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New Medicare Cards are in the Mailbox

Last June’s post was about new Medicare cards.  At the time of the post, it seemed like a long time away and something that could be pushed off until a later time.  Well, that time is upon us.  Beginning next month, the federal government will begin issuing new Medicare cards.  Gone are the days of using the patient’s Social Security numbers as their ID numbers.  The new Medicare cards will have unique, randomly assigned numbers and letters that replace Social Security numbers.  The new Medicare cards are being mailed in waves beginning April 1 and continuing through April 2019.

What the new Medicare cards mean to your practice

This is good news and bad news for all medical practices.  The good news is that the old cards will work until December 31, 2019.  The bad news is this means the front office staff has to wade through this transition for 21 months!  Health care providers must use the new card numbers beginning January 2020.  Some practices may think they can put this off but this time the patients are likely to force the transition.

This change will undoubtedly result in some of your patients having questions and concerns   The Centers for Medicare & Medicaid Services is encouraging Medicare patients to bring their new card to their next visit.  They are informing seniors that the change in cards is to protect them from medical identity theft.  CMS is also informing patients that if they forget their card then their health care provider can look it up for them.  If patients are also in a Medicare Advantage plan then the Medicare Advantage card is the main card for Medicare.  However, it is better to be safe than sorry so make sure you add the new card to the patient’s record, as well.

Is Your Practice Ready for MIPS?

The Merit-based Incentive Payment System (MIPS) program is a key component of the MACRA Quality Payment Program (QPP) and is expected to be the more popular path for 2017, the first performance year.  Under MIPS, the Meanighful Use (MU) Medicare incentive program, Physician Quality Reporting System (PQRS) and the Value-Based Modifier (VBM) program will be consolidated into one program.

We’ve consolidated the key highlights for the 2017 transition year and compiled them into this concise overview.  It’s short and created for anyone in your practice wondering what to do next.

MIPS HIGHLIGHTS FOR THE 2017 TRANSITION YEAR

Is it too late to start?

  • You can start anytime between January 1 and October 2, 2017

Pick your pace

  • Test: submit a minimum amount of 2017 data to avoid downward payment adjustment.
  • Partial: submit 90 days of 2017 data for a neutral or positive payment adjustment.
  • Full: submit a full year of 2017 data and you may earn a positive payment adjustment
  • If you don’t submit any 2017 data you will receive a negative 4% payment adjustment.

Reporting process

  • The submission of data remains the same as in the past
  • Quality Measures via claims based reporting or registry
  • Advanced Care Information (ACI) and IA categories use the attestation process as you did with Meaningful Use

Requirements reduced

  • ACI measures reduced from 11 measures to 5 measures
  • Cost performance category (formerly VBM) – 0% weight in 2017
  • Quality cross-cutting measures and domains removed to avoid a penalty and not earn an incentive, need only report on 1 patient.

Eligibility

MIPS eligible clinicians billing Medicare Part B listed as Physicians, Pas, NPs, Clinical Nurse Specialists, CRNAs.

Exempt eligible clinicians

  1. Physicians in their first year of Medicare Part B participation
  2. Membership in an advanced APM
  3. Physicians with less than $30,000 in annual Medicare revenue/or have less than 100 Medicare patients

MIPS Performance Categories for 2017

Quality (formerly PQRS) = 60%

  1. Submission: Claims Based, Qualified Registry or EHR
  2. Report: 6 measures
  3. Resource: https://qpp.cms.gov/measures/quality

Advanced Care Information (ACI) Formerly MU = 25%

  1. Submission: Attestation based on your health technology.  Attest to 5 required measures for a minimum of 90 days.
    1. Security Risk Analysis
    2. ePrescribing
    3. Provide Patient Access
    4. Send Summary of Care
    5. Request/Accept Summary of Care (bonus credits available)
  2. Resourcehttps://qp.cms.gov/measures/aci

Improvement Activities – IA  (aka from proposed rule CPIA) = 15%

  1. Submission: Attestation based on your health technology.  Complete 2 – 4 improvement activities for a minimum of 90 days
  2. Resource: https://qpp.cms.gov/measures/ia

 

Three Coding Updates – Provider Beware

CodingCODING IT RIGHT

We know everyone is busy and there is no way you can read every single article that comes in your inbox or crosses your desk.  So we thought we’d share three bullet items regarding coding that may impact your practice.

  • New Vaccine Codes for 2018

Medicare has announced a coding change.  After January 1, 2018 they will cover the new influenza virus vaccine code 90756 (Influenza virus vaccine, quadrivalent (ccIIV4), derived from cell cultures, subunit, antibiotic free, 0.5mL dosage, for intramuscular use).

During the interim period of Aug. 1, 2017, through Dec. 31, 2017, Medicare Administrative Contractors (MACs) will use code Q2039 (Influenza virus vaccine, not otherwise specified) to handle bills for this new influenza virus vaccine product (Influenza virus vaccine, quadrivalent (ccIIV4). Q2039 is already an active code.

The new influenza virus vaccine code 90756 will then be implemented for DOS on or after Jan. 1, 2018.

  • Consult Codes not being paid

United Healthcare, has announced that they will stop paying for consult codes effective October 1, 2017.  This may be the wave of the future so make sure your billing service or office manager notifies you if other payers follow suit.

  • Documentation requirements for coding by time

Before you code by time make sure you know the documentation requirements.  The documentation must include the total time of the visit, a summary of the discussion or counseling AND support that over 50% of the visit was spent in counseling or coordination of care.

MEDICARE TO STOP USING SOCIAL SECURITY NUMBERS

Medicare MBIMEDICARE SAYS NO MORE SOCIAL SECURITY NUMBERS

Medicare has announced they will stop using Social Security numbers for identification beginning April 2018.  The change is required by a law enacted two years ago to discourage identity theft.

The Centers for Medicare & Medicaid Services (CMS) recently updated its web page to help health care providers prepare for the change.  Medicare plans to begin mailing the new cards with unique Medicare Beneficiary Identifiers (MBI) to each person.  According to the Medicare website, the agency is just now trying to figure out the best way to mail the cards.  They plan a “wide-scale outreach” to let beneficiaries know that they need to bring their new Medicare cards when they receive medical care.

WHAT THIS MEANS FOR YOU

Don’t expect CMS to reach every one of your patients and don’t count on the patients to remember to bring their new card to their appointment.  Start getting the word out to your patients now.  Let you patients know that they will be getting new cards.  Let them know that they must bring this card into your office.  Include this information on your website and in your newsletter. Prepare handouts and fliers that you can leave in your waiting room and at the front desk.  Be ready to remind your patients to bring their new Medicare cards at the time of service.

Update the patient registration information with the MBI number as soon as patients present with their new card.  It is best to scan the new Medicare card into the practice management system.  Scanning all insurance cards is a good practice since it allows the billing team to easily access the information and correct or update, as necessary.

WHAT CAN THE BILLING AND COLLECTION TEAM DO?

Now is the time to make sure that the practice management software can accept the new 11 digit alpha numeric MBI.  Whether you outsource your billing and collections or have an in-house team it is imperative to make sure they are prepared to file claims with this new number.

Your billing and collections team can also participate in notifying your Medicare patients about the new cards.  Every interaction with a Medicare beneficiary is a chance to remind them about the upcoming change and what they need to do.

As part of Onpoint Medical Solutions due diligence, the practice management software has already been tested.  The software can accept the MBI, claims are accurately populated and can be submitted.  Make sure your billing and collections team has done their due diligence, as well.

DON’T DELAY

CMS has indicated there will be a transition period through 2019.  A knee jerk reaction is to think it is way too early and you will worry about that later.  However, you don’t want to wait until the last minute.  If you postpone this will become a daunting task.  Contacting all of your Medicare patients will require some time.  Failure to update and utilize the MBI will ultimately result in claim rejections and delayed payments.

How to Get Paid for Incident to Billing

Employing a non-physician practitioner (NPP) e.g. physician assistant or nurse practitioner has many benefits.  It increases patient through-put, enhances the patient experience and increases a practice’s revenue.  Once the NPP is hired, we are many times asked what is “incident to” billing and when does it apply.

Simply put, incident to billing applies only to Medicare and allows the NPP to be reimbursed at 100% of eligible charges.  If incident to billing is not utilized, then the NPP will be reimbursed at 85%.  The specific requirements are detailed in Chapter 15, Section 60 of the Medicare Benefit Policy Manual.

So, what are the rules for incident to billing?  There are some basic rules and all must be met to meet the incident to rules for Medicare payment.

  1. Services must be rendered in a setting other than a hospital or skilled nursing facility. The Centers for Medicare & Medicaid Services (CMS) refers to this as non-institutional settings.
  2. A physician who is Medicare-credentialed must initiate the patient care. The NPP cannot see the patient for the first visit or if a change in the treatment plan is needed.
  3. Both the physician and the NPP must be employed by the entity that is billing for the service. If the physician is a solo practitioner, then the physician must employ the NPP.
  4. Follow-up care can be rendered by the NPP provided they are under the direct supervision of a Medicare-credentialed physician. Direct supervision requires that the physician be a part of the same group, but not necessarily the physician who performed the initial patient evaluation, be present in the same office suite and immediately available to help during the time the NPP is rendering patient care.
  5. Pursuant to the physician’s state licensure rules, they must actively participate in and manage the patient’s treatment.
  6. The service provided must be routinely provided in the office setting and are of a type considered medically appropriate to provide in the office setting. Incident to billing does not apply to services that have their own benefit category, such as diagnostic testing.
  7. Documentation should include who performed the service and who was the supervising physician.