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.
Telephone Visits Now Considered Telehealth Visits
In response to the COVID-19 pandemic, on April 30, 2020, CMS released a second Interim Final Rule which modified or added to the previously released expansions and waivers by CMS since the declaration of the Public Health Emergency (PHE). One of the significant changes within the second Interim Final Rule was the addition of telephone visits, CPT® codes 99441-99443,to the list of Medicare telehealth services for the duration of the PHE. CMS has indicated these codes are reserved for medical discussions and should not be reported for administrative or other non-medical discussions with the patient. CMS has also indicated that CPT® codes 98966-98968 are to be used by practitioners who cannot independently bill for E/M visits.The most up-to-date Medicare Telehealth List of Services can be found here.
CMS has also updated the COVID-19 Frequently Asked Questions (FAQs) on Medicare Fee-for-Service (FFS) Billing document on May 27, 2020. The newest FAQ updates are related to rural health clinics (RHCs), Medicare Telehealth services, and General Billing Requirements. For example, pre-procedure testing for COVID-19 is not outlined in any policy by CMS. The decision is that of the MAC to determine coverage of the testing prior to a medical procedure. The full FAQ document can be found here.
CMS Corrects inappropriate 77014 Denials
The Centers for Medicare and Medicaid Services (CMS) announced a correction made regarding the inappropriate denials for CT image guidance represented by CPT® code 77014 for practices billing under the Medicare Physician Fee Schedule (MPFS). Medicare Administrative Contractors (MACs) were incorrectly denying claims citing practices needed to have an Advanced Diagnostic Imaging (ADI) accreditation to bill for the technical component of 77014. After CMS was contacted about this practice,they confirmed the issue had been corrected. In a statement by ASTRO, CMS has instructed practices effected by the denials to resubmit claims for reimbursement.
GPCI Work Values Extended
In December of 2019, by law, the Floor GPCI (geographic cost index) Work value was set at 1.000 through May 22, 2020. After this date, the values for some locations that fall below the national rate of 1.000 were set to be adjusted downward for the remainder of the year. However, in response to the COVID-19 pandemic and included in the CARES Act, the Floor GPCI Work values are extended through November 30, 2020 and therefore will not be adjusted to the values published in the MPFS Final Rule released on November 1, 2020 until after this date.
CMS 2% Sequestration Suspended
MS has suspended the 2% payment adjustment typically applied to all Medicare Fee-For-Service (FFS) claims in compliance with the Coronavirus Aid, Relief and Economic Security (CARES) Act. The sequestration has been suspended for claims with dates of service from May 1, 2020 through December 31, 2020. Therefore, Medicare Fee-For-Service claims with a date of service or date of discharge on or after May 1, 2020 will not reflect the standard two percent reduction in payment. It is expected the sequestration will be reinstated effective for claims submitted on or after January 1, 2021.
HCPCS Coding Updates for July 2020 Released
Change to Medically Unlikely Edits to Keytruda
In response to the Public Health Emergency (PHE) the FDA approved an optional increase for the drug pembrolizumab of 400 mg(Keytruda) using an extended dosing interval. The previous Medically Unlikely Edits (MUEs) was set at 300 mg per date of service. The MUE change, which gointo effect July 1, 2020 and retroactive to April 1, 2020,will now allow for 400 mg per date of service. Palmetto GBA on their website indicates MACs will begin holding new claims with units greater than 300 and less than or equal to 400 for dates of service on or after April 1, 2020. These held claims will be processed when the July 1, 2020 MUE update file is in production.Providers have the option to hold claims until after July 1, 2020 or appeal denied claims due to the MUE edit of 300, including supporting documentation.
Noridian Healthcare Solutions Updates Billing and Coding: MRI and CT Scans of the Head and Neck Coverage Article
NoridianHealthcare Solutions(Jurisdictions E and F)announced an update to the Local Coverage Article, Billing and Coding: MRI and CT Scans of the Head and Neck. Several ICD-10-CM codes were added to the coverage article. The codes for amyloid angiopathy were added and must be coded first when billing I68.0, Cerebral amyloid angiopathy, which is a covered service.The coverage articlescan be accessed JE hereand JF here.
The added ICD-10-CM codes are as follows:
- E85.0 – Non-europathic heredofamilialamyloidosis
- E85.1 – Neuropathic heredofamilial amyloidosis
- E85.2 – Heredofamilial amyloidosis, unspecified
- E85.3 – Secondary systemic amyloidosis
- E85.4 – Organ-limited amyloidosis
- E85.81 – Light chain (AL) amyloidosis
- E85.82 – Wild-type transthyretin-related (ATTR) amyloidosis
- E85.89 – Other amyloidosis
NGS Revises Multiple Local Coverage Articles
National Government Services (NGS) has made revisions to multiple medical oncology related local coverage articles (LCAs). Some of the revisions include:the addition of a variety of ICD-10-CM and HCPCS codes to multiple LCAs, clarifying statements, as well as modifications to “Utilization Guidelines.” The most up to dateLCAs can be viewed, in their entirety, by following the links provided.
- Billing and Coding: Bevacizumab and biosimilars (A52370)
- Billing and Coding: Bortezomib (A52371)
- Billing and Coding: Filgrastim, Pegfilgrastim, Tbo-filgrastim and biosimilars (A52408)
May 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: Is there a time limit threshold that an organization can use a locum and bill under the modifier?
Advice: Under normal circumstances, the locum physician can only be utilized under the attending physician’s NPI for 60 consecutive days. However, due to the waivers implemented as a result of the COVID-19 pandemic, CMS has modified the 60-day limit. Per CMS: ” CMS is modifying the 60-day limit in section 1842(b)(6)(D)(iii) of the Social Security Act to allow a physician or physical therapist to use the same substitute for the entire time he or she is unavailable to provide services during the COVID-19 emergency plus an additional period of no more than 60 continuous days after the public health emergency expires. On the 61st day after the public health emergency ends (or earlier if desired), the regular physician or physical therapist must use a different substitute or return to work in his or her practice for at least one day in order to reset the 60-day clock.” It is of note that the attending physician cannot be providing services anywhere else during the duration of the locum billing under the attending physician’s NPI
Question: As of last Friday,we started getting denials from NGS for CPT®77014 CBCT. Their reasoning is the following: “The rendering provider is not eligible to perform the service provided” The billing manager called NGS and was told that the practice is not accredited. Has anyone else had this issue and what do we need to do?
Advice: We have seen several denials about this from different Medicare Administrative Contractors (MACs) and have reached out to an accrediting agency for assistance. The Advanced Diagnostic Imaging (ADI) accreditation only applies to the TC of the advanced diagnostic imaging, it does not apply to the professional component. It does not apply to hospitals. After the inquiry, CMS has stated “CPTcode 77014 is for a therapeutic ADI procedure. As it does not involve the technical component of a diagnostic ADI procedure, the provider of the procedure under CPR code 77014 is not required to be accredited. However, if the ADI supplier does provider other ADI procedures that do include the technical component of diagnostic ADI procedures (i.e. –CT. MRI and nuclear medicine procedures including PET scans), they would need to be accredited. We have issued a revised CR (which is currently in process) which will reflect this and removed CPT code 77014 from the list of ADI CPT codes.