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Prostate awareness
Published on Sep 08, 2021
20210908
Question

We do ultrasound guided prostate biopsies in Radiology and report the ultrasound guidance with CPT code 76742. To report CPT code 76942, should we maintain permanently recorded images?

Answer

Yes, per the parenthetical guidelines in the Diagnostic Ultrasound section of the CPT book, permanently recorded images must be maintained for ultrasound guidance. The physician should also document the use of ultrasound guidance. This documentation can be included in the biopsy report or can be documented as a separate report. Typically, we see only one physician’s report that describes both the prostate needle biopsy as well as the ultrasound guidance.

Jeffery Gordon

August 2021 Medicare Transmittals and Coverage Updates
Published on Aug 25, 2021
20210825

Medicare MLN Articles & Transmittals – Recurring Updates

New Waived Tests
  • Article Release Date: August 9, 2021
  • What You Need to Know: This MLN article lists the six latest tests approved by the FDA as waived tests under CLIA. CMS reminds you that the CPT codes for the new tests must have the modifier QW to be recognized as a waived test.
  • MLN MM12381: (link)
Inpatient Psychiatric Facilities Prospective Payment System (IPF PPS) Updates for Fiscal Year (FY) 2022
  • Article Release Date: August 12, 2021
  • What You Need to Know: This article highlights key changes in the FY 2022 IPF PPS.
  • MLN MM12417: (link)
Medicare Part A Skilled Nursing Facility (SNF) Prospective Payment System (PPS) Pricer Update FY 2022
  • Article Release Date: August 10, 2021
  • What You Need to Know: This article provides information related to the SNF payment for rates for FY 2022.
  • MLN MM12366: (link)
Inpatient Rehabilitation Facility (IRF) Annual Update: Prospective Payment System (PPS) Pricer Changes for FY 2022
  • Article Release Date: August 12, 2021
  • What You Need to Know: This article includes information regarding rate updates for PPS IRFs for FY 2022.
  • MLN MM12364: (link)

Other Medicare MLN Articles & Transmittals

Modifications/Improvements to Value-Based Insurance Design (VBID) Model – Implementation
  • Article Release Date: August 9, 2021
  • What You Need to Know: This article alerts you to Change Request (CR) 11754 – Transmittal 10170, which replaces the May 8, 2020, Transmittal 10127. This was done to add a note to the effective date and to revise the background section and business requirements, 11754.3. All other information remains the same.
  • MLN MM 12349: (link)
Update of Internet Only Manual (IOM), Pub. 100-04, Chapter 8 – Outpatient ESRD Hospital, Independent Facility, and Physician/Supplier Claims
  • Article Release Date: August 9, 2021
  • What You Need to Know: This article provides a quick summary of updates to the Medicare Claims Processing Manual, Chapter 8 – Outpatient ESRD Hospital, Independent Facility, and Physician/Supplier Claims. Complete reviews can be found in related Change Request (CR) 12079.
  • MLN MM12079: (link)
Internet Only Manual Updates to Publication (Pub.) 100-02 to Implement Updates to Policy and Correct Errors and Omissions (Inpatient Rehabilitation Facility (IRF))
  • Article Release Date: August 9, 2021
  • What You Need to Know: This article tells you about updates to Chapter 1, Section 110 (IRF Services) of the Medicare Benefit Policy Manual.
  • MLN MM12353: (link)
Internet Only Manual Updates to Pub. 100-01, 100-02, and 100-04 to Implement Consolidated Appropriations Act Changes and Correct Errors and Omissions (SNF)
  • Article Release Date: August 9, 2021
  • What You Need to Know: Changes made clarify existing content. CMS notes in this MLN article that no policy, processing, or system changes are anticipated.
  • MLN MM12009: (link)
Implementation of the GV Modifier for Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) for Billing Hospice Attending Physician Services
  • Article Release Date: August 11, 2021
  • What You Need to Know: Effective January 1, 2022, an RHC or FQHC can bill and receive payment under the RHC All-Inclusive Rate (AIR) or FQHC Prospective Payment System (PPS), respectively, when their employed and designated attending physician provides services during a patient’s hospice election. This article provides detail regarding the required modifier to receive payment in both settings.
  • MLN MM12357: (link)
Skilled Nursing Facility (SNF) Claims Processing Updates
  • Article Release Date: August 11, 2021
  • What You Need to Know: This article highlights changes to correct claims processing edits applicable to the FISS and CWF in CR 12344.
  • MLN MM12344: (link)

Revised Medicare MLN Articles & Transmittals

National Coverage Determination (NCD) Removal
  • Article Release Date: Initial article May 24, 2021 – 3rd Revision August 3, 2021
  • What You Need to Know: The MLN Article was revised to reflect the CR 12254 revisions made to the spreadsheet for NCD 20.5 and NCD 220.6.16.
  • MLN MM12254: (link)

Medicare Coverage Updates

August 11, 2021: Proposed Decision Memo for Transvenous (Catheter) Pulmonary Embolectomy (CAG-00457R)

The CMS released Proposed Decision Memo CAG-00457R (link) proposing to remove the NCD for Transvenous Pulmonary Embolectomy (NCD 240.6) and allow for Medicare coverage determinations to be made by Medicare Administrative Contractors (MACs). The public comment period ends on September 10, 2021. You can follow the progress of this proposed decision memo on the related National Coverage Analysis (NCA) tracking sheet (link).

Beth Cobb

COVID-19 & Other Medicare Updates - August 2021
Published on Aug 25, 2021
20210825

COVID-19 Updates

August 12, 2021: FDA Authorized Additional Vaccine Dose for Certain Immunocompromised Individuals

The FDA has amended the emergency use authorization (EUA) for the Pfizer-BioNTech COVID- 19 Vaccine and the Moderna COVID-19 Vaccine to allow for additional doses “in certain immunocompromised individuals, specifically, solid organ transplant recipients or those who are diagnosed with conditions that are considered to have an equivalent level of immunocompromise.” (link). CMS updated their COVID-19 webpage on August 13, 2021 (link), to reflect that they will pay the same amount to administer this additional dose as they did for the other doses (approximately $40 each). .

August 16, 2021: Actemra® (Tocilizumab) Supply Shortage

Genentech released a statement (link) indicating that due to “the unprecedented surge in worldwide demand and supply constraints driven by Delta variant spikes in much of the rest of the world that preceded the current situation in the U.S., has led to a global shortage of Actemra® (tocilizumab) supply for at least the next several weeks…This new wave of the pandemic has led to Genentech experiencing an unprecedented demand for Actemra IV-- well-over 400% of pre-COVID levels over the last two weeks alone and it continues to increase.”

August 18, 2021: COVID-19 Booster Shots

The U.S. Department of Health and Human Services (HHS) published a Press Release (link) regarding the need for COVID-19 booster shots. Specifically, data has shown that protection from vaccination begins to decrease over time and they have a plan to begin offering booster shots “subject to FDA conducting an independent evaluation and determination of the safety and effectiveness of a third dose of the Pfizer and Moderna mRNA vaccines and CDC’s Advisory Committee on Immunization Practices.”

Other Updates

July 19, 2021: CY 2022 Medicare Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System Proposed Rule (CMS-1753-P) – Hospital Price Transparency

The September 17, 2021 deadline to comment on the CY 2022 OPPS and ASC Payment System Proposed Rule is fast approaching. In a related CMS Fact Sheet (link), CMS noted several proposed “modifications designed to increase compliance and reduce hospital burden beginning January 1, 2022.” One key proposal for hospitals to be aware of is the proposed increase in Civil Monetary Penalties (CMP) for non-compliance with the Hospital Price Transparency rule. Specifically, CMS has proposed the following:

  • Set a minimum CMP of $300/day that would apply to smaller hospitals with a bed count ≤30, and
  • Apply a penalty of $10/bed/day for hospitals with a bed count >30, not to exceed a maximum daily dollar amount of $5,500.

Under the proposed increases, the new penalty for a full year of noncompliance would be a minimum of $109,500 per hospital and a maximum total penalty of $2,007,500 per hospital.

August 11, 2021: Hospital Price Transparency Stakeholder Webinar

This CMS webinar focused on how to meet the requirements of the Hospital Price Transparency Final Rule (link) for posting standard charge information in a comprehensible machine-readable file (link). CMS experts reviewed 8 steps to a Machine-Readable File of All & Services and provided hospital compliance examples. For those that missed this event, a pdf copy of this presentation is available on the Hospital Price Transparency Resources web page (link). (link)

July 2021 Medicare Transmittals and Coverage Updates
Published on Jul 28, 2021
20210728

Medicare MLN Articles & Transmittals – Recurring Updates

July Quarterly Update for 2021 Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) Fee Schedule
  • Article Release Date: July 2, 2021
  • What You Need to Know: This article provides information about changes to the DMEPOS fee schedule that is updated on a quarterly basis. Key points in Change Request 12345 are related to The Coronavirus Aid, Relief, and Economic Security (CAREs) Act, 2020 as it relates to DMEPOS.
  • MLN MM12345: (link)
October 2021 Quarterly Average Sales Price (ASP) Medicare Part B Drug Pricing Files and Revisions to Prior Quarterly Pricing Files
  • Article Release Date: July 15, 2021
  • What You Need to Know: This article talks about the ASP methodology, which CMS bases on quarterly data submitted to them by manufacturers.
  • MLN MM12342: (link)
Changes to the Laboratory National Coverage Determination (NCD) Edit Software for October 2021
  • Article Release Date: July 15, 2021
  • What You Need to Know: This article is related to Change Request 12384 which announced the changes that will be included in the October 2021 quarterly release of the edit module for clinical diagnostic laboratory services.
  • MLN MM12384: (link)
Quarterly Update to the National Correct Coding Initiative (NCCI) Procedure-to-Procedure (PTP) Edits, Version 27.3, Effective October 1, 2021
  • Article Release Date: July 14, 2021
  • What You Need to Know: Change Request (CR) 12340 provides quarterly updated to the NCCI PTP edits.
  • MLN MM12340: (link)

Other Medicare MLN Articles & Transmittals

Section 50 in Chapter 30 of Publication (Pub.) 100-04 Manual Updates: ABNs
  • Article Release Date: July 14, 2021
  • What You Need to Know: This article alerts providers about key changes being made to Chapter 30, Section 50 of the Medicare Claims Processing Manual related to Advance Beneficiary Notices of Non-coverage (ABNs). One key revision listed is the period of effectiveness of the ABN for repetitive or continuous non-covered care.
  • MLN MM12242: (link)

Revised Medicare MLN Articles & Transmittals

National Coverage Determination (NCD 110.24): Chimeric Antigen Receptor (CAR) T-cell Therapy – This CR Rescinds and Fully Replaces CR 11783
  • Article Release Date: Initial article May 24, 2021 – 2nd Revision July 21, 2021
  • What You Need to Know: The revised change request added CPT code C9076 (Breyanz). The implementation date was also revised to September 20, 2021. Breyanz joins a list of other CAR T-cell therapies including Kymriah®, Yescarta®, Tecartus™, and ABECMA®.
  • MLN MM12177: (link)

Medicare Coverage Updates

July 12, 2021: National Coverage Analysis (NCA) for Monoclonal Antibodies Directed Against Amyloid for the Treatment of Alzheimer’s Disease

July 12, 2021: National Coverage Analysis (NCA) for Monoclonal Antibodies Directed Against Amyloid for the Treatment of Alzheimer’s Disease On June 7, 2021, The FDA approved, using accelerated approval, aducanumab (brand name Aduhelm™) with an indication for the treatment of Alzheimer’s disease. Aducanumab is a monoclonal antibody directed against amyloid beta to reduce amyloid accumulations. CMS has initiated a national coverage determination (NCD) analysis (link) and is requesting public comments to several questions.

Medicare Educational Resources

Critical Access Hospital MLN Booklet Revised

JCMS recently revised the MLN Booklet (link) to include changes related to the COVID-19 Public Health Emergency (PHE). Specifically:

  • CAH temporary emergency coverage without a qualifying hospital stay due to COVID-19 PHE, and
  • Waiving the limitation on number of swing beds (25) and Length of Stay of 96 hours during the COVID-19 PHE.

COVID-19 Updates

Medicare COVID-19 Snapshot Updates

CMS updated their Medicare COVID-19 Data Snapshot slides (link) on June 30, 2021, to provide insight on the Medicare population from January 1, 2020 – April 24, 2021. With this update, data shows that there have been over 4.3 million COVID-19 cases and over 1.2 million COVID-19 hospitalizations.

OIG Fraud Alert: COVID-19 Scams

On July 21, 2021, the OIG updated their Fraud Alert: COVID-19 Scam’s webpage (link). You can find a short YouTube video highlighting 5 things about COVID-19 fraud and tips to protect yourself. For example, “offers to purchase COVID-19 vaccination cards are scams. Valid proof of COVID-19 vaccination can only be provided to individuals by legitimate providers administering vaccines.”

July 19, 2021: COVID-19 PHE Extended

In case you missed it in a recent Wednesday@One article, On July 19, 2021, Xavier Becerra, Secretary of Health and Human Services, renewed the PHE effective July 20, 2021 (link).

Other Updates

CY 2022 Medicare Physician Fee Schedule Proposed Rule

CMS issued this proposed rule on July 13, 2020 (link). Examples of what is being proposed includes:

  • Proposals related to telehealth services added during the COVID-19 PHE and a proposal to require use of a new modifier for telehealth services furnished using audio-only communications,
  • Proposal to make direct payments to Physician Assistants (PAs) for professional services furnished under Part B beginning January 1, 2022, and
  • Proposal to begin the payment penalty phase of the Appropriate Use Criteria (AUC) Program on the later of January 1, 2023, or the January 1 that follows the declared end of the PHE for COVID-19.

You can read additional highlights from the proposed rule in a related CMS Fact Sheet (link).

Beth Cobb

July 2021 Pro Tips: Prior Authorization for Certain Hospital Outpatient Department (OPD) Services
Published on Jul 21, 2021
20210721

Welcome to the second monthly edition of MMP’s P.A.R. Pro Tips. For those new to the Wednesday@One, MMP has collaborated with RealTime Medicare Data (RTMD), to develop a proprietary Protection Assessment Report (P.A.R.). This report is a combination of current Medicare Fee-for-Service review targets with hospital specific Medicare Fee-For-Service paid claims data. As a bonus to our Wednesday@One readers, we have begun to provide useful “Did You Know” information that we come across in our ongoing review of key websites (i.e., Medicare Administrative Contractors (MACs), OIG, Recovery Auditors, etc.)

Did You Know?

The Prior Authorization for Certain Hospital OPD Services was implemented effective July 1, 2020. On July 1, 2021, two additional services were added to the list of services requiring prior authorization (Spinal Neurostimlators and Cervical Fusion with Disc Removal). The full list of HCPCS codes requiring prior authorization is available on the CMS webpage dedicated to this process (link).

Pro Tip: MAC Education

MACs nationwide have been providing education to providers regarding this program and more specifically the two new services that have been added to the list of services requiring prior authorization. Following is a sampling of information available for hospital outpatient departments:

CGS (Jurisdiction 15)

CGS’ OPD Prior Authorization webpage (link) walks providers through the process of submitting a prior authorization request, outlines medical record documentation requirements to meet coverage criteria, provides a detailed exemption process timeline, and information about claims submission and appeals. There are also several “NOTES” included throughout this webpage, for example:

  • “Although other providers, such as a physician/staff may submit a PAR on the hospital OPD’s behalf, departmental collaboration is crucial.”
  • “A PAR is valid for one claim/date of service.” Unlike MMP’s Protection Assessment Report (P.A.R.), the PAR related to this CMS program is an acronym for Prior Authorization Request.

    First Coast Service Options, Inc. (Jurisdiction N)

    In late June, First Coast modified their article Vein ablation and related services (link). This article includes:

    • Clinical definitions of veins, varicose veins, endovenous ablation, and chronic venous insufficiency,
    • Applicable HCPCS codes,
    • Documentation requirements,
    • Best practice/documentation feedback/tips and help,
    • Billing and coding alerts, and
    • References, including links to applicable Local Coverage Determination (LCD) and related Local Coverage Article (LCA).

    First Coast also released an updated Prior Authorization (PA) program Q&A document (link) on July 15th.

    National Government Services (NGS Jurisdiction K)

    On July 7, 2021, NGS posted an Outpatient Department Prior Authorization for Implanted Neurostimulators Alert (link). The alert begins by reminding providers that HCPCS 63650 is the only code that needs to be prior authorized for trial and permanent placement. The alert goes on to provide documentation requirements and links to related content.

    Noridian (Jurisdiction E)

    Noridian has created a Prior Authorization Lookup Tool to help providers determine which HCPSC codes require a prior authorization (link). They are also providing Prior Authorization for Certain Hospital Outpatient Department (OPD) Services webinars (link). One is scheduled for today July 21, 2021, and another one is scheduled for August 12, 2021.

    Novitas Solutions Jurisdiction (Jurisdiction H)

    On the Novitas webpage that is dedicated to this program (link), you will find the following:

    • Program background information,
    • Quick links to key documents,
    • General information,
    • Upcoming Education events,
    • Links to all applicable LCDs and LCAs,
    • Information about expedited requests, and
    • Contact Information.

    Palmetto GBA (Jurisdiction J)

    Palmetto has made available a Cervical Disc Spinal Fusion and Spinal Cord Stimulator On-Demand Webcast (link). On July 15th, Palmetto also posted an article detailing the Prior Authorization Exemption Process (link).

    WPS (Jurisdiction 5)

    On Monday, July 19th, WPS posted the following notice about spinal neurostimulators prior authorization requests:

    “Providers who perform and bill CPT code 63650 (percutaneous implantation of neurostimulator electrode array, epidural) must remember to request prior authorization (PA) for both the trial and permanent placement.

    Providers should submit a PA for the trial placement only if the plan is to perform the procedure in a hospital outpatient department (HOPD). Providers should submit one prior authorization request (PAR) when both the trial and the permanent placement will be in the same HOPD. WPS will only assign one Unique Tracking Number (UTN) that the provider should use to bill for both claims.

    If the trial and permanent placement are to occur at two separate HOPDs, then the provider will need two separate UTNs as each HOPD has their own Provider Transaction Access Number (PTAN) and National Provider Identifier (NPI).”

    What Can You Do?

    For those involved in the Prior Authorization process at your hospital, be sure and check out available resources on your MAC specific webpage. CMS’s Review Contractor Directory – Interactive Map (link) among other Medicare Contractors, provides links to your state specific MAC.

  • Beth Cobb

    What Code to report for the Drug Romidepsin
    Published on Jul 14, 2021
    20210714
    Did you know?

    Romidepsin was first approved by the FDA November 5, 2009, for the treatment of cutaneous T-cell lymphoma (CTCL) and then approved in June 2011 for other peripheral T-cell lymphomas (PTCLs). HCPCS code C9065 was established as a temporary code to report the drug Romidepsin in the outpatient prospective payment system (OPPS) until a permanent J code was established.

    Why it matters.

    This code was to be terminated on June 30, 2021. However, on June 21, 2021, MLN article MM12289 (Quarterly Update to the Medicare Physician Fee Schedule Database (MPFSDB) – July 2021 Update (link) was revised to reflect that HCPCS J9314 (Injection, romidepsin, non-lyophilized (e.g., liquid), 0.1mg) was removed from the table of new HCPCS codes for July 1, 2021 and after.

    Shortly after the release of the revised MLN article, Medicare Administrative Contractors (MACs) posted announcements on how to report administration of this drug. For example, the JN MAC, First Coast’s June 29, 2021 announcement (link), indicated “HCPCS code C9065 was set to be terminated on June 30; however, a permanent J code has not yet been established. For services on or after July 1, please continue using HCPCS code C9065 on your OPPS claims to report the drug Romidepsin.”

    What can You do?

    Make sure you billing staff is aware of this update.

    Beth Cobb

    Coding Outpatient Surgery without the Pathology Report
    Published on Jul 14, 2021
    20210714
    Question

    Is it appropriate for hospitals to code and submit an outpatient surgery claim before the pathology report is available? At our hospital we do a lot of skin excisions, but we code the record and bill the claim before we have the pathology report. Therefore, there are times when the malignant skin cancers are not reported on the claim since we do not know about it at the time of coding.

    Answer

    Yes, it is appropriate / allowed for hospitals to code and submit a claim before the pathology report is available to the coder for review. It is up to the individual hospital to determine this process. For additional discussion, refer to Coding Clinic, 1st quarter 2017, page 15.

    Jeffery Gordon

    June 2021 Medicare Educational Resources, COVID-19, and Other Medicare Updates
    Published on Jul 07, 2021
    20210707

    Medicare Educational Resources

    Revised MLN Fact Sheet: Medicare Disproportionate Share Hospital

    CMS issued a revised edition of the Medicare Disproportionate Share Hospital MLN Fact Sheet (link). Specifically, the Fact Sheet includes information about how CMS calculates uncompensated care payments for FY 2021 and FY 2022.

    Revised MLN Fact Sheet: Medicare Billing for Cardiac Device Credits

    This revised Fact Sheet (link) includes the following two changes highlighted in dark red font in the text:

    • When a hospital gets a replaced device credit 50% or greater than the device’s cost, report the amount in the claim’s FD code value portion.
    • Beginning in 2020, Medicare applies a device offset cap to the Ambulatory Payment Classification (APC) claims that require implantable devices and have significant device offset (greater than 30%) based on the FD value code’s listed credit amount.”
    MLN Educational Tool: Medicare Preventive Services Revised

    CMS updated this Education Tool (link) in May. Information available in this tool includes:

    • Link to National Coverage Determination (NCD) services webpage when applicable to a service,
    • HCPCS and CPT codes,
    • Prolonger Prevention Services information,
    • ICD-10-CM diagnosis codes,
    • Billing for telehealth during COVID-19,
    • Coverage Requirement,
    • Frequency Requirements,
    • Patient liability, and
    • Telehealth eligibility.

    COVID-19 Updates

    June 3, 2021: Myths and Facts about COVID-19 Vaccines

    The CDC developed this webpage (link) to help stop common myths and rumors such as:

    • The COVID-19 vaccine can make you be magnetic,
    • The COVID-19 vaccine will alter my DNA, or
    • The COVID-19 vaccine will make me sick with COVID-19.
    June 9, 2021: Medicare to Increase Payment for Medicare Vaccination Administration in the Home

    In a Special Edition MLN Connects, CMS announced additional payment for administering in-home COVID-19 vaccinations to Medicare beneficiaries (link). A related infographic (link) was also updated to include this information.

    June 17, 2021: CMS MLN Connects – Emergency Use Authorization (EUA) for Monoclonal Antibody Updates

    CMS noted that on May 26, 2021, the FDA released an EUA for the COVID-19 monoclonal antibody product sotrovimab. Coinciding with the FDA release, CMS created new HCPCS codes also effective May 26th for sotrovimab. This drug can be administered in health care setting and the home. The following is an excerpt from the MLN Connects newsletter:

    Q0247

    • Long descriptor: Injection, sotrovimab, 500 mg
    • Short descriptor: Sotrovimab
    • Price: The government won’t provide this drug for free; visit the COVID-19 Vaccines and Monoclonal Antibodies webpage for pricing information (available soon)

    M0247

    • Long Descriptor: Intravenous infusion, sotrovimab, includes infusion and post administration monitoring
    • Short Descriptor: Sotrovimab infusion
    • Price: $450.00 per infusion

    M0248

    • Long Descriptor: Intravenous infusion, sotrovimab, includes infusion and post administration monitoring in the home or residence; this includes a beneficiary’s home that has been made provider-based to the hospital during the COVID-19 public health emergency
    • Short Descriptor: Sotrovimab inf, home admin
    • Price: $750.00 per infusion

    On June 3rd, the FDA released a revised EUA for Regnereon’s COVID-19 monoclonal antibody combination product casirivimab and imdevimab. Updates includes new dosing regimen and allows a new route of administration. “In response to this change, CMS created a new HCPCS code, effective June 3, and updated the short and long code descriptors. This information is detailed in the MLN Connects newsletter (link).

    Other Medicare Updates

    July 1, 2021: Interim Final Rule Banning Surprise Billing and Certain Out-of-Network Charges

    HHS issued the interim final rule, “Requirements Related to Surprise Billing: Part 1,” that will restrict surprise billing for insured patients that receive emergency care, non-emergency care from out-of-network providers at their in-network facility, and air ambulance services from out-of-network providers. One way this helps patient, as noted in a Related CMS Fact Sheet (link), is that “if your health plan provides or covers any benefits for emergency services, this rule requires emergency services to be covered:

    • Without any prior authorization (meaning you no not need to get approval beforehand).
    • Regardless of whether a provider or facility is in-network.”

    This rule will take effect on January 1, 2022. CMS is excepting written comments through 5 p.m. 60 days after the rule is displayed in the Federal Register. At the time of this article, the interim final rule had not been published in the Federal Register. You can learn more about the interim rule requirements in another CMS Fact Sheet (link).

    Beth Cobb

    June 2021 Medicare Transmittals and Coverage Updates
    Published on Jul 07, 2021
    20210707

    Medicare MLN Articles & Transmittals – Recurring Updates

    Addition of the QW Modifier to Healthcare Common Procedure Coding System (HCPCS) Codes 0240U, 0231U and 87637
    • Article Release Date: June 11, 2021
    • What You Need to Know: The FDA has issued Emergency Use Authorizations (EUAs) for the COVID-19 tests represented by these three HCPCS codes. “For Medicare to recognize these tests performed under a CLIA certificate of waiver or a CLIA certificate for provider-performed microscopy procedures, you must add the modifier QW.”
    • MLN MM12318: (link)
    July 2021 Update of the Hospital Outpatient Prospective Payment System (OPPS)
    • Article Release Date: June 14, 2021
    • What You Need to Know: This article provides a summary of changes to and billing instructions for payment policies to be implemented by CMS on July 1, 2021.
    • MLN MM12316: (link)
    July 2021 Update of the Ambulatory Surgical Center [ASC] Payment System
    • Article Release Date: June 25, 2021
    • What You Need to Know: For the July 2021 Update there are 8 new CPT Category III codes, a new device pass through code, new HCPCS codes for drugs and biologicals, a change to a skin substitute HCPCS code from the low to the high-cost skin substitute group and a new technology HCPCS code as been established to describe the technology associated with vaginal colpopexy by sacrospinous ligation fixation.
    • MLN MM12341: (link)

    Revised Medicare MLN Articles & Transmittals

    Quarterly Update to the Medicare Physician Fee Schedule Database (MPFSDB) – July 2021 Update
    • Article Release Date: February 23, 2021 – Most recent revision June 3, 2021
    • What You Need to Know: In the third iteration of this MLN article, important information about the use of the QW modifier was added in red print on page 10 of this document.
    • MLN MM12131: (link)
    International Classification of Diseases, 10th Revision (ICD-10) and Other Coding Revisions to National Coverage Determinations (NCDs) – July 2021
    • Article Release Date: May 18, 2021 – Revised June 3, 2021
    • What You Need to Know: This article was revised to reflect NCD specific changes made in a revised Change Request (CR) 12124.
    • MLN MM12124: (link)
    July 2021 Quarterly Average Sales Price (ASP) Medicare Part B Drug Pricing Files and Revisions to Prior Quarterly Pricing Files
    • Article Release Date: April 27, 2021 – Revised June 8, 2021
    • What You Need to Know: This article was revised to reflect a revised CR 12244 which added language about Section 405 of the Consolidated Appropriates Act, 2021.
    • MLN MM12244: (link)
    Quarterly Update for Clinical Laboratory Fee Schedule (CLFS) and Laboratory Services Subject to Reasonable Charge Amount
    • Article Release Date: May 24, 2021 – Revised June 15, 2021
    • What You Need to Know: This article was revised due to a revised Change Request (CR) 12885 which included the addition of new codes to the national HCPCS file.
    • MLN MM12285: (link)

    Medicare Coverage Updates

    June 10, 2021: NGS Reminder Regarding General Anesthesia, Conscious Sedation and Facet Joint Interventions

    NGS posted a reminder regarding the recent revision to Local Coverage Determination (LCD) (L35936) “Facet Joint Interventions for Pain Management” and Local Coverage Article (LCA) (A57826) “Billing and Coding: Facet Joint Interventions for Pain Management.” As of April 25, 2021, one Limitation of LCD L359356 (link) indicates that “general anesthesia is considered not reasonable and necessary for facet joint interventions.” Neither conscious sedation nor monitored anesthesia care (MAC) is routinely necessary for intraarticular facet joint injections or medial branch blocks are not routinely reimbursable. Individual consideration may be given on redetermination (appeal) for payment in rare, unique circumstances if the medical necessity of sedation is unequivocal and clearly documented in the medical record. Frequent reporting of these services together may trigger focused medical review.”

    National Coverage Determination (NCD) 20.9.1 Ventricular Assist Devices (VADs)
    • Article Release Date: June 11, 2021
    • What You Need to Know: Effective December 1, 2020, CMS covers VADs under certain criteria. Change Request (CR) 12290 revises NCD 20.9 in the Medicare NCD Manual and Chapter 32, Section 320 of the Medicare Claims Processing Manual.
    • MLN MM12290: (link)
    July 2, 2021: Proposed Decision Memo for Home Use of Oxygen and Home Oxygen Use to Treat Cluster Headaches

    CMS issued Proposed Decision Memo CAG-00296R2 (link). Two changes being proposed includes:

    • Remove NCD 240.2.2 of the Medicare NCD Manual, ending coverage with evidence development, and allow the Medicare Administrative Contractors (MACs) to make coverage determinations regarding the use of home oxygen and oxygen equipment for cluster headaches (CH), and
    • Modify NCD 240.2 Home Use of Oxygen to expand patient access to oxygen and oxygen equipment in the home, and to permit MACs to cover the use of home oxygen and equipment in order to treat CH and other acute conditions.

    You can submit comments through August 1, 2021. The related National Coverage Analysis (NCA) Tracking Sheet for this Decision Memo CAG-00296R2 (link) will enable you to follow the progress of this proposal.

    May 2021 Medicare Coverage Updates and Education Resources
    Published on Jun 02, 2021
    20210602

    Medicare Coverage Updates

    May 18, 2021: CMS Initiates National Coverage Analysis for Screening for Lung Cancer with Low Dose Computed Tomography (LDCT)
    • Coverage Analysis Issue: The United States Preventive Services Task Force (USPSTF) recently published an updated recommendation for certain persons at high risk for lung cancer based on age and smoking history for screening for lung cancer with LDCT.
    • CMS Actions: CMS received a complete, formal request to reconsider the National Coverage Determination 210.14 and are soliciting public comment. The public comment period ends on June 17, 2021.
    • Resources
      • March 9, 2021 USPSTF Lung Cancer Screening Recommendation Statement: (link)
      • Coverage Analysis (CAG-00439R): (link)
      • NCD 210.14: (link)
    National Coverage Determination (NCD) Removal
    • Article Release Date: May 24, 2021
    • What You Need to Know: 6 NCDs are being removed from the NCD Manual based on rulemaking in the Calendar Year 2021 Medicare Physician Fee Schedule.
      • NCD 20.5 Extracorporeal Immunoadsorption (ECI) Using Protein A Columns,
      • NCD 20.5 Extracorporeal Immunoadsorption (ECI) Using Protein A Columns,
      • NCD 100.9 Implantation of Gastrointestinal Reflux Devices,
      • NCD 110.19 Abarelix for the Treatment of Prostate Cancer,
      • NCD 220.2.1 Magnetic Resonance Spectroscopy, and
      • NCD 220.6.16 FDG PET for Inflammation and Infection.
    • MLN MM12254: (link)
    National Coverage Determination (NCD 110.24) Chimeric Antigen Receptor (CAR) T-cell Therapy
    • Article Release Date: May 24, 2021
    • What You Need to Know: Effective for claims with dates of service on or after August 7, 2019, CMS covers autologous treatment for cancer with T-cells expressing at least 1 CAR when administered at healthcare facilities:
    • MLN MM12177: (link)
    National Coverage Determination (NCD) 210.3 – Screening for Colorectal Cancer (CRC) – Blood-Based Biomarker Tests
    • Article Release Date: May 26, 2021
    • What You Need to Know: Effective January 19, 2021, CMS determined that the blood-based biomarker test is an appropriate CRC screening test once every three years for Medicare patients when performed in a CLIA certified lab, ordered by a treating physician, and the patient is:
      • Aged 50-85 years, and
      • Asymptomatic (no signs or symptoms of colorectal disease including but not limited to lower gastrointestinal pain, blood in stool, positive guaiac fecal occult blood test, or fecal immunochemical test); and, • At average risk of developing CRC (no personal history of adenomatous polyps, or inflammatory bowel disease, including Crohn’s Disease and ulcerative colitis; no family history of CRCs or adenomatous polyps, familial adenomatous polyposis, or hereditary nonpolyposis CRC).
    • MLN MM12280: (link)

    Medicare Educational Resources

    Revised MLN Booklet: Behavioral Health Integration Services

    CMS issued a revised version of this MLN Booklet (link) to add CY 2021 MPFS Final Rule CMS-1734-F Updates and add new HCPCS code G2214 (Initial or subsequent psychiatric collaborative care management, first 30 minutes in a month of behavioral health care manager activities, in consultation with a psychiatric consultant, and directed by the treating physician or other qualified health care professional).

    Revised MLN Booklet: Medicare Mental Health

    CMS issued a revised version of this MLN Booklet (link) to include a new outpatient psychiatric services medical records checklist, an acute care hospital section, and CPT codes updates and additions.

    Revised MLN Fact Sheet: Complying with Medicare Signature Requirements

    CMS issued a revised version of this MLN Fact Sheet (link) to include information about signing documentation written by a medical student.

    Revised MLN Booklet: Medicare Diabetes Prevention & Diabetes Self-Management Training

    CMS issued a revised version of this MLN Booklet (link) to add information about flexibilities extended in the March 1, 2020, COVID-19 Interim Final Rule and the CY 2021 Physician Fee Schedule Final Rule to all patients receiving services as of March 31, 2020. They also spotlight that in January 2020, the American Association of Diabetes Educator (AADE) changed their name to the Association of Diabetes Care & Education Specialists (ADCES).

    National Osteoporosis Month

    National Osteoporosis Month falls in May each year. Following is information CMS provided in their Thursday May 6th edition of MLN Connects:

    “Medicare covers bone mass measurements, and your patients pay nothing if you accept assignment. During National Osteoporosis Month, talk to your Medicare patients about their risk factors and bone health.

    More Information:

    • Medicare Preventive Services educational tool (link)
    • Preventive Services webpage (link)
    • CDC Osteoporosis webpage (link)
    • National Osteoporosis Foundation website (link)
    • Information for your patients on bone mass measurements” (link)
    MLN Booklet: Outpatient Rehabilitation Therapy Services: Complying with Documentation Requirements

    The Thursday May 13, 2021 edition of the CMS e-newsletter, MLN Connects (link), included the following information related to complying with Medicare billing requirements for outpatient rehabilitation therapy services:

    “An Office of Inspector General report (link) found that payments for physical therapy services didn’t comply with Medicare billing requirements. Review the Outpatient Rehabilitation Therapy Services: Complying with Documentation Requirements (PDF) (link) booklet to help you bill correctly, reduce common errors, and avoid overpayments. CMS listed additional resources in the newsletter.

    April 2021 MLN Fact Sheet: Medical Record Maintenance & Access Requirements

    This MLN Fact Sheet (link) provides information on updated documentation maintenance and access requirements for billing services to Medicare patients. It also includes how long providers are to keep the documentation and who is responsible for providing access.

    Beth Cobb

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