Medicare Delays Physician Pay Cut Until December

By: Justin Vaughn, MDiv, CPC
Director of Compliance

On June 25, 2010, President Obama signed into law the Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act, which provides for a six-month extension of the physician pay update.  The effect of this legislation is that, instead of a significant pay cut, Medicare physicians will now receive a modest 2.2% pay increase—to run through November 30, 2010.  

Previously, a scheduled 21% cut in Medicare physician payments went into effect on June 1.  The new law provides a rate update retroactive to that date.  On June 25, CMS instructed its contractors to hold all claims for services rendered after May 31 until the new 2.2% updated rates can be tested and loaded into the Medicare contractors’ claims processing systems.  CMS revealed that it expects to begin processing claims at the new rate no later than July 1.  Claims that had been paid at the reduced rates will be re-processed "as soon as possible," according to CMS officials.

This is good news for now, but continued vigilance is warranted.  We continue to urge our clients to make your views known to your representatives in Congress.  Thank you, and have a great week!

The information presented herein reflects general information that is current as of the date it is first published.  In light of changes that may occur in the health care regulatory and compliance environments, the author's presentation of this information and any general advice previously published might become outdated.  Please check with your individual legal and/or compliance advisor(s) prior to taking any significant actions based upon the information and advice presented.

Medicare To Hold Claims Through June 14th

By: Bellinger P. Moody, RHIA, CPC, CCP, CPC-I
Executive Vice President of Compliance

Yesterday, June 1, 2010 was the proposed date that the 2010 Medicare physician pay cut (21.2 %) was to go into effect.  This pay cut will not go into effect as Congress in looking to pass legislation that will give providers a 1.3% increase for now and put off solving the Sustainable Growth Rate (SGR) problem until some time in 2014. 

In light of this recent development, CMS has announced that it will hold claims for services provided on June 1 through June 10th  so as to provide Congress time to pass legislation that would put off the SGR cut.  THEREFORE, CMS WILL HOLD CLAIMS PROCESSING THROUGH JUNE 14TH FOR ALL DATES OF SERVICE BETWEEN June 1 and June 10, 2010.  The Senate will return on June 7th and hopefully this issue will be resolved during the next session.

The information presented herein reflects general information that is current as of the date it is first published.  In light of changes that may occur in the health care regulatory and compliance environments, the author's presentation of this information and any general advice previously published might become outdated.  Please check with your individual legal and/or compliance advisor(s) prior to taking any significant actions based upon the information and advice presented.

FTC “Red Flags” Regulations:
Implementation Delayed Again

By: Justin Vaughn, M.Div, CPC
Director of Compliance

The Medical Group Management Association (MGMA) has announced today that the Federal Trade Commission (FTC) is delaying yet again the implementation date of the “Red Flags” rule.  Slated to become effective on June 1, 2010, the FTC has, at the request of Congress, pushed back the effective date of the rule until Jan 1, 2011.

This is the latest in a series of implementation delays that are due in part to the continuing debate over whether or not a medical practice falls under the regulatory definition of “creditor.”  According to the FTC, entities so designated must follow the Red Flags rule, which among other requirements mandates the creation of policies and procedures aimed at limiting identity theft.

So, once more, anesthesia groups can breathe a temporary sigh of relief.  Thank you, and have a wonderful Memorial Day weekend!

The information presented herein reflects general information that is current as of the date it is first published.  In light of changes that may occur in the health care regulatory and compliance environments, the author's presentation of this information and any general advice previously published might become outdated.  Please check with your individual legal and/or compliance advisor(s) prior to taking any significant actions based upon the information and advice presented.

Post-Anesthesia Assessment:
CMS Revises its Recent Rule

By: Justin Vaughn, M.Div, CPC
Director of Compliance

As many of you know, CMS released at the end of 2009 an advanced copy of “Interpretive Guidelines” (IGs) pertaining to rules for hospital surveyors, as found in Appendix A of the Medicare State Operations Manual.  Among other items, the IGs addressed time limitations for completing the post-anesthesia assessment.  Of some concern to many anesthesia providers was the stipulation that, for outpatient cases, the assessment would have to be completed before the patient was discharged from the facility.  That instruction has now been revised.  

According to the May 21, 2010 version of the IGs, the following sentence has been deleted:  

“For outpatients, the post-anesthesia evaluation must be completed prior to the patient’s discharge.”  

This means that outpatient cases will default to the same requirements as outlined for inpatient cases; that is, you will have 48 hours from the moment the patient is transported to the recovery area to complete the post-anesthesia assessment.  Naturally, you will need to begin the assessment long before this time period has elapsed, as the IGs also advise that the patient must participate in the applicable portions of the assessment (and thus must be sufficiently recovered to be able to answer questions, perform simple tasks, etc.).

In addition to your fellow anesthesia providers, you may want to bring this revision to the attention of appropriate hospital officials in the event facility policies and protocols are at issue.  Thank you, and have a great week!

The information presented herein reflects general information that is current as of the date it is first published.  In light of changes that may occur in the health care regulatory and compliance environments, the author's presentation of this information and any general advice previously published might become outdated.  Please check with your individual legal and/or compliance advisor(s) prior to taking any significant actions based upon the information and advice presented.

MEDAC BILLING & COMPLIANCE ALERT
February 26, 2010

By: Bellinger P. Moody RHIA,CPC, CCP
Executive Vice President of Compliance

Failure to Act By Senate Means 21% Medicare Cut Effective March 1

According  the most recent MGMA Washington Connexion alert sent out at 2:53pm EST today -- the Senate failed to act on legislation  that would extend Medicare’s current physician payment rates and therapy cap exception process through March 31st due to Senator Jim Bunning’s, R-Ky., objections as to how to pay for the bill – which means that by law, the 21.2% payment cut will take effect March 1.  The senate will return on Tuesday and will most likely try to address the issue again.  However, regardless of whether congress acts, by law, Medicare carriers must hold all claims payments for at least 13 business days after receipt.  CMS states that it will also hold all processing of claims at the reduced rate for the first 10 business days of March – which will give the Senate a window to act.

In accordance with MGMA recommendations, you should contact your Senators and urge them to permanently address this issue by repealing the sustainable growth rate formula. You can contact your senators by calling the American Medical Association Grassroots Hotline, 800.833.6354

The information presented herein reflects general information that is current as of the date it is first published.  In light of changes that may occur in the health care regulatory and compliance environments, the author's presentation of this information and any general advice previously published might become outdated.  Please check with your individual legal and/or compliance advisor(s) prior to taking any significant actions based upon the information and advice presented.

MEDAC BILLING & COMPLIANCE ALERT
February 2, 2010

By: Bellinger P. Moody RHIA,CPC, CCP
Executive Vice President of Compliance

ASA Confers with CMS on New Interpretive Guidelines

In a recent letter to CMS dated January 18, 2010, Dr. Alexander Hannenberg, President of the ASA, stated the ASA’s concerns and perspective in reference to the new revisions to the hospital interpretive guidelines that will affect anesthesia service provision.

MEDAC BILLING & COMPLIANCE ALERT
December 30, 2009

By: Bellinger P. Moody RHIA,CPC, CCP
Executive Vice President of Compliance

New Facet  Injection Codes:  Base Unit Assignments

As you may or may not know, there are new CPT codes for facet injections.  The old codes were 64470, 64472 (Cervical or Thoracic) and 64475, 64475 (Lumbar or Sacral).  The base unit assignments for these codes previously were:

MEDAC BILLING & COMPLIANCE ALERT
November 25, 2009

By: Bellinger P. Moody RHIA,CPC, CCP
Executive Vice President of Compliance

New PQRI Measure in 2010 for Anesthesia

As part of the final rule, CMS has approved another quality measure for anesthesia reporting in 2010.  You will be able to report on a third measure:  Perioperative Temperature Management.   Currently there are two reportable measures for anesthesia:  (1) Measure #30 – Administration of prophylactic antibiotics; and (2) Measure #76 – Central Line Sterile Technique measure.

MEDAC BILLING & COMPLIANCE ALERT
November 24, 2009

By: Bellinger P. Moody, RHIA, CPC, CCP
Executive Vice President of Compliance

New 2010 CPT Codes for Facet Blocks

The old Facet injection block codes, 64470-64476, have been deleted and replaced by codes 64490-64495. Now, there are 6 facet block codes, instead of four.  Additionally, fluoroscopy is now bundled into these codes for all payers. Consequently, the Facet Radiofrequency codes (64622, 64623, 64626, and 64627) have not changed. Therefore, fluoroscopy can still be billed with the facet Radiofrequency codes, and the number of levels of RF has not been restricted, as is the case with the new 2010 facet block codes.

MEDAC BILLING & COMPLIANCE ALERT
November 18, 2009

By: Bellinger P. Moody, RHIA, CPC, CCP
Executive Vice President of Compliance

Clarification & Update:  2010 SRNA Medical Direction Rule

On November 9, 2009 I issued a “Medac Billing & Compliance Alert” entitled “New Teaching Rules for Anesthesiologists”.  In this alert I addressed my interpretation of the 2010 Medicare Physician Fee Schedule Final rule as it pertains to rules for teaching anesthesiologists in reference to Residents and SRNAs. 

As you may or may not know, there has been a great deal of discussion (and alarm) about the “CORRECT” interpretation of the 2010 SRNA teaching rule.  Currently, the anesthesia administrative community is split in its interpretation of the 2010 SRNA teaching rule:

MEDAC HEALTHCARE REFORM ALERT & UPDATE
November 11, 2009

By: Bellinger P. Moody, RHIA, CPC, CCP
Executive Vice President of Compliance

ASA Tele-Town Hall:  Wednesday, November 11, 7pm EST

I strongly urge all Medac Clients that are ASA members to participate in a Tele-Town Hall meeting to be held tonight at 7pm EST.  The Tele-Town Hall meeting will be hosted by ASA President Alex Hannenberg, M.D.  This meeting will focus on the recent bill -- H.R. 3962 “Affordable Health Care for America Act” – and will provide great insight into the history of  the healthcare reform debate and what you must do as the legislative process moves into the U.S Senate and House-Senate conference committee.  

This event is open to all ASA members and Component Society staff and it will provide detailed information and legislative analysis based on the facts relative to healthcare reform.  It is sure to clear up a lot of speculation about what is currently happening and what may happen with healthcare reform.  I encourage all of you to become informed about the provisions included in H.R. 3962 and its effects on the specialty of Anesthesia.  This meeting will also help you to better understand the ASA’s strategy throughout the legislative process.

There are H.R. 3962 materials on the ASA website at www.ASAhq.org that you may review prior to the Tele-Town Hall meeting tonight.  You may register for the Tele-Town Hall meeting online at www.directeventreg.com/registration/event/41033095 or by phone:  (888) 869-1189, Conference ID 41033095.

The information presented herein reflects general information that is current as of the date it is first published.  In light of changes that may occur in the health care regulatory and compliance environments, the author's presentation of this information and any general advice previously published might become outdated.  Please check with your individual legal and/or compliance advisor(s) prior to taking any significant actions based upon the information and advice presented.

MEDAC BILLING & COMPLIANCE ALERT
November 9, 2009

New Teaching Rules for Anesthesiologists
By: Bellinger P. Moody, RHIA, CPC, CCP
Executive Vice President of Compliance

The 2010 Medicare Physician Fee Schedule Final Rule has new rules for teaching anesthesiologists in reference to residents and SRNA’s.  I will address both rules and the impact they may potentially have on your anesthesia practice.

MEDAC BILLING & COMPLIANCE ALERT
November 6, 2009

CMS Eliminates Consults
By: Bellinger P. Moody, RHIA, CPC, CCP
Executive Vice President of Compliance

For decades, coding professionals and consultants alike have tried to educate physicians about the proper use of the consult codes.  The fact is, many healthcare providers, across all specialties have not properly utilized these codes and as a result, they have been a significant cost burden for CMS.  As reported on Wednesday, November 4 in the MGMA Washington Connection, in an effort to curtail its cost, “in the 2010 Medicare Physician Fee Schedule, CMS has eliminated the use of all consultation codes (inpatient and office/outpatient codes for various places of service except for tele-health consultation G-codes)”.  

In an effort to calm providers on the elimination of consults, CMS has increased the work RVUs for new and established patient visits.  They have also increased the work RVUs on initial hospital and nursing facility visits, and have made adjustments for the increased use of these codes into the practice expense and malpractice RVU calculations.

Will this decrease your revenues?

MEDAC BILLING & COMPLIANCE ALERT
November 2, 2009

Red Flags Rule Delayed Once Again

By: Bellinger P. Moody, RHIA, CPC, CCP,
Executive Vice President of Compliance

According to a recent posting on the Federal Trade Commission’s website:  www.ftc.gov/opa/2009/10/redflags.shtm, at the request of Members of Congress, enforcement of the Red Flags Rule has been delayed again – this time until June 1, 2010. 

The delay was posted on the FTC site on Friday, October 30, 2009 at approximately 3:37 pm.  Therefore, those physician practices with greater than 20 members now have until June 1, 2010 to fully develop and implement identity theft prevention programs.

The information presented herein reflects general information that is current as of the date it is first published.  In light of changes that may occur in the health care regulatory and compliance environments, the author's presentation of this information and any general advice previously published might become outdated.  Please check with your individual legal and/or compliance advisor(s) prior to taking any significant actions based upon the information and advice presented.

MEDAC BILLING & COMPLIANCE ALERT
October 30, 2009

By: Bellinger P. Moody, RHIA, CPC, CPC-I, CCP
Executive Vice President of Compliance

Red Flag Identity Theft Rules

Effective November 1, 2009, the FTC mandated Red Flag Rules for health care providers become enforceable.

In compliance with these rules, Medac, Inc. has adopted new policies and procedures to identify and avoid risk factors in patient accounts.  One significant risk factor is patient identity theft – specifically in the processing of patient credit card information.

MEDAC BILLING & COMPLIANCE ALERT
October 23, 2009

By Bellinger P. Moody, RHIA, CPC, CCP
Executive Vice President of Compliance

NC Medicare Bundles Fluoroscopy Service With Facet Joint Injections/Denervations & SI Joint Injections:  Other Medicare Contractors Likely To Follow

Effective for dates of service performed on or after September 15, 2009, NC Medicare will no longer separately pay for Fluoroscopy (CPT code 77003-26) when performed in addition to Paravertebral Facet Joint Nerve Blocks/Denervation and Sacroiliac Joint Injections.

MEDAC BILLING & COMPLIANCE ALERT
PA Catheter Rebill Potential for Additional Revenues

By: Bellinger P. Moody, RHIA, CPC, CCP
Executive Vice President of Compliance

Due to a recent increase in the Practice Expense Relative Value Units (PE RVUs) assigned to CPT code 93503 -- Insertion and placement of flow directed catheter (e.g., Swan-Ganz) -- when performed in the facility setting, you may be able to get additional reimbursement for all PA catheters billed in the facility setting, effective October 5, 2009.