The summary of events and newsworthy items for the month of August is provided on the following pages. In most instances, the link to the full document of information is provided. Any of the contents may be further discussed by reaching out to Revenue Cycle Coding Strategies LLC.
CMS Extends AUC and Clinical Decision Support Mechanism Mandate
On August 10, 2020, The Centers for Medicare and Medicaid Services (CMS) announced the extension of the Educational and Operations Testing Period for the appropriate use criteria (AUC) and clinical decision support mechanism mandate through December 31, 2021. This decision is considered final and is not open to comment. The mandate is inclusive of all advanced diagnostic imaging services and the extension provides additional time for practices to implement clinical decision support systems (CDSMs). During the Educational and Operations Testing Period, CMS expects ordering professionals to being consulting qualified CDSMs and providing information to the furnishing practitioners and providers for reporting on their claims. In the event in which the furnishing practitioners and providers do not receive AUC-related information from the ordering professional, it can be reported with modifier MH. While the claims with modifier MH will not be denied during the educational and operations testing period, inclusion is encouraged. In addition to the updated timeline of the mandate, CMS also released an updated list of qualified clinical decision support mechanisms available for referring providers to use.
Continued Confusion Surrounding CPT® Codes 99441-99443 During PHE
The Centers for Medicare and Medicaid Services (CMS) continues to field questions surrounding the use of telephone Evaluation & Management (E/M) CPT® codes 99441-99443 during the Public Health Emergency (PHE). CMS states these are patient-initiated services, but practitioners can provide education to beneficiaries on the availability of these services. For the duration of the PHE, these services can be furnished to and billed for new or established patient visits. CMS provides further information on telehealth flexibilities that have been granted due to the response of the PHE declared as a result of the COVID-19 pandemic in an informational video titled Medicare Coverage and Payment of Virtual Services.
OIG COVID-19 Portal
The Office of Inspector General (OIG) has a dedicated COVID-19 webpage portal which provides extensive information and resources regarding all aspects of the COVID pandemic. Among other things, the portal contains policies and guidance, toolkits, the most up-to-date news, as well as quick links to additional resources from reputable sites such as the Centers for Disease Control and Prevention (CDC). It is recommended to check the portal often to receive the most up-to-date information in the everchanging climate surrounding the COVID-19 pandemic.
NGS Incorrect Denials for Pegfligrastim and Biosimilars
National Government Services (NGS) has acknowledged an error in processing claims for pegfilgrastim and biosimilars. NGS states claims for both Jurisdictions 6 and K, Part A have had claims incorrectly denied that have reported codes J2505, Q5108, Q5111 due to an internal system issue. NGS is in the process of reviewing the cause of the errors and will determine the actions they will take based on the review. At this time, no provider action is necessary but NGS does encourage providers to continuously check the Production Alerts section of their website for future updates regarding the issue.
!!UPDATE!! ABN Form Renewal Approved
Last month it was announced that the Advance Beneficiary Notice of Noncoverage (ABN) form and instructions had been approved by the Office of Management and Budget (OMB) for renewal. The announcement originally instructed the mandatory start date for utilizing the renewed form would be August 31, 2020. However, due to COVID-19 concerns, CMS has expanded the deadline for the use of the renewed ABN form. CMS has set the new mandatory date for use to January 1, 2021. CMS also states the new form can be implemented prior to this date. The ABN webpage has updated information along with renewed forms and instructions, which can be located here.
NGS Alerts of Postcard Disguised as OCR Communication
The Office of Civil Rights (OCR) dispersed an official notification regarding a deceptive postcard mailing that was sent out attempting to make providers believe it came from the OCR. The postcard is designed to appear as official OCR communications claiming to be notices of a mandatory Health Insurance Portability and Accountability Act (HIPAA) compliance risk assessment. The postcards have a Washington, D.C. return address and the sender uses the title “Secretary of Compliance, HIPAA Compliance Division.” The postcard is addressed to the health care organization’s HIPAA compliance officer and prompts recipients to visit a URL, call, or email to take immediate action on a HIPAA Risk Assessment. The URL link provided on the postcard directs individuals to a nongovernmental website marketing consulting service. The OCR wants to make it clear that this is NOT an HHS/OCR communication, it is from a private entity. You can authenticate communications from OCR by verifying the OCR address or email address which is provided through the OCR website. An image of the deceptive post card is seen below.
Emergency Room Visits, Abdominal CTs Decline During Pandemic
Abdominal CTs and Emergency department visits have markedly decreased during the COVID-19 pandemic, while prognoses continue to worsen, according to a new study published by the Journal of the American College of Radiology (JACR).
According to the study published August 20, the COVID-19 pandemic has resulted in a global decrease in medical imaging of all types. In reviewing emergency imaging trends, scientists determined there has been a 42% decline in abdominal CT scans and a 47% decline in emergency room visits for abdominal pain when compared with the same period in 2019. Meanwhile, there has been a statistically significant increase in positive findings on abdominal CTs (50.5% as compared to 32.7% last year), as well as a nearly 12% increase in complications and severity of pathologies (up to 19.7%) and cases requiring surgeries (up from 26.3% to 47.6%).
While the specific reasons for the decrease in imaging and worsened prognoses during the pandemic are unclear, Ciara O’Brien of the Department of Medical Imaging at University Health Network and her colleagues hypothesized many patients likely ignored their symptoms out of fear & anxiety associated with presenting to the hospital, resulting in increased complications. They also cite postponement of medical imaging studies by government bodies, medically appropriate delay of imaging by physicians, and studies cancelled or not initiated by patients as possible reasons for the decline. The study highlights the importance of educating patients on when it is necessary to report to the emergency department and assuaging patient fears by informing them of the measures in place to keep them safe from the spread of COVID-19.
“The onus is on the government, media and healthcare institutions to publicize the measures undertaken to ensure patient safety during the pandemic and reduce anxiety associated with presenting to hospital when in need of any type of medical attention,” wrote O’Brien.
Access the JACR article here.
3D CT Modeling Aids in Diagnosis and Assessment of COVID-19
3D CT modeling has proven to be effective in the assessment and diagnosis of lung damage related to COVID-19, a recent study has shown.
According to an article published August 18 in BMJ Case Reports, a research team at Louisiana State University has utilized methods from evolutionary anatomy research to create 3D digitally segmented models which reveal the extent and impact of COVID-19 on the lungs. These models could be 3D-printed and used to communicate the severity and effects of the disease to the public.
“Three-dimensional segmented digital models provide a dramatically clearer method for visually evaluating the impact of COVID-19 on the lungs than straight radiographs, CT data, or reverse transcription polymerase chain reaction alone,” wrote study co-authors Emma Schachner, PhD, an evolutionary anatomist, and Dr. Bradley Spieler, a radiologist at LSU Health Sciences Center New Orleans. “Unlike simple volume rendered images, these models can be 3D printed, and thus have a much broader functional application that allows for the collaboration between basic and clinical scientists, which is particularly important given the critical nature of COVID-19,” they wrote. Drs. Schachner and Spieler now plan to segment additional models for a larger follow-up project.
Access the article from BMJ Case Reports in its entirety here.
August Coding Corner
Within this section, current topics will be the focus. In some cases, the Q&A could reflect common questions received by Revenue Cycle Coding Strategies and in other cases, represent current issues encountered by Revenue Cycle Coding Strategies professionals.
Question: Question: We are expanding our facility next year and will be adding some new machines (Unity, Ethos and Halcyon). It is my understanding that these will feature adaptive planning and advanced imaging. Are there any additional billing codes we will be able to charge?
Advice: There may be potential additional and/or different codes based on what is being performed. Additional planning codes (77295/77301) are only applicable if medically necessary due to significant change in tumor volume or patient anatomy. With newer technology, the ability to adjust the treatment plan in real-time while the patient is on the table does not warrant billing a new set of planning codes.
Question: A patient receives 25mg of Benadryl prior to receiving a unit of blood and another 25mg prior to their second unit of blood. The patient received a total of 50mg of Benadryl. If 2 x 50mg vials were used can the patient be charged for both 50mg vials?
Advice: If two vials were used, then this scenario supports a J1200 x2 charge since they were administered at different timepoints during the encounter. Nursing documentation should support that only 25 mg was administered at each timepoint. Thank you
Question What CPT would be billed for a Fetal MRI? We have Physicians inquiring about the study
Advice: There are two codes for fetal MRI, 74712, Magnetic resonance (eg, proton) imaging, fetal, including placental and maternal pelvic imaging when performed; single or first gestation, and 74713, Magnetic resonance (eg, proton) imaging, fetal, including placental and maternal pelvic imaging when performed; each additional gestation (List separately in addition to code for primary procedure).
Fetal MRI is reported with code 74712 for a single fetus and add-on code +74713 for each additional fetus examined. These codes include imaging of the placenta and maternal pelvic organs when performed.
Per Clinical Examples in Radiology, Winter 2016 and CPT Assistant, June 2016, the fetal MRI codes cannot be reported together with the codes for MRI of the pelvis (72195-72197). The study should be coded as an MRI of the pelvis rather than a fetal MRI when it is limited to the placenta and/or maternal pelvis without examination of the fetus.