appendix q: toxic release inventory for calendar year 2004

CMS & WPS

Medicare Physician Fee Schedule Database P.3.

OIG to Investigate E/M Notes “Cloned” by EHR Software P.3.

New WPS Website Area Dedicated To Claims Information P.3.

Allow 60 Days on Appeal Requests P.4.

MREP Update Available P.4.

Are you Submitting Adequate Docu‐mentation? Many are not. P.4.

5010 Batch Rejections Due to NPI & Submitter Name Not Rhyming. P.4.

Only one Electronic Remittance Advice per NPI/legacy number. P.5

Get on Board with PECOS P.5.

Revalidating Medicare Enrollment P.5.

Facts on Provider Compliance P.6.

Noridian DME

PECOS Warning Message on Ordering‐Referring Provider Not in System P.6,7

2011 1099 Tax Forms P.7.

CEDI Gateway Password Portal Secu‐rity Information Needed P.7.

HIPAA

ICD‐10 to be Delayed P.8. 5010 Editing For Not Otherwise Classi‐fied (NOC) Codes P.8.

AOA on Coding

More on New CPT Therapeutic CL Codes 92071 and 92072 P.10.

Stages of Glaucoma for ICD‐9‐CM Diagnosis Coding P.10.

Discounting for Payment the Day of Services? P.11

Medicaid

Medicaid Managed Care In Greater Nebraska P.2.

EHR

Stay Informed Via CMS’ EHR Incentive Programs Listserv P.9.

CMS Has Updated the EHR Informa‐tion Center with New Self‐Service Options P.9.

March 2012

Nebraska Optometric Association Volume 12, Number 3

NOA 3rd Par ty Newsletter

Be sure to attend this important program on Electronic Health Records (EHR).

These courses are part of Phase II in AOA's EHR Preparedness Program.

Last year, NOA offered Phase I: "Enhancing Patient Care through the Implementation of EHRs."

In Phase II, Dr. Jay Henry will provide a de‐tailed update on meaningful use and incentive programs as well as successful implementation of PQRS and e‐Prescribing.

The March 14 courses are: EHR Incentive Programs and Meaningful Use Update (2 hours) This course will provide details of the CMS EHR Incentive Programs including requirements, incentives, penalties, and registration and attestation process. Meaningful Use objectives will be covered in detail including requirements, clinical implications, ex-emptions, and compliance.

Physician Quality Reporting System (PQRS) and e-Prescribing Made Easy (2 hours) This course will provide information on the clinical importance of PQRS and e-Prescribing. It will provide examples as well as a process to allow the successful implementation of PQRS reporting and e-Prescribing.

Part of the AOA's Electronic Health Records Preparedness Program, the EHR courses reflect the strategic goals of the AOA. They are intended to serve as the optometrist's primary HIT resource, with the most current information on Meaningful Use, Federal Incentives, Implementation of EHRs, e-Prescribing and Quality Re-porting. For AOA's information page on EHR, go to http://aoa.org/x18599.xml.

Register here:

Register and pay online (credit card only) at http://nebraska.aoa.org/x17455.xml

Fill out form and send in registration at http://nebraska.aoa.org/Documents/NE/2012LegConf_EHR_RegPrint.pdf

Qualifies for 4 hours of CE for both ODs and Paras. Paras are welcome - however, registrations must be ac-companied by an OD registration from that practice.

AOA EHR Courses At 1:30 on March 14th At Cornhusker Hotel

The Department of Health and Human Services, Division of Medicaid and Long-Term Care (MLTC) is planning an expansion of the physical health managed care program statewide effective July 1, 2012. The Intent to Award has been issued and is available at the following website: http://www.das.state.ne.us/materiel/purchasing/3792.htm

MLTC will be implementing two (2) health plans to manage physical health services for clients in the 83 counties not currently served by Physical Health Managed Care. MLTC intends to contract with:

Coventry Cares, by Coventry Healthcare of Nebraska, Inc.

Arbor Health, by Amerihealth Nebraska via BCBS.

Providers must enroll as a network provider with these new plans to be able to serve their respective managed care clients.

For those interested, contact information for enrolling is as follows...

Coventry Cares, by Coventry Healthcare of Nebraska, Inc: Medical Diagnosis: If you wish to see Coventry Cares Medicaid patients with medical diagnoses, you will need to enroll with the Coventry Cares MCO, even if you were previously a Coventry pro-vider. The Coventry Cares enrollment contact for medical diagnoses is

Scott Davis Manager, Network Development 402-995-7174 (800) 471-0240 Ext. 7174 [email protected] 15950 West Dodge Road Omaha, NE 68118

Routine Care: As with the Coventry MCO in the eastern 10 counties of Nebraska, Block Vision will be the routine care benefit manager. To enroll with Block Vision and be included in their directory, return your contract packet to Block Vision by March 15. If you need a contact packet re-sent to you, call 1-800-243-1401 x 1067 and they will send one to you right away. For contract questions call:

Monica Jenifer-Sr. Network Development Specialist 1-800-243-1401 x 1067 [email protected]

Teresa Moragne El-Sr. Network Development Specialist 1-800-243-1401 x 1067 [email protected]

Arbor Health, by Amerihealth Nebraska via BCBS. As of press time, contact information for Amerihealth Nebraska had not been received by Dr. Quack. He will forward it via mass email as soon as it is received.

More on Medicaid Managed Care In Greater Nebraska

Medicaid will be implementing two

Managed Care health plans in the

83 counties not currently served by

Physical Health Managed Care.

Coventry Cares, by Coventry Healthcare of Nebraska, Inc.

Arbor Health, by

Amerihealth Nebraska via

BCBS.

NOA 3rd Par ty Newslet ter

1633 Normandy Court, Suite A Lincoln, NE 68512

Nebraska Optometric Association

The NOA Third Party Newsletter is published monthly by the Nebraska Optometric Association with the assistance of Ed Schneider, O.D., Third Party Consultant. To reach Ed (aka Dr. Quack):

BEST to contact via Email at: [email protected]

Ed’s mobile phone is 402-310-2367. Voicemail available, but delays are possible.

Fax number is 402-464-1214. Call Ed before faxing.

Allow 60 Days on Appeal Requests

WPS Medicare has seen an increase in the number of duplicate appeal (redetermination) requests. Medicare contractors have 60 days to complete an appeal request. Please do not submit duplicate appeal requests, as they represent unnecessary costs and duplicative efforts to both the Medicare Program and your office. For additional information, please refer to http://www.wpsmedicare.com/j5macpartb/departments/appeals/duplicate-appeal-requests.shtml.

The Centers for Medicare & Medicaid Services (CMS) has a resource designed to help providers determine if a procedure code is payable by Medicare and how it should be reimbursed. It is named the Medicare Physician Fee Schedule Database (MPFSDB) or the Relative Value Files. It explains payment on bilateral vs. unilateral surgery, when multiple surgeries are appropriate, etc. Just enter the CPT code in question, and follow directions. Interested in learning more? Read more at http://www.wpsmedicare.com/j5macpartb/resources/new_providers/_files/mpfs-database.pdf.

In an effort to improve your website experience, WPS recently reorganized the Claims information on our web-site. You can now access information on claims submission, claims processing, claim denials, and claim rejec-tions by selecting the "Claims" tab from the top navigation. This change will help you more quickly and easily locate the claims information you need. Let us know what you think of this change, and your overall website experience, by completing the ForeSee website satisfaction survey next time it is presented to you. Please note, you may have to recreate any bookmarks you had saved for claims-related information. You can find the Claims page at http://www.wpsmedicare.com/j5macpartb/claims/.

Medicare Physician Fee Schedule Database (MPFSDB)

New WPS Website Area Dedicated To Claims Information

Office of Inspector General to Investigate E/M Notes “Cloned” by EHR Software

Do you take notes from a previous visit and “clone” them into the current visit? If so, WPS reports that you may be the target of the Office of the Inspector General.

The following information abridged from a PowerPoint presentation by Ken Bussan, MD, Medical Director of Wisconsin Physician Services, was presented to the Medicare Medical Advisory Committee in early 2012.

In a classic example of EHR-cloned notes, the doctor, in a follow-up visit, will take the note from the previous visit and bring virtually the whole old history of present illness into the new note. It’s hard to blame time-pressed physicians for using their expensive new electronic health records (EHR) systems to optimize their E/M notes. Cloned notes are the unfortunate byproduct of computer-automated exam notes. But ‘errors’ like these are caus-ing Medicare contractors and the OIG to audit and in some cases recoup payments. [Note: it seems to Dr. Quack that the real problem is the EHR software then determining an erroneously high exam level based on the presence of the cloned HPI, when a more abbreviated HPI would have been appropriate for the follow-up visit.]

The Medicare contractor, CERT contractor, or OIG auditor may then decide to review 20 of the doctor’s notes, and if they all look the same, the doctor faces 100% pre-payment review. The OIG 2012 Work Plan states it again will study E/M documentation, specifically cloned notes.

The OIG 2012 Work Plan states it again will study E/M documen-tation, specifically cloned notes.

Vo lum e 12, Num ber 3

WPS recently reorganized the Claims information on its website.

Insurance Claim

A new version of the Medicare Remit Easy Print (MREP) software (version 3.2.2) dated December 15, 2011, is available to download from the CMS website at http://www.cms.gov/AccesstoDataApplication/02_MedicareRemitEasyPrint.asp. This version includes the latest Code Group Information (Codes.ini 11-7-11). If you are an electronic biller who does not receive the Electronic Remittance Advice (ERA) and would like to, please complete the ERA information sheet located at http://www.wpsic.com/edi/pdf/Medicare-provider-authorization-ERA.pdf. If you already receive the ERA and want to try the MREP software, please download the MREP software at http://www.cms.gov/AccesstoDataApplication/02_MedicareRemitEasyPrint.asp. If you are not an electronic biller and want to receive ERA to use in the MREP software, you will need to com-plete a Request for Submitter form, an EDI Enrollment form, and an ERA Request form. Please label MREP only. You can download these forms from the following websites:

http://www.wpsic.com/edi/pdf/medb_profile.pdf http://www.wpsic.com/edi/pdf/medb_enroll.pdf http://www.wpsic.com/edi/pdf/Medicare-provider-authorization-ERA.pdf

If you have questions about this or any other Medicare electronic billing issue, please contact EDI at (866) 503-9670.

WPS: The error message STC*A8:496:85 is a batch rejection for 5010A1 claim files. Receiving this error means the National Provider Identifier (NPI) and the submitter ID combination are not valid on the Medicare electronic provider file.

This error message was informational for 4010A1 electronic claim files. For 5010A1 claim files, this is a batch rejection on the 277CA. Previously, when sending 4010A1 files, the error message that you would have received would have been: M013 PROV/SUB ID MISMATCH

If you receive this error on your 5010A1 277CA, you will need to complete an EDI Enrollment form or EDI Change of Submitter form and fax it to the EDI Department at the numbers below so we can update our files. You can find these forms on the following web page: http://www.wpsic.com/edi/get_started.shtml.

If you have questions about this or any other Medicare electronic billing issue, please contact EDI:

Phone: (866) 503-9670 Fax: (608) 223-3824

Medicare Remit Easy Print - February 2012 Update

5010 Batch Rejection due to NPI and Submitter Combination

Are You Submitting All Supporting Documentation For Diagnostic Services?

WPS Medicare continues to see significant Comprehensive Error Rate Testing (CERT) error findings for insuffi-cient documentation of diagnostic services. The majority of these findings are due to lack of a signed physician order or progress note supporting the intent for the service(s) to be rendered and documentation to support the medical necessity of the service(s).

Providers must include all documentation to support services billed in response to a Medicare medical record request. If necessary, you may need to contact another facility (e.g., physician office, nursing home, hospital) to obtain the necessary supporting documentation for services billed. To avoid this type of finding, we recommend periodic self audits of your medical record documentation. Corrective action taken now can improve future re-view results and expedite processing of Medicare medical records requests. For more information on Medicare requirements for diagnostic services, read the full article on our CERT page:

http://www.wpsmedicare.com/j5macpartb/departments/cert/phys-orders-dx.shtml


Receiving error message

STC*A8:496:85 means the National Provider Identi-fier (NPI) and the submit-ter ID combination are not valid on the Medicare electronic provider file.

Providers must include all documentation to support services billed in re-sponse to a Medicare medical record request.

A new version of the Medicare Remit Easy Print (MREP) software dated December 15, 2011, is available to download from the CMS.

In order to accurately produce electronic remittance advices to match the EFT/check amount, Medicare’s Multi-Carrier System will, effective Sun. April 1, 2012, no longer consider the sender information when creating the ERA files. WPS will allow only one receiver of an electronic remittance per NPI/legacy ID regardless of whether the provider submits their inbound files under different sender IDs. WPS should be contacting you if you are set up on their files for multiple receivers of the ERA, in which case you will need to select one receiver for your electronic remittance.

Section 6401 (a) of the Affordable Care Act established a requirement for all enrolled providers and suppliers to revalidate their enrollment information under new enrollment screening criteria. This revalidation effort applies to those providers and suppliers that were enrolled prior to March 25, 2011. Newly enrolled providers and suppliers that submitted their enrollment applications to CMS on or after March 25, 2011, are not impacted. Between now and March 23, 2015, MACs will send out notices on a regular basis to begin the revalidation process for each provider and supplier. Providers and suppliers must wait to submit the revalidation only after being asked by their MAC to do so. Please note that 42 CFR 424.515(d) provides CMS the authority to conduct these off-cycle revalidations.

Were you sent a revalidation request?

In the "Downloads" section below is a listing of all providers and suppliers who have been mailed a revalidation notice. The files are broken down by the month in which the revalidation request was mailed. CMS will add lists on a bimonthly basis. If you are listed, and have not received the request, please contact your Medicare contractor. Their contact information can be found in the Downloads section below.

Would you like to learn more?

In the "Related Links Inside CMS" section below you will find the transcript of the October 27, 2011 National Provider Call about the Revalidation of Medicare Enrollment. You will also find helpful articles about the revalidation process, enrollment provisions of the Affordable Care Act and how to pay your enrollment application fee.

(Continued on page 6)

Only One Electronic Remittance Advice Recipient beginning April 1st

Revalidating Your Medicare Enrollment

Get On Board with PECOS: Major Improvements to Medicare Online Enrollment System

Over the last year, CMS has listened to your feedback about the Medicare online enrollment system, PECOS (“Provider Enrollment, Chain, and Ownership System”). As a result, we’ve made upgrades in order to reduce data entry time and increase access to information.

Providers and staff using internet-based PECOS will now see the following improvements: Electronic Signature – You now have the ability to digitally sign and certify the application. Access to More Information – Now you can see if a request for revalidation has been sent by your MAC. Multiple Views of Your Information – Switch between Topic View and Fast Track View:

The Fast Track View allows you to quickly review all enrollment information on a single screen.

Overall Usability – We are making the system easier to use: You can access previously-used address information when completing an application. You can quickly update and resubmit an application returned for correction via internet-based

PECOS as part of any application submission. You will have fewer screens and steps to navigate when you are changing information or

revalidating your application(s).

Learn more about PECOS at https://PECOS.CMS.hhs.gov, and be on the look-out for more enhancements in the coming months! And see the next article on using PECOS to revalidate your Medicare Enrollment.

There are recent upgrades to

PECOS. Once signed up, it

makes your interactions with

Medicare much simpler.


Between now and March 23,

2015, WPS and Noridian will

send out notices on a regular

basis to begin the revalidation

process for each provider and

supplier.

Still have questions?

Questions concerning provider enrollment policy or your provider's situation should be referred to your MAC. Their contact information can be found in the "Downloads" section below. Questions concerning a system issue regarding PECOS should be referred to the CMS EUS Help Desk at 1-866-484-8049, or send an e-mail to [email protected]. Source: https://www.cms.gov/MedicareProviderSupEnroll/11_Revalidations.asp

Using the Internet-based Provider Enrollment, Chain and Ownership System (PECOS)

To revalidate via the Internet-based PECOS, go to http://www.cms.hhs.gov/MedicareProviderSupEnroll. This system allows you to review information currently on file, update and submit your revalidation via the internet. Once submitted, be sure to print, sign, date, and mail the certification statement along with all required supporting documentation. In order for us to process the revalidation, the original signature and documentation must be received within seven (7) days of internet submission.

In order to access the PECOS, your Authorized Official must register with the PECOS Identification and Authen-tication system. If you have not registered, do so now by going to https://pecos.cms.hhs.gov. To avoid any registration issues, review the PECOS related documents available on the CMS Web site

http://www.cms.hhs.gov/MedicareProviderSupEnroll..

This registration process can take up to three (3) weeks. If additional time is required to complete the revalida-tion, you may request one 60-day extension, which will begin the date requested.

Source; https://www.cms.gov/MedicareProviderSupEnroll/Downloads/NSC_RevalidationLetter.pdf

(Continued from page 5)


From the MLN: New Fast Fact on MLN Provider Compliance Webpage - A new fast fact is now available on the MLN Provider Compliance webpage:

http://www.cms.gov/MLNProducts/45_ProviderCompliance.asp. This webpage provides the latest Medicare Learning Network products designed to help Medicare Fee-For-Service providers understand – and avoid – common billing errors and other improper activities. Please bookmark this page and check back often as a new fast fact is added each month!

Effective January 1, 2012, the DME MACs will begin to return the warning messages if the ordering or referring provider on the claim is not eligible to order or refer DME supplies as determined from PE-COS. These messages will be returned on the Electronic Remittance Advice (ERA) or Standard Paper Remit (SPR) with the following Remittance Advice Remark Code (RARC) and will apply to both 4010A1 and 5010A1 formatted claims:

N544 - Alert: Although this was paid, you have billed with a referring/ordering provider that does not match our system record. Unless corrected, this will not be paid in the future.

Through January 29, 2012, CEDI will continue to return the PECOS warning edits for 4010A1 claims on the GenResponse Report.

CMS and the DME MACs will communicate when the edits will become denials when that date is de-termined.

If you have any questions regarding the CEDI PECOS warning edits, please send an e-mail to [email protected] or call 866-311-9184.

Noridian: PECOS Warning Message Returned on Remittance Advices when Ordering/Referring Provider not in System

Internet-based PECOS allows

you to review information

currently on file, update and

submit your revalidation via

the Internet.

Effective January 1, 2012, the DME MACs will begin to return the warning messages if the ordering or refer-ring provider on the claim is not eligible to order or refer DME supplies as deter-mined from PECOS.

CEDI is requesting all Trading Partners access the CEDI Gateway Self-Service Password Portal on our CEDI Web site www.ngscedi.com and enter their security information. This security information will be required when our front-end system is upgraded in 2012.

To provide the security information, select the “Change/Reset Your Trading Partner Password” button on the CEDI Gateway Self-Service Password Portal page. A pop-up screen will ask if you want to “Proceed with Password Reset/Change” or “Provide Security Info.” Select the “Provide Security Info” to provide the security information CEDI needs. You will not be required to change or reset your password after the security information has been added.

CEDI has provided a step-by-step instruction document Providing Security Information Instructions found at http://www.ngscedi.com/PasswordReset/ProvidingSecurityInformationInstructions.pdf ,for more detail on what information will be requested and how to submit this information. Once the security information has been entered, it cannot be changed until the front-end system is upgraded later in 2012.

Please contact the CEDI Help Desk at [email protected] or at 866-311-9184 with any questions about this process.

CEDI Gateway Self-Service Password Portal Security Information Needed


You should ensure that any items or services submitted on Medicare claims are referred or ordered by Medicare enrolled providers of a specialty type author-ized to order or refer the same.

Medicare will only pay for items or services for Medicare beneficiaries that have been ordered by a physician or eligible professional who is enrolled in Medicare and their individual National Provider Identifier (NPI) has been provided on the claim. The ordering provider or supplier (physician or eligible professional) must also be enrolled with a specialty type that is eligible (per Medicare statute and regulation) to order and refer those particular items or services.

You should ensure that any items or services submitted on Medicare claims are referred or ordered by Medicare enrolled providers of a specialty type authorized to order or refer the same. You must also place the ordering or referring provider or supplier’s NPI on the claim you submit to Medicare for the service or item you provide.

Important Reminder for Providers and Suppliers Who Pro-vide Services and Items Ordered or Referred by Other Pro-viders and Suppliers

All 1099s for the Noridian Administrative Services DME Jurisdiction D were mailed January 30, 2012. To streamline the process, NAS has consolidated the 1099s for each Tax Identification Number (TIN) within a single mailing to ensure proper receipt. Previously, 1099s were generated and sent to the payee address re-ceived from the National Supplier Clearinghouse (NSC) which was also the same address used in sending Medicare payments and remittance advices.

The reporting requirements of the Internal Revenue Code, Section 6041A states that any service-recipient engaged in a trade or business that pays in the course of such trade or business during any calendar year remuneration for such services in the aggregate of $600 or more, must file an information return.

If you feel that the dollar amounts on the 1099 are incorrect, please contact the NAS Supplier Contact Center, (866) 243-7272, to report your concerns so we may further investigate.

If the address information or TIN listed on the 1099 form is incorrect, suppliers should work directly with the NSC, (866) 238-9652, http://www.palmettogba.com/nsc, in order to correct their DME supplier records.

https://www.noridianmedicare.com/cgi-bin/coranto/viewnews.cgi%3fid=EFkAEuZAkELNkhQYnn&tmpl=dme_viewnews&style=part_ab_viewnews

1099 Information for 2011 Mailed for DME Suppliers

As part of President Obama’s commitment to reducing regulatory burden, Health and Human Services Secretary Kathleen G. Sebelius today announced that HHS will initiate a process to postpone the date by which certain health care entities have to comply with International Classification of Diseases, 10th Edition diagnosis and procedure codes (ICD-10).

The final rule adopting ICD-10 as a standard was published in January 2009 and set a compliance date of October 1, 2013 – a delay of two years from the compliance date initially specified in the 2008 proposed rule. HHS will announce a new compliance date moving forward.

“ICD-10 codes are important to many positive improvements in our health care system,” said HHS Secretary Kathleen Sebelius. “We have heard from many in the provider community who have con-cerns about the administrative burdens they face in the years ahead. We are committing to work with the provider community to reexamine the pace at which HHS and the nation implement these important improvements to our health care system.”

ICD-10 codes provide more robust and specific data that will help improve patient care and enable the exchange of our health care data with that of the rest of the world that has long been using ICD-10. Entities covered under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) will be required to use the ICD-10 diagnostic and procedure codes.

HHS Announces Intent to Delay ICD-10 Compliance Date

The 5010 electronic media claims (EMC) system reviews every claim for a number of edits to ensure that claim data is valid. The 5010 professional claim transaction (837P) requires that when a non-specific or Not Otherwise Classified (NOC) procedure code is used (in the 2400/SV101-2), then a de-scription is required in the 2400/SV101-7. The 5010 TR3 instructs, "Use SV101-7 to describe non-specific procedure codes." While the 4010 837 professional claim submission allows for use of the NTE segment to include a description; however, 5010 specifically warns, "Do not use this NTE Seg-ment to describe a non-specific procedure code." The SV101-7 allows for 80 bytes (aka characters, including spaces) of information. You can access a current list of the procedure codes that require the SV101-7 on the following CMS website: http://www.cms.gov/ElectronicBillingEDITrans/40_FFSEditing.asp#TopOfPage Please note that this list is subject to change. Please visit our 5010 readiness site http://www.wpsic.com/edi/5010-Readiness.shtml. If you need additional information you may also contact the WPS EDI Hotline at (866) 503-9670.

Revised 5010 Editing For Not Otherwise Classified (NOC) Codes

The 5010 professional claim transaction

requires that when a non-specific or Not

Otherwise Classified (NOC) procedure

code is used, then a description is

required in the 2400/SV101-7.


We want to invite you to join a free email service to receive CMS' latest news on the EHR Incentive Programs. The CMS EHR Incentive Program listserv provides timely information on program requirements and changes in the EHR Incentive Programs at https://www.cms.gov/EHRIncentivePrograms/65_CMS_EHR_Listserv.asp#opOfPage.

By subscribing to this listserv, you will receive early notification of new program developments, the availability of new resources, and the addition of any new Frequently Asked Questions that are published on the CMS EHR Incentive Programs' website.

Click https://public.govdelivery.com/accounts/USCMS/subscriber/new?topic_id=USCMS_627 to join the listserv and visit the listserv sec-tion of the EHR Incentive Programs website to take a look at some of the recent messages we have sent. We encourage you to let others know about the CMS EHR Incentive Program listserv, and to share its messages.

Note: Make sure to add [email protected] to your approved senders list so that the EHR Incentive Pro-grams listserv messages do not get caught in your spam folder.

Want more information about the EHR Incentive Programs?

Make sure to visit the EHR Incentive Programs website http://www.cms.gov/EHRIncentivePrograms/ for complete information about the CMS Medicare and Medicaid EHR Incentive Programs.

Stay Informed Via the CMS’ EHR Incentive Programs Listserv

CMS Has Updated the EHR Information Center with New Self-Service Options

Following months of review and collective input, the Electronic Health Record (EHR) Information Center Inter-active Voice Response (IVR) system has been enhanced to provide users with an increased number of options and services to make accessing and reviewing data easier than ever before.

For eligible professionals (EPs), eligible hospitals or critical access hospitals (CAHs), the revised functionality vastly improves the efficiency in obtaining the desired information, while also offering a more varied amount of information and options for callers.

CMS is proud to announce that providers can now obtain information through an extensive IVR Self-Service option. Included in this option is a reinforced privacy protection module that requires your individual National Provider Identifier (NPI), the last five digits of your Tax Identification Number (TIN) and your EHR registration ID. Once accepted, this newly enhanced Self-Service tool allows you to: Obtain registration status Acquire attestation status Review payment information Check progress towards meeting the $24,000 threshold amount Users may access these new options by following the steps outlined below: Begin by dialing (888) 734 6433 Press 3 for Self Service Enter the authentication elements These options will be available on the IVR effective February 16, 2012.

EHR Information Center Hours of Operation: 7:30 a.m. – 6:30 p.m. (Central Time) Monday through Friday, except federal holidays. (Please note that General Information and Self-Service options may be reached via IVR 24 hours a day, except during periods of planned system maintenance or upgrades).

Supplementary information on the program may also be viewed by visiting the FAQs section of the EHR Incen-tive Programs website https://www.cms.gov/EHRIncentivePrograms/95_FAQ.asp#opOfPage, where users can search for any ques-tions they have about the Medicare or Medicaid EHR Incentive Programs.

Want more information about the EHR Incentive Programs? Make sure to visit the EHR Incentive Programs website for the latest news and updates on the EHR Incentive Programs at http://www.cms.gov/EHRIncentivePrograms/

Providers can now obtain information

through an extensive IVR Self-Service op-tion. Included in this

option is a rein-forced privacy pro-tection module that requires your indi-

vidual National Pro-vider Identifier (NPI), the last five digits of your Tax Identifica-tion Number (TIN)

and your EHR regis-tration ID.


Join a free email ser-vice to receive CMS'

latest news on the EHR Incentive Programs.

From the AOA: The American Medical Association's Current Procedural Terminology (CPT) Editorial Panel has created two new special ophthalmological codes for services for reporting the use of therapeutic contact lenses: 92071 – fitting of contact lens for treatment of ocular surface disease –and 92072 – fitting of contact lens for man-agement of keratoconus, initial fitting. These new codes replace the 92070, "Fitting of contact lens for the treat-ment of disease, including supply of lens," which has been deleted by CPT. Both 92071 and 92072 are consid-ered 'per lens,' reported with RT or LT modifier to indicate which eye, and neither code includes the supply of the contact lens.

When reporting either 92071 or 92072, providers should bill the appropriate evaluation and management or gen-eral ophthalmological service code for the patient visit, the 92072 or 92071 for the fitting, and the appropriate supply code for the lens used in the fitting.

The new codes do not include the supply of the lens, which may be reported using either 99070, "supplies and materials (except spectacles), provided by the physician over and above those usually included with the office visit or other services rendered," or the appropriate code from Healthcare Common Procedure Coding System (HCPCS), either a V code or the S0500 code (disposable contact lens). Since Medicare and many other medi-cal insurers do not reimburse for 99070, the HCPCS code will usually be chosen for reporting the supply of the contact lens. The code used to report the supply of the lens is assumed to include the procurement cost of the lens itself as well as any related costs: postage, handling, etc.

When the patient returns for additional care after the lens is provided, CPT states: "For subsequent fittings, report (the service) using evaluation and management services or general ophthalmological services."

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AOA: More on New Therapeutic CL Codes 92071 and 92072

From the AOA: Glaucoma coding changed as of October, 2011. Borderline glaucoma, previously ICD-9-CM code 365.0, has been replaced by codes 365.01, 365.02, 365.05.

All existing glaucoma diagnosis codes (365.10-365.65) will now need to be reported in combination with new codes (365.70-365.74) to provide information regarding the stage of the disease.

An example of the definitions of the severity of glaucoma as stated by the American Glaucoma Society is as follows:

Mild Stage: optic nerve changes consistent with glaucoma but NO visual field abnormalities on any visual field test OR abnormalities present only on short-wavelength automated perimetry or frequency doubling perimetry.

Moderate Stage: optic nerve changes consistent with glaucoma AND glaucomatous visual field abnormalities in one hemifield and not within 5 degrees of fixation.

Severe Stage: optic nerve changes consistent with glaucoma AND glaucomatous visual field abnormalities in both hemi-fields and/or loss within 5 degrees of fixation in at least one hemi-field.

The new ICD 9 diagnostic coding of glaucoma adds new complexity to coding for your glaucoma patients. The new glaucoma diagnostic codes and the new stage codes will mean providers will need to take greater care when coding for glaucoma patients.

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AOA: Stages of Glaucoma for ICD-9-CM Diagnosis Coding

More information on recent changes

in Therapeutic Contact Lens

Coding, including AOA coding

recommendations on the supply of

the CL.

Discounting for Payment The Day of Services

Dear Dr. Quack, How much can a provider discount their fees for cash payment and still be credible?

Dr Quack’s Quote: As you know, you must charge all patients your usual and custom-

ary fees, including private pay patients. Regarding a discount for payment the day of services, Lance Plunkett JD, AOA attorney, addressed this topic some time ago in the following (abridged) AOA memo, previously printed in the NOA 3rd Party Newsletter in October of 2003.

§

...The fraud issue is generated when an optometrist lists on an insurance form a fee that is different from the fee actually charged to patients. The question then becomes whether or not the optometrist is merely charging a higher fee because of the insurance, when the real fee is much less, or whether the fee listed on the insurance form is accurate, but a legitimate cash discount happens to be given to patients without insurance that might reduce the fee in those instances. Some states (e.g., New York) take a dim view of this practice, and others (e.g., Ohio) appear to have no problem with the practice.

It should be noted that waivers of insurance co-payments or out-of-plan charges differ from a cash discount to a patient who pays a bill with no insurance in-volved. The former is almost always viewed as fraud when routinely engaged in by a health care provider, whereas the true cash discount to a patient who does not use insurance to pay the claim is not automatically viewed that way. How-ever, in all cases it must be clear that the cash discount is genuine. If the under-lying purpose is to list inflated fees on an insurance reimbursement form, then fraud is more likely to be found. If the underlying purpose is to provide a justifi-able discount for immediate cash payment, then no fraud is likely to be found. In assessing these two possibilities, the claimed intent of the optometrist is of mini-mal importance – what counts is the objective appearance of the discount. The objective appearance will be measured in quantifiable economic terms. If the discount is excessive (e.g., a regular 80% discount), then it is likely to be consid-ered economically impractical and not a true discounted price vis-à-vis the price charged to an insurance company. Instead, such a discounted price will be viewed as the true price and the insurance company charge will be viewed as a fraudulent inflation of the true price. On the other hand, a 5% discount for paying

(Continued on page 12)


Dr. Quentin Quack’s Queries and Questionable Quotes ~~~~~~~~~~~~~~~~~~~~~~~~~~

Third Party Questions from NOA Doctors and Staff Dr. Quentin Quack

The Federal Trade Commission has

generally indicated that it views any rou-tine discount in ex-

cess of 25% with suspicion that it is not a genuine dis-

count, but a reflec-tion of the true price.

The FTC indicates that it analyzes how much overhead is

really being saved. If the net savings

appears to be unre-alistic, then the dis-count will be viewed

as phony.


Dr. Quentin Quack’s Queries and Questionable Quotes—continued...

cash is much less likely to be deemed to be economically impractical.

The Federal Trade Commission has generally indicated that it views any routine discount in excess of 25% with suspicion that it is not a genuine discount, but a reflection of the true price. The Federal Trade Commission indicates that it ana-lyzes such situations from the perspective of how much is really being saved (in this case from administrative and paperwork expenses by not using insurance claims processes) as against the actual cost of providing the service (including other office overhead costs, equipment costs, labor costs, etc.). If the net savings appears to be unrealistic vis-à-vis a high percentage cash discount, then the discount will be viewed as phony, and the higher prices charged to persons with insurance will be viewed as fraudulent inflation of the fees for insurance purposes. The Federal Trade Commis-sion engages in elaborate and highly sophisticated economic modeling and analysis to assess such situations. It is not helpful for optometrists to latch onto the idea that cash discounts may be legally possible, and then use bizarre methods for justifying outlandish discounting practices. The Federal Trade Commission would not accept economic justifications that do not meet rigorous, ac-cepted economic standards. Persons who tout special formulas or methods that will help optometrists arrive at unusually large discounts are essentially pro-moting clever disguises for fraud that are not going to fool government authori-ties.

On top of the Federal Trade Commission’s general analysis of cash discounting and price discrimination, some states have insurance anti-discrimination provisions that outlaw altogether having different charges for insured versus non-insured patients, and in those states the concept of a cash discount would be statutorily prohibited for patients. Before the Federal Trade Commission attacked “most favored nation” clauses in insurance contracts as being a form of price fixing, many insurers effec-tively outlawed cash discounts through these contract clauses (requiring the optome-trist to give the insurer the benefit of the lowest price the optometrist charged to any other entity). However, some states have directly enacted by statute the same type of prohibition, and such state laws are beyond the jurisdiction of the Federal Trade Commission to overrule. Blanket advice to optometrists that they should give large “cash discounts” and bill insurers much higher fees is legally question-able and may lure optometrists into unwittingly committing insurance fraud. Certainly, any such incautious advice should be ignored in the context of a federally funded program such as Medicare. Perhaps more importantly, every optometrist needs to check with their state insurance authorities to see if it would be downright illegal to act on such advice in their particular state. Moreover, no optometrist should attempt a large-scale cash discount program without first consulting a knowledgeable attorney. However, all those warnings having been heeded, in appropriate states op-tometrists can safely offer reasonable cash discounts.

(Continued from page 11)

Waivers of insurance co-payments or out-of-

plan charges are al-most always viewed as

fraud when routinely engaged in by a health

care provider.

The FTC would not accept economic

justifications for dis-counts that do not meet rigorous, ac-cepted economic

standards.

Ludicrous questions asked by Attorneys while interrogating witnesses (Part II)

The following excerpts appeared in the Salt Lake Tribune. They were taken from real court records.

Now doctor, isn't it true that when a person dies in his sleep, in most cases he just passes quietly away and doesn't know anything about it until the next morning?

Q: What happened then? A: He told me, he says, "I have to kill you be-cause you can identify me." Q: Did he kill you?

Was it you or your brother that was killed in the war?

The youngest son, the 20-year-old, how old is he?

Q: She had three children, right? A: Yes. Q: How many were boys? A: None. Q: Were there any girls?

Were you alone or by yourself?

Q: I show you Exhibit 3 and ask you if you recog-nize that picture? A: That's me. Q: Were you present when that picture was taken?

Were you present in court this morning when you were sworn in?

Q: You say that the stairs went down to the base-ment? A: Yes. Q: And these stairs, did they go up also?

Q: Now then, Mrs. Johnson, how was your first marriage terminated? A: By death. Q: And by whose death was it terminated?

Q: Do you know how far pregnant you are now? A: I'll be three months on March 12th. Q: Apparently then, the date of conception was around January 12th? A: Yes. Q: What were you doing at that time?

Do you have any children or anything of that kind?

Was that the same nose you broke as a child?

Q: Mrs. Jones, do you believe you are emotion-ally stable? A: I used to be. Q: How many times have you committed sui-cide?

So, you were gone until you returned?

You don't know what it was, and you didn't know what it looked like, but can you describe it?

Q: Have you lived in this town all your life? A: Not yet.

A Texas attorney, realizing he was on the verge of unleashing a stupid question, interrupted him-self and said, "Your Honor, I'd like to strike the next question."

Q: Do you recall approximately the time that you examined that body of Mr. Huntington at St. Mary's Hospital? A: It was in the evening. The autopsy started about 5:30 P.M. Q: And Mr. Huntington was dead at the time, is that correct? A: No, you idiot, he was sitting on the table won-dering why I was performing an autopsy on him!


Dr. Quentin Quack’s Quacked Humor