POE Advisory Group

12/12/2024 Part B POE Advisory Group Meeting

Meeting Minutes

Meeting Time: 10:00 a.m.‒12:00 p.m. ET

Member Attendees: Elizabeth Aldrich, Dawson Ballard, Doris Barnes, Sheila Bembeneck, Madelon Berger, Louise Bertrand, Kimberly Bischel, Mollie Brooks, Tami Carter, Ilka Collier, Eileen Conlan, Renay Coonan, Pam D’Apuzzo, Elizabeth Fitzgerald, Darren Goodwin, Deborah Gregoire, Elaine Guppy, Martha Harris, Christie Hewson, Stephanie Hirst, Allison Israelson, Cindy Kennedy, Kevin Kile, Cindy Kisselburgh, Jenny Kovich, Lloyd Kupferman, Maud Lawrence, Vera Loftin, Sara Luther, Kristen McCormick, Natasha Moser, Sheila Mulka, Joyce Neurenberg, Mark Polge, Tracy Ross, Debra Rossi, Allie Ruffolo, Wendy Shreve, Ekaterina Spirin, Katie Tieppo, Susan Tucker, Katie Watkins, Theresa Weiland, Katie Werner

National Government Services Associates: James Bavoso, Christine Brauer, Laura Brown, Cathy Delli Carpini, Michelle Coleman, Jennifer DeStefano, Michael Dorris, Arlene Dunphy, Heather Fitzmaurice, Nathan Kennedy, Linda Klug, Lori Langevin, Jennifer Lee, Phyllis McAdams, Carleen Parker, Michele Poulos, Susan Stafford, Gail Toussaint

Agenda

  1. Welcome, Introductions and Opening Remarks
  2. NGSConnex Registration
  3. Beneficiary Eligibility Information No Longer Available on the IVR
  4. 2025 Telehealth Services
  5. 2025 Medicare Updates Presentation for Review
  6. Open Discussion
  7. 2025 Meeting Dates

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I. Welcome, Introductions and Opening Remarks

Lori Langevin, POE Consultant, NGS

Lori welcomed the members to the combined J6/JK POE AG Meeting and thanked them for joining. Lori advised she is the facilitator for today’s meeting along with Christine Brauer and Jim Bavoso, our manager. We also have other staff from our POE AG are on the call.

Lori stated members should have received the Team’s invite with a link to this meeting as well as an email with the agenda and material for today’s meeting. Lori reviewed the meeting agenda and turned it over to Jim for opening remarks. Jim welcomed the members and thanked them for all their feedback this year. Lori turned the meeting over to Christine for the first agenda topic.

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II. NGSConnex Registration

Christine Brauer, POE Consultant, NGS

Christine requested feedback from the members on the NGSConnex registration process and asked if it was too cumbersome. She asked members to share what they don’t like about the process and what National Government Services could do to make it easier.

Christine reminded members that each provider organization needs a LSO who is in charge or granting access to the other users, to ensure they only have access to information they need. The LSO also cancels access for users who have left the organization or no longer need access to the portal. NGS recommends two LSOs so you have a back-up if one is out.

POE AG feedback:

  • The MFA security code takes a bit to email to input so could be a little faster.
    • NGS Response: We have not heard this, but we can investigate it. The MFA code is sent out via the Elevance Email servers regardless of if the user requests it via email or text. I log in to production almost every day and generally get my code by text and have not seen any delays.
  • I ask for email code and usually get it very quickly. I have not had to wait for NGSConnex for a long time and no one in my office has complained about the process.
  • Runs smooth for us; but we do need to know how to remove an LSO as someone is changing roles.
    • NGS Response: Go to Registration, then LSO Responsibilities in the User Guide, it will show you how to remove someone.
  • The process was easy for our new employees. We just don't like the need for text or email authentication. Internet and text are subject to computer speed.
  • So how easy is it to remove users from NGSConnex?
    • NGS Response: Fairly simple. Under Manage Account/System Access it will ask you to select the person/user and then follow the prompts from there to remove them.

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III. Beneficiary Eligibility Information No Longer Available on the IVR

Lori Langevin, POE Consultant, NGS

Lori reminded members that as of 11/18/2024, the beneficiary eligibility lookup function on the IVR was disabled per Change Request 13754 (Disable Beneficiary Eligibility Information from MAC IVR Systems).

Lori asked members what issues they are facing and if they are using NGSConnex and/or HETS for eligibility.

POE AG feedback:

  • Never liked the IVR so no effects for me
  • No effect; use NGSConnex all the time for this
  • Have not had an issue with our practice

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IV. 2025 Telehealth Services

Nathan Kennedy, POE Consultant, NGS

Nathan advised for CY 2025 absent Congressional action, that statutory limitations that were in place for Medicare telehealth services prior to the COVID-19 PHE will retake effect for most telehealth services. This will include geographic and location restrictions as well as limitations on the scope of practitioners that can perform telehealth services.

Key Points: 

  • Caregiver Training Services will be added to the CMS list of telehealth services on a provisional basis. Provisional codes may be granted permanent status or be removed in a future year and there is no set timeframe for reevaluation. Services will be monitored for patient safety and a provisional status will never be assigned when it is improbable that the code would ever achieve permanent status.
  • PrEP counseling and safety planning interventions will be added on a permanent basis.
  • Suspension of frequency limitations for subsequent inpatient visits, subsequent nursing facility visits, and critical care consultations will continue through 2025.
  • Interactive telecommunications system may include two-way, real-time, audio only communication for a:
    • Beneficiary in their home
    • Distant site physician/practitioner using an interactive telecommunication system
    • Beneficiary is not capable of, or does not consent to, the use of video technology
  • Distant site practitioners will continue to use their currently enrolled practice location instead of their home address.
  • Definition of direct supervision allowing the supervising physician/practitioner to provide such supervision via a virtual presence through real-time audio and visual interactive telecommunications applies to a certain subset of services:
    • Incident to a physician/practitioner provided by auxiliary personnel, employed by the billing/supervising physician/practitioner and working under direct supervision.
    • The CPT/HCPCS code has been assigned a PC/TC indicator of 5 and services described by CPT code 99211.
    • O/O E/M visits of an established patient who may not require the presence of a physician or other qualified health care professional.
    • All other services furnished incident to, requiring direct supervision, will continue to be permitted through real-time audio and visual interactive telecommunications technology.
  • Teaching physicians may continue a virtual presence for services furnished involving residents in all teaching settings. Only in clinical instances when the service is furnished virtually; ex. three-way telehealth visit provided in separate locations with the patient, resident and teaching physician. Virtual presence will meet the requirement that the teaching physician is present for the key portion of the service.
  • Jim also mentioned we developed and sent a Telehealth Fact Sheet to members and it will be posted to our website soon.
    • The Facilitating Telehealth Fact Sheet is available within the Telehealth Services Medicare Topic.

POE AG feedback:

  • So, telehealth will go back to non-metropolitan or just rural areas again in 2025.
    • NGS Response:  Yes, with mental health services as an exception. Not just mental health codes, but also evaluation and management where behavioral health is being managed. It will be based on diagnosis. There is no geographical restriction with behavioral health.
  • Well, everyone seems to read that telehealth for behavioral health is over as of 12/31/2024. Please clarify this because it is causing issues since the Final Rule came out. If there was a document to provide that would be awesome. Providers always want references. Please also indicate what documentation is needed when audio only is used. We currently tell them the modifier 93 and for RHCs and FQHCs modifier FQ is for audio and no additional documentation is needed.
    • NGS Response: We will get something out to clarify all of this. We’ll have the Telehealth Fact Sheet and work on another one specific to mental health and include it will not go back to pre-COVID-19 guidelines. See Change Request 12549 for a reference to the modifiers. 
  • For services not on the telehealth list as allowed to bill audio, would they now have to be in-person. Also, if still performed as audio only can we issue an ABN? Or can we do this as a “cash only” option for Medicare patients? Also, can an ABN be signed electronically?
  • Can we use codes 98000-98015?
    • NGS Response: CMS does not recognize these telehealth codes. As according to CMS, they are equal to current E/M codes. Code 98016 is the only one CMS will recognize.
  • Regarding the new CPT codes that are “C” status contractor priced codes (15011-15018) will you be setting rates, or processing claims the same as unlisted codes based on the documentation submitted?
    • NGS Response: With carrier-priced codes, the CMDs look at the documentation submitted, or information included on electronic claims to determine pricing usually on a case-by-case basis.

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V. 2025 Medicare Updates Presentation for Review

Arlene Dunphy, POE Consultant, NGS

A PowerPoint presentation was shared with the group and Arlene presented the 2025 Physician Fee Schedule updates. The group was asked to provide comments and advise what, if anything, needed to be added in the presentation, as NGS is usually asked to present updates to a number of organizations/societies and AAPC groups.

POE AG feedback:

  • For the PrEP and Cardiovascular Risk Assessment and Management codes, both state in the literature that they are subject to incident to rules which inherently are not allowed in institutional settings to institutional patients, but they have facility rates. Can these services be performed in a facility setting.
  • For behavioral health telehealth services and the F2F visits - does this apply to prescribers only? Or does a F2F need to happen if patient is seeing nonproviders also?
    • NGS Response: Should be nonprescribers
  • Can you do fee schedule training? Rates change every year.
    • NGS Response: We offer quarterly Medicare Physician Fee Schedule Database webinars. Members were shown where they can look up fees on our website.

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VI. Open Discussion

Lori Langevin, POE Consultant, NGS

Lori opened the floor for any questions/feedback, but none were mentioned at this time.

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VII. 2025 Meeting Dates

Lori Langevin, POE Consultant, NGS

Lori stated that the 2025 meetings dates will be in March, June, September and December. As soon as we finalize the dates, we will post them to our website.

The members thanked us for a great meeting, and we thanked them for their participation and feedback and the meeting adjourned.

Posted 1/3/2025