Reimbursement Briefing Sept - Oct 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
Steven Fowler
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
4. AOTA Reimbursement Resources
***Scope of Practice Report
1. MEDICARE National Policy Updates
***Federal Register Postings.
Medicare Program; Physicians’ Referrals to Health Care Entities With Which They Have Financial Relationships (Phase III); Final Rule- September 5, 2007 -- This final rule is the third phase (Phase III) of a final rulemaking amending our regulations regarding the physician self-referral prohibition. Specifically, this rule finalizes, and responds to public comments regarding, the Phase II interim final rule with comment period published on March 26, 2004, which set forth the self-referral prohibition and applicable definitions, interpreted various statutory exceptions to the prohibition, and created additional regulatory exceptions for arrangements that do not pose a risk of program or patient abuse (69 FR 16054).The final rule becomes effective on December 4, 2007. To review this rule in entirety click here.
Medicaid Program; Elimination of Reimbursement Under Medicaid for School Administration Expenditures and Costs Related to Transportation of School-Age Children Between Home and School; Proposed Rule - September 7, 2007 -- The proposed rule would eliminate reimbursement under the Medicaid program for the costs of certain activities based on a finding that these activities are not necessary for the proper and efficient administration of the State plan, nor do they meet the definition of an optional transportation benefit. Based on these determinations, Federal Medicaid payments would no longer be available for administrative activities performed by school employees or contractors, or anyone under the control of a public or private educational institution, and transportation from home to school and back for school-aged children with an Individualized Education Program (IEP) or an Individualized Family Services Plan (IFSP) established pursuant to the Individuals with Disabilities Education Act (IDEA). Comments on this rule will be accepted until November 5, 2007. Click here to read the entire rule.
Medicare and Medicaid Programs; Quarterly Listing of Program Issuances—April Through June 2007; Notice - September 28, 2007 -- This notice lists CMS manual instructions, substantive and interpretive regulations, and other federal register notices that were published from April 2007 through June 2007, relating to the Medicare and Medicaid programs. To read this notice in its entirety, click here.
2. CMS Transmittal Watch
***CMS Transmittals Postings.
- September 14, 2007, CMS re-issues guidance that instructs physicians and suppliers to begin the discontinued use of the Unique Physician Identification Number (UPIN) Registry effective June 29, 2007.
Transmittal - 222PI (CR5584)
· October 5, 2007, CMS provides the necessary instructions to home health agencies regarding submission of claims under the refined HH PPS. It also makes conforming changes to various sections to reflect contracting reform and the conversion to the UB-O4 claim form.
Transmittal - R1348CP (CR5746)
MedLearn Matters Article
· October 5, 2007, CMS announces its Fee For Service (FFS) National Provider Identifier (NPI) final implementation which discontinues Medicare legacy numbers on electronic claims and other HIPAA transactions.
Transmittal - R1349CP (CR5278)
MedLearn Matters Article
- October 16, 2007, CMS issues instructions for the implementation and execution of the Medicare Provider Enrollment Demonstration for Home Health Agencies (HHAs) in High-Risk Areas”.
Transmittal - R223PI (CR5738)
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 – January 9, 2007 at 2:00pm
- Hospital / Hospital Quality – December 20, 2007 at 2:00pm
- Physician, Nursing and Allied Health – December 18, 2007 at 2:00pm.
- Skilled Nursing Facility / Long Term Care – December 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 13.3 (October 2007 - December 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.
4. AOTA Reimbursement Resources
***Scope of Practice Report.
The Scope of Practice Issues Update newsletters for September - December 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.
