary health care specific cybersecurity performance goals (CPGs) and a new gateway website to help Health Care and Public Health (HPH) sector organizations implement these high-impact cybersecurity practices and ease access to the plethora of cybersecurity resources HHS and other federal partners offer.” https://aspr.hhs.gov/newsroom/Pages/HHS-Releases-CPGs-and-Gateway-Website-Jan2024.aspx

Medicare Transmittals & MLN Articles

December 21, 2023: MLN MM13496: Billing Requirements for Intensive Outpatient Program Services under New Condition Code 92

Starting January 1, 2024, CMS requires the use of new condition code 92 on all Intensive Outpatient Program (IOP) claims from hospitals and Community Mental Health Centers (CMHCs). Make sure your billing staff knows about billing this new condition code and Medicare manual changes related to providing IOP services. https://www.cms.gov/files/document/mm13496-billing-requirements-intensive-outpatient-program-services-new-condition-code-92.pdf

December 26, 2023: MLN MM13222: New Condition Code 92: Billing Requirements for Intensive Outpatient Program Services

CMS advises that you make sure your billing staff knows about this new code, that an OPPS provider will get paid per diem payments for this service, the intensity of services required for Medicare to cover and pay for this service, and the outpatient settings this billing requirement is applicable to. https://www.cms.gov/files/document/mm13222-new-condition-code-92-billing-requirements-intensive-outpatient-program-services.pdf

January 3, 2024: MLN MM13481: Ambulatory Surgical Center Payment System: January 2024 Update - Revised

This MLN article was revised to change the number of HCPCS codes in Tables 8 and 10 and update the web address of the Change Request (CR) transmittal. https://www.cms.gov/files/document/mm13481-ambulatory-surgical-center-payment-system-january-2024-update.pdf

January 9, 2024: MLN MM13503: Specimen Collection Fees and Travel Allowance: 2024 Update

This MLN article provides updated information about the specimen collection fees and travel allowances for 2024 and other policy updates and reminders. https://www.cms.gov/files/document/mm13503-specimen-collection-fees-and-travel-allowance-2024-update.pdf

January 10, 2024: MLN MM13488: Hospital Outpatient Prospective Payment System: January 2024 Update

Make sure your billing staff is aware of the system updates effective January 1, 2024, for example:  

• COVID-19 vaccine and administration codes,
• Covered devices for pass-through payments,
• Inpatient-only list (IPO) updates, and
• Services: Covered dental rehabilitation procedures, Marriage and Family Therapist (MFT), and Mental health counselor (MHC),

https://www.cms.gov/files/document/mm13488-hospital-outpatient-prospective-payment-system-january-2024-update.pdf

January 16, 2024: MLN MM13264: Billing Requirements for Intensive Outpatient Program Services for Federally Qualified Health Centers and Rural Health Clinics

Make sure your billing staff knows about the Intensive Outpatient Program (IOP) scope of benefits, certification and plan of care requirements, payment policies, and coding and billing requirements. https://www.cms.gov/files/document/mm13264-billing-requirements-intensive-outpatient-program-services-federally-qualified-health.pdf

January 18, 2024: MLN MM13473: How to Use the Office and Outpatient Evaluation and Management Visit Complexity Add-on Code G2211

CMS advises that you make sure your billing staff knows about the correct use of HCPCS code G2211 and modifier 25, documentation requirements for G2211, and patient coinsurance and deductible. https://www.cms.gov/files/document/mm13473-how-use-office-and-outpatient-evaluation-and-management-visit-complexity-add-code-g2211.pdf

Related MLN Matters article MM13272 was revised on December 21, 2023. CMS advises in this article that you make sure your billing staff knows about complexity add-on code G2211. https://www.cms.gov/files/document/mm13272-edits-prevent-payment-g2211-office/outpatient-evaluation-and-management-visit-and-modifier.pdf

January 18, 2024: MLN MM13480: Refillable DMEPOS Documentation Requirements

Make sure your staff knows about the updated documentation requirements for refillable DMEPOS and the requirement to contact the patient before refilling DMEPOS.  https://www.cms.gov/files/document/mm13480-refillable-dmepos-documentation-requirements.pdf

The Program for Evaluating Payment Patterns Electronic Report or PEPPER is one resource available to providers to help guide your selection of meaningful review targets for audits. According to the PEPPER User’s Guide for Short-Term Acute Care, this report “contains a single hospital’s claims data statistics for Medicare-Severity Diagnosis-Related Groups (MS-DRGs) and discharges at risk for improper payment due to billing, coding, and/or admission necessity issues…All of the data tables, graphs, and reports in PEPPER were designed to assist the hospital in identifying potential overpayments as well as potential underpayments.”

If you attempted to access the PEPPER Resources website in December 2023, you were directed to a blank page. This week I once again checked this website and the following notice has been posted:

“Updates to the Program for Comparative Billing Reports (CBRs) and Evaluating Payment Patterns Electronic Report (PEPPERs) Coming Soon

There will be a temporary pause in distributing CBRs and PEPPERs as CMS works to improve and update the program and reporting system. This pause will remain in effect through the fall of 2024. We recognized the importance of these reports to your practice. Therefore, during this time, CMS will be working diligently to enhance the quality and accessibility of the reports. In fulfilling this commitment, your feedback is requested. In the near future, CMS will release a Request for Information (RFI) to obtain information from you, the provider community, about how the program can better serve you.

Please visit CBR and PEPPER website for periodic updates. If you have further questions please send them to Medicaremedicalreview@cms.hhs.gov.”

About CBRs

Question

A patient was transferred from a nursing home with a Foley and was found to have a UTI upon admission.  Should we always query to see if the UTI was caused by the Foley catheter?

Answer

Yes.  Patients that have an indwelling catheter are susceptible to bacteria in the urine and UTIs.  If the UTI was caused by the Foley, code T83.511A (Infection and inflammatory reaction due to indwelling urethral catheter, initial encounter) should be assigned as the principal diagnosis.  A code for the UTI should also be assigned as a secondary diagnosis.  A catheter-associated urinary tract infection is also called a (CAUTI).  Coding the CAUTI as the principal diagnosis may also affect the DRG assignment.

It’s good practice to review the chart for supporting evidence of the presence of a Foley catheter or another kind of urinary catheter/device, when a UTI is diagnosed. 

References:

Merck Manual

AHA Coding Handbook

Question:

Are there any updates for rehabilitative therapy services’ threshold amounts for the coming year?

Answer:

Yes. Change Request (CR) 13371 issued September 14, 2023 and re-communicated November 6, 2023 updates the annual per-beneficiary incurred expenses amounts now called the KX modifier thresholds and related policy for CY 2024. These thresholds were previously known as “therapy caps.”

CY 2024 KX Modifier Threshold Amounts

1. $2,330 for Physical Therapy (PT) and Speech-Language Pathology (SLP) services combined, and
2. $2,330 for Occupational Therapy (OT) services.

Providers can track a patient’s year-to-date therapy amounts on Medicare eligibility screens. The KX modifier must be appended to therapy services’ line-items on the claim for medically necessary therapy services above the threshold amounts. The medical necessity of services beyond the threshold amount must be justified by appropriate documentation in the medical record. Services provided beyond the threshold that are not billed with the KX modifier will be denied with Claim Adjustment Reason Code 119 - Benefit maximum for this time period or occurrence has been reached.

There is also a therapy threshold related to the targeted medical review process, now known as the Medical Record (MR) threshold amount. This threshold remains at $3,000 for PT and SLP combined and a separate $3,000 for OT until CY 2028.

Resource

CR 13371: https://www.cms.gov/files/document/r12249cp.pdf