Coding Strategy

Medicare’s elimination of payment for consultation services has caused mass confusion throughout the coding community, not just due to the changes it has caused in your billing procedures, but also due to lack of information from CMS.

In an apparent attempt to quell those issues, CMS has released MLN Matters article SE1010, which offers several questions and answers regarding how to report your services now that Medicare no longer recognizes consult codes (99241-99255).

For example, CMS addresses the often-asked question of whether the agency will release a crosswalk of  consult codes to E/M codes. “No,” CMS responded in the article. “Providers must bill the E/M code (other than a CPT consultation code) that describes the service they provide in order to be paid for the E/M service furnished.” In other words …

You must report the E/M code that best matches your provider’s documentation, rather than attempting to find the appropriate consult code and matching it to an office or hospital visit code.

Plus: Many providers have been concerned about what will happen if  they report a subsequent hospital care code (99231-99233) for a physician who hasn’t first billed an initial hospital care code (99221-99223).

CMS responds that it has instructed MACs “to not find fault with providers who report a subsequent hospital care CPT code in cases where the medical record appropriately demonstrates that the work and medical necessity requirements are met,” even if that provider is seeing that patient for the first time during his or her hospital stay.

© Supercoder.com. Sign up for your free trial.

AUDIO: What surgical specialties need to understand about the new consult rules. With Barbara Cobuzzi, MBA, CPC, CENTC, CPC-H, CPC-P, CPC-I, CHCC.

Related articles:

1. CMS’s Refusal to Pay Consults Makes MSP Claims a HeadacheIf you bill consults to private payers, good luck collecting...
2. AMA Chimes In On How to Report Consults for Non-Medicare PatientsBeware: Don’t use the CMS consult crosswalk for billing purposes....
3. Think You Understand the New Consult Rules? Find Out FastCheck your 2010 consultation coding savvy. Find out if you’re...

On Tuesday evening, the Senate passed H.R. 4691, which freezes the Medicare conversion factor at current levels through March 31.

Because of this vote, you will not face the 21% pay cut until April 1, explains Part B Insider editor, Torrey Kim. Hopefully by that point, a more permanent fix will have been introduced. “The Senate is working on a bill that would extend the current Medicare payment rate until Oct. 1,” reports this article from the AAFP site.

H. R. 4691 is a “hodgepodge” bill that contains a lot of other provisions in addition to this month’s conversion factor freeze, reports The Wall Street Journal. The bill also extends COBRA’s health insurance subsidies.

FREE WEBINAR: Are you home-growing your very own physician pay cuts with faulty E/M coding? Stop shorting yourself on E&M coding levels with this most-often-overlooked medical coding history type.

Related articles:

1. Physician Fee Schedule Update: An Extension for the Temporary Conversion Fix?Fear not: The CF may stay until autumn, but the...
2. SGR Update: What’s Up With That 21 Percent Physician Pay Cut? Here’s what you should be watching on Capitol Hill....
3. How Obama’s Medicare Cuts Hit Physician Reimbursement  The budget released Thursday suggests we cut $300 billion from...

The latest on the 21 percent Medicare pay cut.

If your practice leans heavily on Medicare for reimbursement, expect your cash flow to taper off a bit.

CMS has instructed the MACs to hold claims for the first ten business days in March, according to numerous press reports like this one from Healthcare Finance News.

“A bill intended to extend the freeze on Medicare pay at current levels is still sitting in the Senate,” reports Part B Insider editor Torrey Kim. “Hopefully by that point, Congress will have passed an extension of the pay freeze so you won’t be looking at the 21% pay cut.”

Bummed that the Olympics excitement is over and just twiddling your thumbs until March Madness begins? To follow the pay cut legislation suspense as it happens, join Supercoder.com’s fan page on Facebook.

Take the extra time to get your practice registered in PECOS — don’t wait until the end of the year, CMS reps say.

Practices that were busily struggling to find out whether their ordering/referring physicians’ national provider identifiers (NPIs) were in the PECOS system can relax a little bit — at least until next year.

If your physician performs a service as the result of an order or referral, your claim must include the ordering or referring practitioner’s NPI, and that number must be in the Medicare Provider Enrollment, Chain, and Ownership System (PECOS) or the payer’s computer system.

Currently, if you submit claims for services or items ordered/referred and the ordering or referring physician’s information is not in the MAC’s claims system or in PECOS, your practice will get an informational message letting you know that the practitioner’s information is missing from the system. But CMS was planning to start denying claims as of April 5 that lacked this information. However, that date has been pushed back until Jan. 3, 2011, announced CMS’s Jim Bossenmeyer during a Feb. 17 CMS Open Door Forum.

Repeating the information twice because of its importance, Bossenmeyer said, “CR 6417 and CR 6421 have been delayed until January 3, 2011.”

Don’t waste the extra time: Although CMS offers some breathing room with the date extension, you shouldn’t abandon your attempts to get your information into PECOS.

“The delay in implementing Phase 2 of these CRs will give physicians and non-physician practitioners who order items or services for Medicare beneficiaries or who refer Medicare beneficiaries to other Medicare providers or suppliers sufficient time to enroll in Medicare or take the action necessary to establish a current enrollment record in Medicare prior to Phase 2 implementation,” the CMS Web site indicates.

If you are unsure of whether your information is in the PECOS system, you can check the file, which contains approximately 800,000 practitioner records, on the CMS Web site.

For more on the delay, visit www.cms.hhs.gov/MedicareProviderSupEnroll/06_MedicareOrderingandReferring.asp.

Avoid PECOS Lags

Also on the call, Bossenmeyer indicated that the number one reason for delayed processing of paper Medicare enrollment applications (855-I or 855-B forms) is “incomplete applications or delays in the submission of developmental materials.”

CMS “strongly encourages” providers to use internet-based electronic PECOS, which is faster and results in fewer errors. Always remember to sign, date, and mail your certification statement and any supporting documentation, Bossenmeyer noted.

DMEPOS suppliers will not have internet-based PECOS availability until later this year, Bossenmeyer said.

Get New Docs Into PECOS

One caller noted that her practice hired a new physician who moved from Oregon to Wyoming, but was remaining with the same MAC with which he was previously enrolled, despite moving from one state to another. Even in this case, the new practice should complete a new PECOS application for the physician.

“Medicare enrolls physicians and nonphysician practitioners, along with groups, by state, not by MAC jurisdiction,” a CMS rep. noted on the call. “So if you’re in Montana and you’re in Utah, you should be enrolling twice — once for each state.”

@ Part B Insider

Be a hero. Join your coding community at the Supercoder Fan Page.

Related articles:

1. CMS: Billing Co. Can’t Fill Out PECOS Form on Doc’s BehalfIf you’ve grown accustomed to a designated credentialing specialist in...
2. A Press Release Is Not a Legal Ruling, PECOS Pundits Point OutKeep an eye on the Federal Register as you use...
3. CMS Changes Course: Physicians Need Not Personally Complete PECOS ApplicationWhat a difference three months makes, especially when it comes...

Fear not: The CF may stay until autumn, but the current snow storm is delaying the official word.

Practices that were looking for a permanent change to the sustainable growth rate (SGR) formula before March 1 may come up empty-handed. However, Congress appears to be planning to offer an extension of the pay cuts that you’re due to face after Feb. 28.

Despite CMS’s plans to downgrade your 2010 conversion factor by 21.29 percent, the government stepped in at the last minute and offered you a quick boost in December, when Congress voted to delay a decrease to the conversion factor until March 1. Therefore, you’re facing a conversion factor of $36.0846 for dates of service between Jan. 1, 2010 and Feb. 28, 2010.

The temporary fix was described by many as a way to keep physician pay stable while a more permanent fix was devised. However, it does not appear that Congress is ready to adjust the SGR process.

In the meantime, government sources have indicated that the temporary conversion factor freeze at $36.0846 may be extended through this coming fall. Congress is considering adding a provision to legislation that was written to create new jobs which would extend the conversion factor freeze, according to word from the National Public Radio blog.

Because a snowstorm has shut down most government offices, no official word has come down from Washington about the provision to the jobs bill, but keep an eye on the Insider for future developments.

@ Part B Insider

Get the latest coding information at Supercoder.com, and join the discussion at our Facebook Fan Page!

Related articles:

1. Proposed 2010 Physician Fee Schedule: A Closer Look21.5 percent cut looms for your services Last week, Coding...
2. SGR Update: What’s Up With That 21 Percent Physician Pay Cut? Here’s what you should be watching on Capitol Hill....
3. CMS Issues Corrections to 2009 Physician Fee Schedule Final RuleIt’s that time of year again — time to get...