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Hello,
In
this issue
MGMA
comments on proposed 2010 Medicare physician fee schedule
The
Medical Group Management Association (MGMA) submitted comments
on the proposed
2010 Medicare physician fee schedule released by the Centers for
Medicare & Medicaid Services (CMS). The fee schedule contains proposed
payment rates for covered services and changes to Medicare policy.
MGMA’s
comments to the agency include:
- Applauding
CMS’ proposal to remove physician-administered drugs from the
sustainable-growth-rate-formula calculations. This long-awaited
administrative step will mitigate the size of future Medicare Part B
reductions.
- Urging CMS
to quickly finalize testing of the Physician Quality Reporting
Initiative (PQRI) reporting mechanism via electronic health records
(EHRs), allowing for 2010 PQRI participation through qualified EHRs
and promptly releasing EHR measure-specification information to
vendors.
- Opposing
CMS’ proposed definition of a group practice for purposes of the new
PQRI group-practice reporting option. Instead, the agency should allow
any interested medical group, regardless of size, to report on the
proposed measures through a properly structured group-practice
reporting mechanism.
- Opposing the
increased utilization assumption for all equipment priced at more than
$1 million. The change is based on erroneous assumptions and will
result in a payment rate so low as to make it economically unfeasible
for physicians to perform imaging services in their offices.
- Expressing
concern about several proposed provisions implementing the
accreditation requirements for advanced diagnostic imaging services in
the Medicare Improvements for Patients & Providers Act (MIPPA). In
some instances, CMS has suggested changes that unnecessarily expand on
the statutory requirements for entities seeking designation as
accrediting bodies, which would ultimately have a negative effect on
the suppliers of advanced diagnostic imaging services.
- Expressing
extreme concerns over the agency’s continued use of proprietary,
commercial episode-grouper software, since transparency is one of the
primary goals of CMS’ Value Based Purchasing initiatives. Given the
Association’s regard for quality improvement, we agree that quality
measure information should be included in the Resource Use Reports, as
long as it is reliable.
Read all
of the comments on
the MGMA Public Policy page,
as well as an MGMA member-only
analysis of the proposed regulation.
OIG
investigates “incident to” billing; MGMA offers Webinar to help practices
comply
The
Office of Inspector General (OIG) for the Department of Health & Human
Services released a report examining the services of nonphysician providers
that are billed “incident to” a physician’s care. The report found that
“unqualified” nonphysicians provided 21 percent of physician services,
meaning that the nonphysicians lacked necessary licenses or certifications,
had no verifiable certifications or lacked the training to perform the
service. In addition, the OIG found that 7 percent of invasive services not
performed by physicians were performed by nonphysicians with inappropriate
qualifications.
You
should be aware that the OIG and CMS are closely examining “incident to”
services and that billing for them must fall within current Medicare
requirements. Read the OIG’s report, Prevalence
and Qualifications of Nonphysicians Who Performed Medicare Physician
Services.
To
assist your practice in complying with the “incident to” rules, we have
engaged experts in physician reimbursement to lead a member-focused,
interactive, 90-minute Webinar. Robert J. Saner II, Esq. and Rebecca L.
Burke, Esq. will help you understand these difficult rules during "OIG
targets ‘incident to’ claims – are you billing correctly?"
CMS
releases H1N1 vaccine and administration codes
In
anticipation of the vaccine for H1N1 influenza, the Centers for Medicare
& Medicaid Services (CMS) has created two new codes for medical
providers. G9142 (Influenza A [H1N1] vaccine, any route of administration)
describes the vaccine, while G9141 (Influenza A [H1N1] immunization
administration, including physician counseling the patient/family)
describes the administration of the vaccine. Both codes become effective on
Oct. 1.
CMS
anticipates the H1N1 vaccine will be supplied to providers at no cost,
although Medicare will pay for its administration. From the CMS
adult immunizations Website, “Medicare will cover immunizations for
H1N1 influenza, also called the "swine flu." There will be no
coinsurance or copayment applied to this benefit, and beneficiaries will not
have to meet their deductible. H1N1 influenza vaccine is currently
under production and will be available in the Fall of 2009.”
Read
details in the CMS MLN education article MM6617.
Read the
2008-2009
Immunizers’ Question & Answer Guide to Medicare Coverage of Influenza
and Pneumococcal Vaccinations.
Review
the Centers for Disease Control & Prevention Novel
H1N1 Influenza: Resources for Clinicians Web page.
Prepare
for H1N1 by visiting the MGMA
Emergency Preparedness Resource Center.
Got
a stock of DMEPOS in your office?
The
Centers for Medicare & Medicaid Services (CMS) recently updated
compliance standards for consignment closets and stock and billing
arrangements for durable medical equipment, prosthetics, orthotics and
supplies (DMEPOS).
In
consignment closets and/or stock and billing arrangements, an enrolled
DMEPOS supplier maintains inventory at a practice location owned by a
physician or nonphysician practitioner. The inventory is housed at the
practice location solely for distribution. Physicians and nonphysician
practitioners who maintain consignment closets and stock and bill
arrangements for DMEPOS must comply with National Supplier Clearinghouse
Medicare Administrative Contractor standards. These requirements include:
- Transferring
the title of the DMEPOS to the enrolled provider’s practice when the
DMEPOS are furnished to a beneficiary.
- Using the
provider’s billing number for DMEPOS supplies and services.
- Performing
services for fittings or use of the DMEPOS by individuals being paid
by the provider.
- Directing
beneficiaries with questions or concerns to the provider – not the
supplier – that supplies the DMEPOS to the provider’s office.
CMS
makes changes to 855S form
The
Centers for Medicare & Medicaid Services (CMS) revised the Durable
Medical Equipment Prosthetic and Orthotic Supplier (DMEPOS) enrollment
form, 855S,
to accommodate many requests made by the Medical Group Management
Association and other professional associations. The major revisions:
- Instruct
providers and nonphysician practitioners exempted from accreditation
to check “not accredited” in the section on accreditation status.
- Alter the
surety bond documentation section by adding the phrase “if
applicable,” because this requirement does not apply to all suppliers.
Physicians
and licensed health professionals exempted from DME accreditation
CMS
requires DME suppliers to obtain surety bonds
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