Industry News, March 2020

The summary of events and newsworthy items for the month of March 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.

Coronavirus (COVID-19) Partner Toolkit

The Centers for Medicare and Medicaid (CMS) has developed a toolkit in an effort to provide the most up-to-date information surrounding the 2019 Coronavirus (COVID-19) outbreak. Through the toolkit, information from CMS, HHS and the CDC are available and updated often as new information becomes available regarding COVID-19. Along with providing general information and beneficial links, the toolkit offers information for Medicare beneficiaries, caregivers, clinicians and marketplace consumers.

The toolkit can be located through the CMS website here.

The CMS factsheet regarding these newly extended telehealth services can be found here.

FAQs about the above changes can be found here.

Quality Payment Program: MIPS 2019 Data Submission Deadline Extended

The Centers for Medicare and Medicaid is implementing an extreme and uncontrollable circumstances policy exceptions and extensions for upcoming measure reporting and data submission for Quality Payment Programs in response to COVID-19. For eligible clinicians participating in the Quality Payment Program, the deadline to submit 2019 data of the Merit-based Incentive Payment System (MIPS) has been extended from March 31, 2020 to April 30, 2020. Additionally, MIPS eligible clinicians who do not submit MIPS data by April 30, 2020 will qualify for the automatic extreme and uncontrollable circumstances policy and will receive a neutral payment adjustment for the 2021 MIPS payment year. The press release also outlines the adjustments implemented for hospital programs and post-acute care (PAC) programs. The CMS press release can be read in its entirety here.

Accelerated Financial Relief for Medicare Providers

On March 28, 2020 CMS has also announced expansion of the accelerated and advanced payment program.  The accelerated and advanced payment program providers emergency funding and addresses any cash flow issues when there may be a disruption in the claims submission and/or processing.  There are specific criteria which provider must meet:

  • Have billed Medicare for claims within 180 days immediately prior to the date of signature on the provider’s/ supplier’s request form,
  • Not be in bankruptcy,
  • Not be under active medical review or program integrity investigation, and
  • Not have any outstanding delinquent Medicare overpayments.

Requests can be submitted now, and it is expected payments will be issued within seven business days of the request.  An informational fact sheet on the accelerated/advance payment process and how to submit a request can be found here:

Proper Use of Modifier 59 Revisions

The Centers for Medicare and Medicaid (CMS) revised Proper Use of Modifier 59 MLN Matters article on March 2, 2020. The revised article includes modifiers X{EPSU}.  According to the revised article: These modifiers were developed to provide greater reporting specificity in situations where modifier 59 was previously reported and may be used in lieu of modifier 59 whenever possible. (Modifier 59 should only be used if no other more specific modifier is appropriate.) For definitions and examples of -X modifiers, refer to the revised MLN Matters article.

OIG Releases Work Plan to Include Payments to Physicians for Co-Surgery Procedures

The Office of Inspector General (OIG) has published recently added work plan items to include Medicare Part B payments to physicians for co-surgery procedures. According to CPT®, “When 2 surgeons work together as primary surgeons performing distinct part(s) of a procedure, each surgeon should report his/her distinct operative work by adding modifier 62 to the procedure code and any associated add-on code(s) for that procedure as long as both surgeons continue to work together as primary surgeons. Each surgeon should report the co-surgery once using the same procedure code. If additional procedure(s) (including add-on procedure(s) are performed during the same surgical session, separate code(s) may also be reported with modifier 62 added.“ By appending modifier 62 to the CPT® procedure code(s), the fee schedule amount applicable to the payment for each co-surgeon is 62.5 percent of the global surgery fee schedule amount.


The objective of the OIG was to ensure Medicare Part B payments to physicians for co-surgery procedures were properly made by auditing a sample of claim line items in which different physicians billed for the same co-surgery procedure code(s) for the same Medicare beneficiary on the same date of service.

To review the OIG’s Work Plan, including background, objectives and updates, click the following link:

HHS Finalizes Rules to Provide Patients More Control of Their Health Data  

The U.S. Department of Health and Human Services (HHS) finalized two rules that will implement data sharing policies that require both public and private entities to share health information between patients and other parties, while keeping that information private and secure.  According to the CMS press release: Beginning January 1, 2021, Medicare Advantage, Medicaid, CHIP, and, for plan years beginning on or after January 1, 2021, plans on the federal Exchanges will be required to share claims and other health information with patients in a safe, secure, understandable, user-friendly electronic format through the Patient Access API. The new rules will work to ensure patient’s access and control of their electronic health information while ensuring the ability of health information systems to work together within and across organizational boundaries in order to advance the effective delivery of healthcare.

For More Information

March 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: If the CTPN (clinical treatment planning note) is not completed before simulation and dosimetry tasks are completed how does this effect the clinics ability to capture these charges? Are they still billable? I am under the understanding that the CTPN is/includes orders for many of these services.

Advice: The CTPN provides the written orders for the services provided to the patient, like simulation and dosimetry planning. If the CTPN is not provided by the physician, this means signed as well, prior to the services then there are no orders and the services are not billable. Orders cannot be provided after the service was provided if forgotten or not appropriately provided.

Question: We have a patient that originally had a 3D plan and treatment. One week later, from the original CT sim, a second area was planned out and we have started treatment. How do we bill this second plan with it being a separate isocenter but from the original CT data set?

Advice: Billing two plans for distinct and separate anatomical locations is allowable from the same CT data set. Documentation should support the medical necessity for the plans to be developed on different dates of service. Some planning codes may edit with treatment codes if billed on the same date of service and modifiers may be needed but do not guarantee payment. Additionally, if more than one area is treated within the same treatment fraction, only one treatment code would be billable.