Reimbursement Briefing July - Aug 2007
AOTA’s Reimbursement briefing
Vol. 8, NO. 4
July / August 2007
Reimbursement and Regulatory Policy (RRP) rrpd@aota.org / 1-800-SAY- AOTA, ext. 2013
Chuck Willmarth
Sharmila Sandhu
Leslie Lloyd
Tara Alexander
Judy Thomas
Tali Schulman
CONTENTS
1. MEDICARE National Policy Update
***Federal Register Postings
2. CMS Transmittal Watch
***CMS Transmittals Postings
3. CMS Resources
***CMS Open Door Meeting Dates
***CCI Edits
***PAC Payment Reform Demonstration: Your Help and Feedback are needed.
***PQRI Educational Materials information available on CMS website
4. AOTA Reimbursement Resources
***Scope of Practice Report
1. MEDICARE National Policy Updates
***Federal Register Postings.
Medicare Program; Proposed Revisions to Payment Policies Under the Physician Fee Schedule, and Other Part B Payment Policies for CY 2008; Proposed Rule- July 12, 2007 -- This proposed rule would address certain provisions of the Tax Relief and Health Care Act of 2006, as well as make other proposed changes to Medicare Part B payment policy. The proposed rule is over 250 pages and contains several issues related to therapy services. Some of the areas include: revisions to therapy standards and requirements, outpatient therapy cap, physician self-referral prohibition (STARK Law), and the 2008 physician quality reporting initiative (PQRI). Comments on this proposed rule were due August 31, 2007. To review this rule in entirety click here.
Medicare Program; Revised Civil Money Penalties, Assessments, Exclusions, and Related Appeals Procedures; Final Rule - July 20, 2007 -- This final rule establishes the procedures for imposing exclusions for certain violations of the Medicare program and is based on the procedures that the Office of Inspector General has published for civil money penalties, assessments, and exclusions under their delegated authority. Implementation of this final rule protects beneficiaries from persons (that is, health care providers and entities) found in noncompliance with Medicare regulations, and strives to improve the safeguard provisions under the Medicare statute.
This final rule was effective on August 20, 2007. Click here to read the entire rule.
Medicare Program; Surety Bond Requirement for Suppliers of Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS; Proposed Rule - August 1, 2007 -- The proposed rule seeks to implement a requirement of the BBA of 1997 that would obligate all Medicare suppliers of durable medical equipment, prosthetics, orthotics and supplies (DMEPOS) to furnish CMS with a surety bond. Medicare believes that this requirement would limit the Medicare program risk to fraudulent DME suppliers and enhance the Medicare enrollment process to help ensure that only legitimate DME suppliers are enrolled in the Medicare program. Under the Medicare regulations, Occupational Therapy providers that provide DMEPOS to beneficiaries are considered suppliers of the DME program. Comments on this proposed rule will be received until October 1, 2007. To read this proposed rule, click here.
Medicare Program: Proposed Changes to the Hospital Outpatient Prospective Payment System and CY 2008 Payment Rates; Proposed Rule - August 2, 2007 -- This proposed rule describes changes to the amounts and factors used to determine the payment rates for services to the Medicare hospital outpatient perspective payment system (HOPPS). Changes would become effective on or after January 1, 2008. To read this proposed rule, click here.
Medicare Program; Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities for FY 2008; Final Rule – August 3, 2007 -- This final rule updates the payment rates used under the prospective payment system (PPS) for skilled nursing facilities (SNFs) for fiscal year (FY) 2008. The rule becomes effective October 1, 2007. To review this rule in entirety, click here.
Medicare Program; Inpatient Rehabilitation Facility Prospective Payment System for Federal Fiscal Year 2008; Final Rule – August 7, 2007 -- This final rule will update the prospective payment rates for inpatient rehabilitation facilities (IRFs) for discharges occurring on or after October 1, 2007 and on or before September 30, 2008.The rule becomes effective October 1, 2007. To review this rule in entirety, click here.
Medicaid Program; Coverage for Rehabilitative Services; Proposed Rule – August 13, 2007 -- This proposed rule would amend the definition of Medicaid rehabilitative services in order to provide for important beneficiary protections such as a person-centered written rehabilitation plan and maintenance of case records. The proposed rule makes clearly defines Medicaid criteria for reimbursement of rehabilitation and habilitation therapy services. To read this proposed rule, click here.
TRICARE; Outpatient Hospital Prospective Payment System (OPPS); Interim Final Rule – August 14, 2007 -- This interim final rule implements a prospective payment system for Department of Defense (DOD) hospital outpatient services similar to those furnished to Medicare beneficiaries outside of the DOD. This interim final rule is accepting comments on or before October 15, 2007. The effective date for this rule is September 13, 2007. Click here to read the entire rule.
Medicare Program; Changes to the Hospital Inpatient Prospective Payment
Systems and Fiscal Year 2008 Rates; Final Rule – August 22, 2007 -- This final rule, with a November 20, 2007 comment period deadline, describes changes and factors used to determine the rates for Medicare hospital inpatient services for operating costs and capital-related costs for fiscal year 2008. The final rule is effective October 1, 2007. Click here to read the entire rule.
Medicare Program; Medicare Integrity Program, Fiscal Intermediary and Carrier Functions, and Conflict of Interest Requirements – August 24, 2007 -- This final rule establishes the Medicare Integrity Program (MIP) and implements program integrity activities that are funded from the Federal Hospital Insurance Trust Fund. This final rule sets forth the definitions related to eligible entities; services to be procured; competitive requirements based on Federal acquisition regulations and exceptions (guidelines for automatic renewal); procedures for identification, evaluation, and resolution of conflicts of interest; and limitations on contractor liability. The final rule is effective October 23, 2007. Click here to read the entire rule.
Medicare Program; Home Health Prospective Payment System Refinement and Rate Update for
Calendar Year 2008; Final Rule – August 29, 2007 --This final rule sets forth an update to the 60-day national episode rates and the national per-visit amounts under the Medicare prospective payment system for home health services. This final rule reflects the ongoing efforts of CMS to support beneficiary access to home health services and improve the quality and efficiency of care. This final rule will be accepting comments for consideration until October 29, 2007. Click here to read the entire rule.
2. CMS Transmittal Watch
***CMS Transmittals Postings.
· June 29, 2007, CMS issues guidance that allows physicians and suppliers to charge Medicare beneficiaries for missed appointments, provided that they do not discriminate against Medicare beneficiaries but also charge non-Medicare patients for missed appointments.
Transmittal - 1279CP (CR5613)
Supporting Medlearn Matters Article
· July 5, 2007, CMS issues a important special edition Medlearn Matters article for Providers/Suppliers regarding National Plan and Provider Enumeration System (NPPES) Errors, using the NPI on Medicare Claims and 835 Remittance Advice Changes.
Special Edition Medlearn Matters Article - (SE0725)
- July 20, 2007, CMS issues an update to Intermediaries, Carriers, and DME Contractors to obtain the most recent taxonomy codes from the Healthcare Provider Taxonomy Codes (HPTC) list.
Transmittal - R1300CP (CR5673)
- July 20, 2007, CMS issues an update to the payment rates used under the Medicare Part A Skilled Nursing Facility (SNF) Prospective Payment System for FY 2008.
Transmittal - R1306CP (CR5688)
- July 20, 2007, CMS issues implementation requirement instructions for all carriers and Medicare Administrative Contractors (MACs), Fiscal Intermediaries (FIs), the institutional branches of MACs, and the Durable Medical Equipment (DME) MACs for timeliness in processing “other-than-clean” claims.
Transmittal - 1312CP (CR5513)
Medlearn Matters Article
· August 8, 2007, CMS issues a special edition Medlearn Matters article on the 2007 Medicare Contractor Provider Satisfaction Survey (MCPSS) results for Medicare’s Fee-for-Service Contractors.
Special Edition Medlearn Matters Article (SE0733)
- August 10, 2007, CMS issues the first of several partial updates to the Program Integrity Manual, Chapter 10 on provider enrollment.
Transmittal - 218PI (CR5671)
- August 17, 2007, CMS issues the 2008 Annual Update of HCPCS Codes for Skilled Nursing Facility (SNF) Consolidated Billing (CB) for the Common Working File (CWF)
Transmittal - 1317CP (CR5696)
3. CMS Resources
***CMS Open Door Meeting Dates.
The CMS Open Door meeting schedule includes the following forums that may be of particular interest to occupational therapy.
- Home Health, Hospice, & DME – October 10, 2007 at 2:00pm
- Hospital / Hospital Quality – September 27, 2007 at 2:00pm
- Physician, Nursing and Allied Health – September 25, 2007 at 2:00pm.
- Skilled Nursing Facility / Long Term Care – September 13, 2007 at 2:00pm.
We urge occupational therapists to participate in these forums to keep up to date on policies that affect therapists’ work environments. The toll free call in number is 1-800-837-1935. All you provide to the teleconference operator is your name and the company or association you are with, and the name of the open door forum to which you wish to gain access. Please Note that meeting dates and times may change unexpectantly. For the latest information check out the CMS Open Door Meetings Schedule page. To sign up and receive notification of all upcoming meetings visit the Open Door Forum Listserv.
***CCI edits.
Version 13.1 (July 2007 - September 2007) of the National Correct Coding Initiative Edits may be reviewed and downloaded on the CMS website. To view the comprehensive and mutually exclusive code pair edits for the Physical Medicine and Rehabilitation codes (97000-97999), click on the sections marked Medicine Evaluation and Management Services under both groups.
CMS also posts NCCI edit FAQs on its website. Here, a series of questions and answers provide basic information about the Correct Coding Initiative (CCI), which affects all providers who bill Medicare Part B outpatient services (including CORF’s, outpatient clinics, hospital outpatient departments, private practices, and physician offices (e.g. billing “incident to”). CMS also has issued instructions on correct use of the -59 modifier. To view this document, click here. AOTA also has fact sheets about the CCI under the News and Announcements and Coding and Billing sections of the reimbursement webpage.
To order a hard copy of the edits visit the National Technical Information Service or call (703) 605-6000 and request Chapter 11 - Medicine, Evaluation & Management Services.
***PAC Payment Reform Demonstration: Your Help and Feedback are needed.
1.CMS Seeking Provider Volunteers
CMS is recruiting Medicare providers to take part in the Post Acute Care Payment Reform Demonstration (PAC-PRD). The Demonstration seeks to understand and compare the populations served in acute hospitals and each of the four PAC settings. The demonstration settings include: Long Term Care Hospitals (LTCHs), Inpatient Rehabilitation Facilities (IRFs), Skilled Nursing Facilities (SNFs), and Home Health Agencies (HHAs). Service providers of these settings are being asked to collect information using the CARE Tool (Continuity Assessment Record and Evaluation tool) developed specifically for PAC data collection. Participation in the demonstration is voluntary and will assist CMS to further refine the CARE Tool and assure appropriate data is gathered.
CMS announced that it has contracted with RTI, International to carry out this directive of the 2005 Deficit Reduction Act. RTI plans several initiatives to fulfill this mandate. A summary of RTI, International’s plans for this project can be read on the CMS website.
Providers interested in participating in the 2008 demonstration should contact Barbara Gage, Ph.D., Principal Investigator at RTI by emailing PAT-COMMENTS@RTI.ORG. Final selection of the provider participants will occur in the fall of 2007.
2. AOTA Seeking Therapist Feedback on CARE Tool
The CARE Tool, will measure the health and functional status of Medicare acute care discharges and measure changes in severity and other outcomes for Medicare PAC patients. CMS is currently accepting stakeholder comments on the CARE Tool. Please share your feedback with AOTA to ensure your concerns are addressed in AOTA’s official comment letter to CMS. You can email your comments to ssandhu@aota.org by September 21, 2007. Comments are due to CMS on September 25, 2007.
Viewing the CARE Tool:
Please use the following link to view uniform patient assessment instrument, the Continuity Assessment Record and Evaluation (CARE) tool, CMS intends to use to conduct the demonstration: CARE Information. Follow the download link to see a zip file of documents. In particular, you should review Appendix B (Master PAC tool).
Occupational therapists should be aware that the CARE Tool and PAC demonstration project will not directly impact therapists immediately. It would be great if members who work in sites that are part of the demonstration would provide ongoing feedback to AOTA as we begin to prepare all of our members who work in the relevant sites to understand the larger effort to address post acute care. AOTA is interested in your feedback with respect to the kind of data that will be collected by the CARE tool and whether OTs are qualified--and prepared--to collect the data OR if the allowed data collection methodology permits OTs to contribute to the data collection process.
Click here to read more about the PAC-PRD Medicare demonstration and evaluation report on the CMS website.
***PQRI Educational Materials information available on CMS website.
Providers wishing to participate in the Physician Quality Reporting Initiative (PQRI) and seeking additional information and tools can visit the CMS PQRI toolkit webpage. This page was created especially for the 2007 PQRI and will assist providers with educational resources plus step-by-step measure specific data collection worksheets and presentations on each measure. Additionally, there is a handbook for quality coding that provides guidelines for how to successfully report measures using clinical scenarios and a code master that includes a numerical listing of all codes included in PQRI intended for incorporation into billing software. The Tool Kit is now a featured section on the CMS PQRI web page http://www.cms.hhs.gov/PQRI/31_PQRIToolKit.asp#TopOfPage .
5. AOTA Reimbursement Resources
***Scope of Practice Report.
The Scope of Practice Issues Update newsletters for July, August and September 2007 are available online. The reports focus on national, state and payer trends affecting the occupational therapy profession. The report is available exclusively to AOTA members in the Members Only section of the Web site. You also can subscribe (free to AOTA members) to receive the monthly report directly on your e-mail. Submit your name and request to this email address to subscribe: scope@aota.org
If you have local reimbursement news that affects other states or may help other states with advocacy strategies, please send us (rrpd@aota.org) a short summary of what's happening to include in future Briefings. Feel free to use links to your state web page or other Internet sites that have additional information.
