All Entries Tagged With: "NCCI"
FIND quarterly updates
Flipping over the calendar from September to October means there are plenty of updates available to MedicareFind subscribers.
The latest versions of the NCCI edits, both on the physician and hospital outpatient side, have been loaded into our NCCI edit lookup tool. Keep in mind that the hospital outpatient edits are one quarter behind the physician edits.
The quarterly updates to the medically unlikely edits (MUE) is available. As before, some of the MUEs remain unpublished.
And you can now locate the following, in addition to other quarterly changes:
- Third quarter updates to OPPS Addendum A and Addendum B
- The October 2009 lab NCD manual
- The latest I/OCE update
Sign up for a free trial to MedicareFind to access updates like these and more.
OPPS, MPFS, NCCI developments
You may have heard about two big announcements yesterday from CMS:
We’re still analyzing these changes, but a look at the CMS fact sheet on the OPPS issuance shows some proposals related to the controversial physician supervision issue:
Physician supervision requirements – CMS is proposing to revise or further define several current policies for the physician supervision of outpatient services. First, CMS is proposing that nonphysician practitioners, specifically physician assistants, nurse practitioners, certified nurse specialists, and certified nurse-midwives, may directly supervise all hospital outpatient therapeutic services that they are able to personally perform within their state scope of practice and hospital-granted privileges. Under current policy, only physicians may provide the direct supervision of these services.
In addition, CMS is proposing to define “direct supervision” for on-campus hospital outpatient services to mean that the physician or nonphysician practitioner must be present in the hospital or on-campus provider-based department of the hospital and immediately available to furnish assistance and direction throughout the performance of the procedure, in contrast to the current definition which requires the physician to be present in the on-campus provider-based department. For services furnished in an off-campus provider-based department, “direct supervision” would continue to mean that the physician or nonphysician practitioner must be present in the off-campus provider-based department and immediately available to furnish assistance and direction throughout the performance of the procedure.
Yesterday also brought a change in NCCI edits for the new quarter. Check these out using our special NCCI lookup tool, available to subscribers or free-trial users.
Purchase MedicareFind to start FINDing late-breaking developments like these. You can also try a free trial to test drive the site.
Medically Unlikely Edits and medical necessity
Kimberly Hoy previously focused on recently issued FAQ 9697. In FAQ 9697, CMS restated its position that hospitals cannot bill beneficiaries for units of service in excess of MUE limits, even when the hospital has provided an ABN to the beneficiary prior to the provision of the services subject to the MUE. CMS’s rationale is that MUEs are coding edits, not medical necessity edits. [more]
Medically Unlikely Edits and ABNs
This was an especially light week for items from CMS for hospitals. This is, perhaps, because shortly we should see the FY2010 Inpatient Prospective Payment System Proposed Rule.
I did want to discuss a new FAQ on Medically Unlikely Edits (MUEs) that brings up some questions. The new FAQ focuses on Advanced Beneficiary Notices (ABNs), pointing out that a beneficiary can not be billed for units in excess of an MUE even if the provider issues an ABN to the beneficiary. CMS explains that an MUE denial is a coding denial, and that ABN provisions only apply to medical necessity denials. [more]
Listen to the February 25 Hospital Open Door Forum
CMS held its latest conference call for hospitals on February 25. This call featured an extensive discussion of “incident to.” If you’re new to this issue, check out the discussion here.
You can listen to the audio below. Subscribers to the MedicareFind database also have access to a transcript of the call.
What is your reaction to CMS’ recent activity regarding “incident to” coverage requirements?
Try a free trial to MedicareFind and gain access to transcripts and audio of CMS’ Hospital Open Door Forum calls.
Application of critical care Correct Coding Initiative (CCI) edits to hospitals
Effective January 1, 2009, the CCI edits for evaluation and management (E&M), including critical care, apply to hospitals. Two prior-existing frequently asked questions (FAQ) have been updated to reflect these changes. The updated FAQs are FAQ 8813 and FAQ 2392. Prior to January 1, 2009, not all CCI edits that applied to physician services also applied to comparable hospital services. In particular, those CCI edits that applied to physician E&M services (including critical care) were not incorporated into the Outpatient Code Editor (OCE) for application to hospital E&M services. [more]
CMS increases its scrutiny of modifier -79 for multiple procedures
Last week, CMS published a One Time Notification related to modifier -79 (Unrelated Procedure or Service by the Same Physician During the Postoperative Period) and the global surgical package (GSP). The GSP is a feature of Medicare’s payment system for physicians and so at first blush this transmittal would appear not to apply to hospital providers. However, CMS’ business requirements apply to both carriers (who traditionally process physician claims) and fiscal Intermediaries (who traditionally process hospital claims), indicating that CMS is concerned about modifier -79 usage in both settings. [more]
Listen to the January 15 Hospital Open Door Forum
CMS’ regular Open Door Forum conference calls are a useful source of updates and clarifications, and an important line of communication between the agency and its industry. Check out the latest Hospital Open Door Forum, which CMS held January 25, 2009. This particular call includes an extensive discussion (during the Q&A) of CMS’ recent clarifications on physician supervision under “incident to” (begins around 30:15 of the audio clip).
Do you dial into CMS’ Open Door Forum calls regularly? Try a free trial to MedicareFind and gain access to transcripts and audio of these meetings.
Watch for missing drug injection and infusion NCCI edits
As many of you know, CMS maintains two sets of NCCI edits: one for hospitals and one for physicians. The hospital version of the edits is one quarter behind the physician version. This can cause significant compliance issues for hospitals.
CPT and HCPCS codes are generally updated January 1 of each year. However, because the NCCI edits for hospitals are one quarter behind, the edits that apply to hospitals during the first quarter of a year are the edits for the fourth quarter of the prior year. This would mean that any new codes, adopted January 1, would not be included in the edits for the first quarter. This is especially problematic this year because of the new renumbered drug infusion and injection codes, which are subject to many bundling edits. [more]
