Industry News, February 2022 - Revenue Cycle Coding Strategies Inc.

February Industry News

CMS Expands LDCT Lung Cancer Screening Coverage

On February 10, 2022, The Centers for Medicare and Medicaid Services (CMS) announced the new expanded coverage for lung cancer screening utilizing low dose computed tomography (LDCT).

Lung cancer is one of the most common cancers and ranked highest in cancer-related deaths for both men and women. LDCT is the only recommended screening test for lung cancer and is aimed at early detection or non-small cell lung cancer. The expanded eligibility for LDCT for lung cancer includes the following changes:

  • Lowering the starting age for screening from 55 to 50 years
  • Reduction of tobacco smoking history from at least 30 packs/year to at least 20 packs/year
  • Simplification of requirements for the counseling and shared-decision making visit
  • Removal of the requirement for the reading radiologist to document participation in continuing medical education
  • Requirement added back into the NCD criterial for radiology imaging facilities to use a standardized lung nodule identification, classification, and reporting system

The changes made in the final decision expands eligibility in an attempt to broaden access to at-risk populations and improve health outcomes by helping to detect lung cancer earlier. Imaging advocates such as The American College of Radiology (ACR), GO2 Foundation for Lung Cancer and the Society of Thoracic Surgeons praised the decision by CMS to expand screening eligibility. The imaging groups stated they will work with the federal government, medical providers and patients to implement and update the screening recommendations.

Additional Information:

Providers See Change in Retrospective Billing Date

Medicare has changed the timeframes for certain providers’ Medicare retrospective billing dates. This recent change reduces the retrospective billing period effective for applications received, pending or in process on or after January 3, 2022.

The retrospective billing period for the below listed providers was previously one year from the receipt of the enrollment application. Effective for applications received, pending or in process as of January 3, 2022, the retrospective billing period is now up to 30 days prior to the receipt of an enrollment application that is subsequently approved (or up to 90 days prior to the receipt date when a presidential-declared disaster occurs).

Provider types affected include:

  • Radiation Therapy Centers
  • Part B Hospital Departments
  • Clinical Laboratory Improvement Act (CLIA) Labs (Independent Clinical Labs)
  • Mammography Centers
  • Mass Immunization Roster Billers
  • Pharmacy
  • Home Infusion Therapy Suppliers

CMS states this change brings the retrospective billing period for these provider types in line with that of other physicians and practitioners. Providers may see a gap in which they are eligible to receive payment from Medicare for services provided to Medicare patients with the shorter retrospective billing period. However, CMS emphasizes providers cannot bill Medicare and may not charge patients for services provided prior to their retrospective billing date.

More information regarding this change in retrospective billing can be found here.

Call to Action on Cancer Screening Praised by Radiology Community

The presidential call to action on February 2, 2022, sets the ambitious goal of reducing the death rate from cancer by at least 50 percent over the next 25 years. The relaunched initiative has garnered praise from the radiology community.

The Cancer Moonshot initiative aims to harness the last 20 years of bipartisan support, public health progress and scientific advances to continue to reduce the cancer death rate and improve the experience of people and their families living with and surviving cancer. One of the steps the government is taking to jumpstart the initiative is to issue a call to action on cancer screening and early detection. Imaging will be at the forefront of the effort as there were an estimated 9.5 million missed cancer screenings in the United States as a result of the COVID-19 pandemic. Hoping to catch up on preventative cancer screening and ensure equitable access, officials hope to offer new access points and utilize at-home and mobile cancer screening options.

In conjunction with the announcement, the President’s Cancer panel released their report “Closing Gaps in Cancer Screening” which also highlights the need for cancer screenings. The American College of Radiology (ACR) praised the panels highlights, goals and recommendations found within the report. The ACR, a proponent for screening initiatives, state they will continue to support the recommendations released in the report to foster and improved access and equity to cancer care.

“We could not be more pleased with the direction that this has taken and firmly believe that there is a real opportunity here for radiology to play an increasing role in three of the four cancers (lung, breast, colon) studied by the President’s Cancer Panel,” said American College of Radiology® (ACR®) Chief Executive Officer William T. Thorwarth Jr., MD, FACR.

CAR-T Remission Exceeds Expectations in Two

Remissions of more than 10 years have been seen in two chronic lymphocytic leukemia (CLL) patients who received chimeric antigen receptor (CAR) T-cell therapy a decade ago.

The published findings of a study on the long-lasting CAR-T cells in two patients who received CAR-T immunotherapy, indicate there is no evidence of leukemia at their 10-year follow-up. However, the authors caution that many more patients still need to be followed. The results seen in the two decade-long remissions have physicians cautiously but optimistically using the word “cure.”

While pleasantly surprised by the findings within the two studied remissions, there is still work to be done to figure out why the therapy doesn’t present the same results in every patient. However, the importance of the study is highlighted as a starting point to learn about the mechanisms of the treatment and how to improve its efficacy for more people.

Bill Aimed at Providing MIPS Relief to Small Practices

On February 3, 2022, members of the House and Senate introduced the bipartisan Small Practice, Underserved, and Rural Support Program Extension Act of 2022 (SURS). The Act would reauthorize the program which helps small practices comply with the Merit-based Incentive Payment Program (MIPS).

The SURS Act would reauthorize the Centers for Medicare and Medicaid Services (CMS) technical assistance initiative for clinicians and practices with 15 or fewer providers participating in the Quality Payment Program (QPP). The Act is aimed at assisting small practices in in rural locations, health professional shortage areas, and medically underserved areas in complying with the potentially cumbersome reporting requirements of the payment programs.

In a letter to the members of Congress, signed by 25 national stakeholders including the American Medical Association (AMA) and The American College of Physicians (ACP), states: “The SURS Extension Act extends the QPP-SURS program until 2027 and ensures that small practices in rural and underserved areas have the support and tools necessary to succeed in the MIPS program.”

Omnibus CR Covers Removal and Updates

MLN Matters Article Number: MM12613 covers a plethora of different policies including the removal of two National Coverage Determinations (NCDs) and updates to four other policies.

The following items are covered in the Article:

  • Removal of:
    • NCD 220.6 Positron Emission Tomography (PET) Scans
    • NCD 180.2 Entera/Parenteral Nutritional Therapy
  • Updates to the conditions of coverage for:
    • Pulmonary Rehabilitation (PR)
    • Cardiac Rehabilitation (CR)
    • Intensive Cardiac Rehabilitation (ICR)
  • Policy update:
    • Medical Nutritional Therapy (MNT)

The effective date, by statute, for the outlined changes is January 1, 2022, with an implementation date July 5, 2022.

February 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: Our practice is wanting to explore counseling and billing for nutritional therapy services for our patients. We do not have a dietician or nutritional therapist on staff. These services would be provided by a Medical Oncology APP. In researching the billing, it looks like we could not bill for the MNT codes 97802-97804. My question is if you could help provide guidance on billing a regular e/m 99212-99215 for the nutritional counseling. In my research, I found that the e/m codes 99212-99215 may be reimbursed if there is medical necessity such as obesity. I could not find any documentation to support billing the established e/m codes for just counseling the patient on nutritional therapy.

Advice: When the APP, as part of the physician group, provides educational nutritional counseling to a patient, it should be able to be billed separately as an established E/M visit. The appropriate E/M level billable will follow the E/M guidelines and supporting documentation by the APP.

Question: When a patient comes in for follow up with Physician after finishing Radiation Tx (during what’s considered global period), is it appropriate to bill a laryngoscopy exam (31575) or is it only appropriate to bill if there are significant changes as far a diagnosis?

Advice: If the scope is performed and documented either as a separate note or a separate section of the E/M from the physical exam, billing 31575 could be supported. Although the physician cannot bill the E/M during the 90-day period following treatment, if performed and documented separately, the scope could be supported as billable.

Question: If a doctor happens to not be available at time of SIM can we bill the technical component?

Advice: If there is no radiation oncologist who can be present for a simulation, it should be rescheduled. The simulation requires the active participation of the physician in the simulation process.