Coding Strategy

MACs won’t process June claims until today, in hopes that Congress will act.

The Senate’s delays could mean serious payment crunches for your practice.

Last month, the freeze that has been keeping the Medicare conversion factor at 2009 levels expired, meaning that Part B practices were due to face a 21-percent cut effective for dates of service June 1 and thereafter. Because Congress had not yet intervened to stop those cuts, CMS initially instructed MACs to hold claims for the first 10 business days of June while lawmakers could deliberate whether to eliminate the looming cuts.

When the Senate reconvened on June 7, many analysts expected its members to vote on H.R. 4213, “The American Jobs and Closing Tax Loopholes Act of 2010,” which was expected to increase your payments through the end of this year, according to the text listed on the House Ways and Means Committee Web site. However, the bill has not passed, leading CMS to extend the MACs’ claims hold through June 17.

According to a June 14 CMS notification, the agency directed its contractors “to continue holding June 1 and later claims through Thursday, June 17, lifting the hold on Friday, June 18.”

CMS acknowledged in its June 14 notification that the lengthened claims hold period “may present cash flow problems for some Medicare providers. However, we expect that the delay, if any, beyond the normal processing period will be only a few days.”

The impact of the 17-day claims hold will vary, depending on the practice and how many Medicare patients it sees, says Quinten A. Buechner, MS, MDiv, CPC, ACSFP/GI/PEDS, PCS, CCP, CMSCS, president of ProActive Consultants in Cumberland, Wis.

Those practices with large Medicare populations could face a cash flow crisis, says Barbara J. Cobuzzi, MBA, CPC, CENTC, CPC-H, CPC-P, CPC-I, CHCC, president of CRN Healthcare Solutions, a coding and reimbursement consulting firm in Tinton Falls, N.J., and senior coder and auditor for The Coding Network.

“The claims hold effectively cuts off their Medicare pay for that period,” Cobuzzi says. “This has been happening almost monthly this year (with a few exceptions that gave us multiple month extensions).”

Avoid Holding Claims on Your Own

Some practices do not count on Medicare to do the claims hold correctly, so they are holding the claims themselves, Cobuzzi says. “In May, the MACs released payments before the fix was in, at the 21-percent reduction, and then those claims had to receive corrections,” she notes. “The practices that are holding their own claims figure that kind of mistake will not happen to them. But their delay will be even longer because they are not submitting to Medicare until the fix is voted on and then they have to wait the time period for Medicare processing.”

@ Part B Insider (Editor: Torrey Kim, CPC).

Sign up for the upcoming live audio conference, Risk Management Strategies for Healthcare Providers, or order the CD/transcripts.

Be a hero. Sign up for Supercoder.com, and join the coding community at the Supercoder.com Facebook Fan Page.

No legislative wrangling can take place until April 12.

Unless Congress steps in soon, you could be facing the 21.2 percent Medicare pay cut that you’ve feared since January.

Despite several Congressional attempts to cobble together another temporary pay fix to prevent cuts to your Medicare pay, no votes solidified these efforts. Lawmakers went on recess on March 29, leaving practices to face the 21.2 percent pay cut effective April 1.

Claims hold: Congress returns on April 12, and your MACs will wait until after that before they begin processing claims, in hopes that lawmakers will pass another extension to the pay freeze.

“CMS believes Congress is working to avert the negative update that will take effect April 1,” CMS noted in a March 26 email to providers. “Consequently, CMS has instructed its contractors to hold claims containing services paid under the MPFS … for the first 10 business days of April. This hold will only affect claims with dates of service April 1, 2010, and forward.”

Should you hold your claims? “If you can track submitted claims, then just keep sending them in. You can create a report from which you can resubmit or submit for an increase if they get paid on the old schedule that is updated,” advises Quinten A. Buechner, MS, MDiv, CPC, ACSFP/ GI/PEDS, PCS, CCP, CMSCS, president of ProActive Consultants in Cumberland, Wis.

If you can’t track the claims or easily find out which ones your MAC paid, then you might consider holding them. “This will prevent claims from getting lost in the system,” Buechner says. “The drawback is your claims will get in line after all the other claims already in-house at the carrier, so payment may be slower.”

Industry reaction: Physician groups, which have grown tired of the monthly extensions, expressed displeasure at the passing of the April 1 deadline.

“One month ago when Congress delayed this year’s 21 percent cut to April 1, we urged them to use this time wisely to repeal the payment formula that projects these cuts,” noted AMA president J. James Rohack, MD, in a March 26 statement. “It is unconscionable for elec-ted officials to play politics with se-niors and military families who rely on them to preserve their ability to see the physician of their choice.”

@ Part B Insider, Editor-in-Chief: Torrey Kim, CPC

Want to know more? Attend the 2010 Physician Fee Schedule: Rate Reductions, Imaging Accreditation, Stark Clarification and More (or order the transcript/CDs).

Be a hero. Join the coding community at Supercoder.com.

Check your 2010 consultation coding savvy.

Find out if you’re set to properly code your physician’s consultation services this year by tackling three problems and their solutions.

Check With Your MAC for Guidance

When your physician sees a Medicare inpatient and would have used an inpatient consultation code, this year you should report an initial hospital care code (99221-99223). If the E/M service and documentation do not meet the requirements of an initial inpatient hospital care code, however, your coding will now depend on your Medicare Administrative Contractor’s (MAC) or carrier’s policy.

Problem: The lowest initial hospital care code (99221) requires a detailed history and detailed exam. When your physician’s documentation does not reach this level, there is a question as to what CPT codes you should use.

Option 1: Some MACs/carriers have stated that you should use the subsequent hospital care codes (99231-99233). “Our MAC (Highmark) has actually stated to not use 99499 (Unlisted evaluation and management service) for consultations and to use subsequent care codes,” says Barbara J. Cobuzzi, MBA, CPC, CENTC, CPC-H, CPC-P, CPC-I, CHCC, president of CRN Healthcare Solutions, a coding and reimbursement consulting firm in Tinton Falls, N.J., and senior coder and auditor for The Coding Network. She adds that instructions about whether or not to use 99499 seem to be MAC-by-MAC specific right now.

Option 2: Other MACs, however, have instructed practices to use the Not Otherwise Classified (NOC) code 99499, says Quinten A. Buechner, MS, MDiv, CPC, ACSFP/ GI/PEDS, PCS, CCP, CMSCS, president of ProActive Consultants in Cumberland, Wis.

For example, WPS Medicare states on its Web site: “Many providers have questioned the use of a subsequent care code when the provider does not meet the requirements of an initial care code. Wisconsin Physicians Service (WPS) Medicare advises the use of Not Otherwise Classified (NOC) code 99499 as stated in the Internet-Only Manual (IOM).”

“Check with your contractor,” Buechner advises. “Code 99499 is the correct coding choice by CPT rules.” Some payers, such as Highmark, don’t seem to like that coding, however, so you need to know what code(s) your payers want you to use.

Important: Because five levels of inpatient consults are now billed using only three levels of inpatient E/M visits, some practices are seeking crosswalks that refer them from consult codes to E/M codes. But you should not rely on any such guides as the final word. Instead, when the practitioner performs an E/M service, report the code “that most appropriately describes the level of services provided,” notes MLN Matters article MM6740.

Stick With Two Letters for Admitting Physician

Admitting physicians now have a new modifier for their initial inpatient service. As of Jan. 1, if you’re billing for the admitting physician you must append modifier AI (Principal physician of record) to the initial visit code. This will denote the admitting physician who is overseeing the patient’s care, “as distinct from other physicians who may be furnishing specialty care,” according to CMS Transmittal 1875.

Example: A trauma surgeon admits from the emergency room a patient who was involved in a motor vehicle accident and calls in an orthopedic surgeon to perform a consult for multiple fractures in the patient’s leg. The trauma surgeon would report 99221-99223 (Initial hospital care, per day, for the evaluation and management of a patient …) with modifier AI appended. The orthopedic surgeon then bills 99221-99223 with no modifier for his initial examination of the patient whether the visit represents a consultation or a new visit.

Remember: The new modifier is made up of two letters. “Some people are interpreting the new modifier as a one,” Cobuzzi says. “But it’s two letters, A and I,” she reminds coders. Think: A-eye.

Skip 99241-99255 for Medicare, Even as Secondary

Don’t even think about billing a consult to Medicare — even if the claim is to a Medicare secondary payer (MSP).

The challenge: Medicare may have scratched consultations codes off its list of payable services, but many other insurers did not follow suit. This dual system leaves you in a quandary when your physician performs a consultation, and the primary non-Medicare insurer pays for the consultative service, but the secondary payer is Medicare.

The MSP “will not pay for consults,” says Samantha Daily, a medical biller for a practice in Portland, Ore.

Official word: MLN Matters article MM6740 indicates the following: “In MSP cases, physicians and others must bill an appropriate E/M code for the services previously paid using the consultation codes [99241-99255, Office or other outpatient consultation …]. If the primary payer for the service continues to recognize consultation codes” you should bill for secondary payment from Medicare in one of the following two ways:

• Bill the primary payer using an E/M code (not a consultation code), and then report the amount paid by the primary payer, along with the same E/M code, to the MSP for determination of whether additional payment is due; or
• Bill the primary payer using a consult code, and then report the amount paid by the primary payer, and change the code to the non consult E/M code (that is equal to the consultation code/service documented and paid), to the MSP for determination of whether you are owed additional payment.

Potential snag: In some cases the physician may not know whether a hospitalized patient is on Medicare or another insurance when he documents his consultation and determines code assignment for the billing department. You will need to be able to glean an appropriate E/M code from your physician’s consult documentation if the patient ends up also having Medicare as secondary insurance.

@ Medical Office Billing & Collections Alert

Be a hero. Join the coding community at the Supercoder Fan Page. There, you can find a FREE webinar from Jen Godreau about consult coding.

Related articles:

1. Think You Understand the New Consult Rules? Find Out FastTest your 2010 consultation coding understanding with these questions. Consultation...
2. Ask 3 Questions to Head Off 2010 Consult Problems Before They Start Ever used an unlisted E/M code? Get ready. By...
3. CMS Will Offer New Modifier to Denote Admitting Physician on ClaimsPop the champagne cork & get ready for brand new...

Test your 2010 consultation coding understanding with these questions.

Consultation coding has every practice on edge this year. Ensure that you’ve got a handle on this complicated coding and billing situation by trying your hand at this question.

Question: When a visit with a Medicare inpatient that would normally have been coded as a consultation does not meet the requirements of an initial inpatient hospital care code, what should you report?

Click ‘read more’ for answer …

Answer: Check With Your MAC for Guidance

When your physician sees a Medicare inpatient and would have used an inpatient consultation code, this year you should report an initial hospital care code (99221- 99223). If the E/M service and documentation do not meet the requirements of an initial inpatient hospital care code, however, your coding will now depend on your Medicare Administrative Contractor’s (MAC) or carrier’s policy.

Problem: The lowest initial hospital care code (99221) requires a detailed history and detailed exam. When your physician’s documentation does not reach this level, there is a question as to what CPT codes you should use.

Option 1: Some MACs/carriers have stated that you should use the subsequent hospital care codes (99231-99233). “Our MAC (Highmark) has actually stated to not use 99499 (Unlisted evaluation and management service) for consultations and to use subsequent care codes,” says Barbara J. Cobuzzi, MBA, CPC, CENTC, CPC-H, CPCP, CPC-I, CHCC, president of CRN Healthcare Solutions, a coding and reimbursement consulting firm in Tinton Falls, N.J., and senior coder and auditor for The Coding Network. She adds that instructions about whether or not to use 99499 seem to be MAC-by-MAC specific right now.

Option 2: Other MACs, however, have instructed practices to use the “Not Otherwise Classified” (NOC) code 99499, says Quinten A. Buechner, MS, MDiv, CPC, ACSFP/ GI/PEDS, PCS, CCP, CMSCS, president of ProActive Consultants in Cumberland, Wis. For example, WPS Medicare states on its Web site: “Many providers have questioned the use of a subsequent care code when the provider does not meet the requirements of an initial care code. Wisconsin Physicians Service (WPS) Medicare advises the use of Not Otherwise Classified (NOC) code 99499 as stated in the Internet-Only Manual (IOM).”

“Check with your contractor,” Buechner advises. “Code 99499 is the correct coding choice by CPT rules.” Some payers, such as Highmark, don’t seem to like that coding, however, so you need to know what code(s) your payers want you to use.

Important: Because five levels of inpatient consults are now billed using only three levels of inpatient E/M visits, some practices are seeking crosswalks that refer them from consult codes to E/M codes. But you should not rely on any such guides as the final word. Instead, when the practitioner performs an E/M service, report the code “that most appropriately describes the level of services provided,” notes MLN Matters article MM6740.

AUDIO: What surgical coders need to know about the 2010 consult revisions.

Stay tuned to Coding News for more consult coding quiz questions!

©Medical Office Billing & Collections Alert. Download 2 FREE sample issues here.

Related articles:

1. Think You Understand the New Consult Rules? Find Out FastCheck your 2010 consultation coding savvy. Find out if you’re...
2. Ask 3 Questions to Head Off 2010 Consult Problems Before They Start Ever used an unlisted E/M code? Get ready. By...
3. CMS Will Soon Issue Consult Code Replacement Advice, According to Open Door ForumPlus: You can now download a list of all practitioners...