3/13/2024 Part B POE Advisory Group Meeting
Meeting Minutes
Meeting Time: 10:00 a.m.‒12:00 p.m. ET
Member Attendees: Doris Barnes, Aurelio Barraco, Madelon Berger, Ilka Collier, Eileen Conlan, Renay Coonan, Tracy Essling, Stephanie Fiedler, Deb Gregoire, Darren Goodwin, Martha Harris, Stephanie Hirst, Allison Israelson, Kevin Kile, Cindy Kisselburgh, Jenny Kovich, Vera Loftin, Sara Luther, Sheila Mulka, Joyce Neurenberg, Mark Polge, Theodora Revelas, Maria Rivera, Gilbert Rosenblum, Ken Ryan, Wendy Shreve, Ekaterina Spirin, Stephanie Thebarge, Kathleen Tieppo, Susan Tucker, Katie Werner, Elaine Guppy, Dawson Ballard, Mary Casaburri, Jessica Marden, Traci Watson, Robin Devine, Shannon Fairbanks Deleon, Wanick Baptiste, Nena Rodrigues, Nikki Ramirez, Debra Rossi, Lloyd Kupferman, Liz Fitzgerald, Christine Leibold, Alie Ruffolo
National Government Services Associates: James Bavoso, Lori Langevin, Nathan Kennedy, Michelle Coleman, Cathy Delli Carpini, Arlene Dunphy, Jennifer Lee, Phyllis McAdams, Michele Poulos, Susan Stafford, Gail Toussaint, Laura Brown, Carleen Parker, Jennifer DeStefano, Michael Dorris, Jean Roberts, Linda Klug, Nadine Riccobene, Julia Meehan
Agenda
- Welcome, Introductions & Opening Remarks
- Change Healthcare
- G2211 FAQs
- POE Educational Webinars After Business Hours
- Spring Virtual Conference
- Open Discussion
- 2024 Meeting Dates
I. Welcome, Introductions & Opening Remarks
Lori Langevin, POE Consultant, NGS
Lori welcomed members to the meeting and advised everyone should have received an invite with a link to the meeting as well as an email with the agenda and handouts. Members were reminded they can use computer audio or a call-in number and to mute their line if they’re not speaking to avoid unnecessary background noise. Lori reviewed the meeting agenda and turned it over to Jim for opening remarks. Jim also welcomed and thanked members for the feedback they provide all year long. Jim wanted to get right to the cyber-attack involving Change Healthcare.
II. Change Healthcare
Jim Bavoso, POE Manager, NGS
Jim asked how many members were affected by the cyber-attack on Change Healthcare. Many members replied they were affected in some way.
CMS and NGS are aware that Change Healthcare recently suffered a cyber-attack. Change Healthcare is a clearinghouse vendor that connects providers with insurance payers and has operations that impact the submission of Medicare claims, including NGS. At this time, there is no indication that NGS’ systems have been compromised. This is not a CMS or NGS incident.
Options Providers Have to Submit their Medicare Claims:
- Medicare Part B Providers can use our provider portal, NGSConnex.
- This is a free option, and the provider may already be enrolled with NGSConnex.
- NGSConnex does not offer batch claim submission. Claims must be submitted one at a time.
- Providers can enroll with a clearinghouse.
- PC-ACE free billing software is available for NGS J6 and JK providers.
- PC-ACE is a stand-alone claims processing system that enables an electronic submitter to store demographic information, enter and store claim information, and prepare files in the HIPAA compliant 837 ANSI 5010A2 format.
- For paper claims, providers must submit and receive approval of an ASCA waiver.
- The Medicare payment floor standards for paper claims is 29 days from the date the paper claim is received, whereas the payment floor for electronically submitted claims is only 14 days.
Advance and Accelerated Payment Program Available for Providers Impacted by the Change Healthcare/Optum Payment Disruption
- Providers experiencing cash flow problems related to CHOPD, which began on 2/21/2024, may be eligible for AAP.
- Accelerated and Advance Payments are intended to provide necessary funds to providers when there is a disruption in Medicare claims submission and/or claims processing.
- The expansion of the AAP is only for the duration of the claims processing disruptions associated with this incident.
- Most providers supported by this vendor are eligible to request up to 100% of the Medicare payment amount for a 30-day period.
- Requests must be submitted on the NGS Request for Accelerated/Advance Payment Form
Member feedback on how they have been affected by this cyber-attack:
- “We have not since we use Trizetto, very minimal.”
- “Our MaineCare authorizations and Rx were impacted.”
- “We are but not with Medicare claims just other Payers.”
- “Our clients have experienced issues to different degrees.”
- “Our biggest issue is claims submission, so we are setting up an alternative clearinghouse. However, it is such a run around to get that updated.”
- “I have been told that our Medicare claims are processing. We use Experian as our clearinghouse.”
Jim concluded this topic by advising members NGS will be offering Let’s Chat sessions on:
- 3/14/2024 – 3:00–4:00 p.m.
- 3/20/2024 – 10:00–11:00 a.m.
- 3/21/2024 – 11:00 a.m.–12:00 p.m.
III. G2211 FAQs
Catherine K. Delli Carpini, BSN, RN, POE Clinical Lead, NGS
Cathy explained CMS approved G2211 as an add-on code for 2024. We’ve received many inquiries from our provider community about this code. Cathy reviewed the Complex and Chronic Care - HCPCS Code G2211 FAQs that are on our website at Evaluation and Management FAQs.
Member feedback/questions for G2211:
Question: What about chronic episodic symptoms and flare ups where we are the primary point of contact for managing pain? For chiropractors, is it appropriate to use G2211?
Answer: Jim stated that it’s not appropriate for chiropractors to use G2211. Cathy advised that the use of G2211 would go case by case; but those other elements indicate would be feasible.
Question: Can this be billed when a resident sees a patient under the primary care exception?
Answer: Cathy stated there is no restriction under the primary care exception but as a reminder the physician would be billing the service.
Question: Can you update slide 14 to include POS 10 as allowable for G2211?
Answer: Yes, we will update that FAQ to also include POS 10 and POS 02. Cathy mentioned that the FAQ was addressing G2211 as in-person; but it is allowed via telehealth.
Question: Will NGS publish any documentation guidelines on G2211?
Answer: Cathy stated that for each individual service you need to reflect something happening and that you are going to see this patient over time and are treating them long term for these chronic conditions. It will be the overall ongoing medical record that will show you are establishing care for that patient.
Question: For a primary care office, is there any situation that G2211 would not be eligible?
Answer: Cathy advised- for a patient that comes in with no diagnosis or serious condition. Nathan added CMS indicated they define G2211 as the care for continuous care for a serious or chronic condition so just coming in for the common cold would not be chronic.
Question: I understand there are no frequency limits for G2211; but for specialties like behavioral health or dermatology, is G2211 allowed?
Answer: Cathy replied, a psychiatrist and a dermatologist can bill E/M services, therefore they can bill G2211.
Dr Gilbert Rosenblum commented about the primary care being the continuing focal point for all needed services, and a few members agreed.
Nathan provided follow-up after further research on G2211, and we agree with Dr. Rosenblum’s interpretation. A patient seeing their PCP for an upper respiratory infection, or any singular type of visit needed, that has the ongoing longitudinal relationship with the provider could be billed for G2211. Because of the aspects that are described as part of the visit complexity defined by G2211, this would be acceptable.
Reference for the use of G2211: MLN Matters® MM13473 How to Use the Office & Outpatient Evaluation and Management Visit Complexity Add-on Code G2211
Lori shared the G2211 BLAST results and explained how they show us where we need to focus our educational efforts. Jim stated when you participate in BLAST you have three attempts to get the answer right.
Member Feedback
- “I learn from these BLAST.”
- “Yes, I take the BLAST and like them.”
Jim advised members to send any topics they’d like to see as a BLAST game, we are always looking for new topics.
IV. POE Educational Webinars After Business Hours
Lori Langevin, POE Consultant, NGS
Lori stated that there have been some comments on surveys from our webinars that attendees are looking for webinars to be conducted after business hours. We’re looking for feedback from our members, do you think this is something the provider community would benefit from?
Member Feedback
- “I have no problem attending webinars during normal business hours. I would be less inclined to attend one after-hours.”
- “How about offering two sessions. One in the morning and one after 4 p.m.”
- “After hours would be great.”
- “I’m insomniac and my organization holds most meetings 8 am to 2 pm.”
- “For me during business hours is better since I have other things in the evening going on.”
- “I would not be able to attend after normal business hours (7-5).”
- “I like the recording option.”
- “I was thinking 4 or 5 pm.”
- “4-6 pm would be great.”
- “I agree to have two sessions on a day or two different days, one for morning and one for afternoon so everyone can have their preference.”
- “A survey may help to get the best time.”
- “If later in the day, make the webinars shorter in time.”
Lori thanked everyone for their feedback and comments.
Jim asked the members for feedback on their use of podcasts:
- “I haven't as of yet.”
- “Not me.”
- “Yes, podcasts are good as they can play in the background while you work.”
- “I do not listen to podcasts.”
- “No to podcasts.”
- “I like the on the demand function.”
- “Yes, I listen, and agree by topic and shorter 30-45 minutes and could send in questions prior.”
- “Yes 15 -30 minutes.”
Member feedback for podcast topics:
- What about collaborating with other organizations for podcast?
- Podcasts like an ACT.
- I like that idea of specialties and documentation requirements.
- I listen to ones for personal growth more, not work, and unlikely for me. I still think education with some depth, ex. discussing published policies for example and what is still missing/what still needs to be clarified.
- Podcast suggestions: wound care, facet joint interventions.
- Summary of medical review findings.
Jim mentioned incident-to is a hot topic for NGS. Michael Dorris stated our Part A and HH+H Podcasts are averaging around 20 minutes.
V. Spring Virtual Conference
Lori Langevin, POE Consultant, NGS
Lori asked the members to start thinking about topics for our 2024 Spring Virtual Conference. We know that E/M services is always top of the list; but we find these sessions can turn into “what if” question sessions. Lori reviewed the slides with the previous topics suggested by the members for our virtual conference.
Jim added that we used to do live conferences but due to PHE we moved to these virtual conferences.
Member Feedback
- Critical Care is big one.
- Transitional Care Management and documentation is a hot topic for us.
- Mental Health will be good this time since you have added more providers to Medicare payor list.
Nathan asked if there was something specific to mental health that members were looking for.
Additional Member Feedback
- Intensive Outpatient Mental Health Programs
- For the BH services it is important to make it clear the rules are different when the BH is billed by a hospital outpatient department on a facility claim only
- The new 2024 CPT Codes:
- PIN Services
- Caregiver Training Services
- SDOH Risk Assessment
- Pelvic Exam – nonfacility setting only
- CHI Service Referrals
- PA and APRN students in teaching setting separate from teaching guidelines for residents
- The problem is teaching physician guidelines specify medical student resident attending physician only and exclude all other provider types and student types. Would be great if more were included – specifically NP and PA.
- Reiteration of teaching physician attestations for minor/major surgical procedures.
- Inpatient psych services – certifications, treatment plan, orders, supervision, billing requirements
- Split/shared visits
- Licensing requirements for telehealth when treating a patient from a different state
- Critical care regarding time because it differs from CPT and observation services
VI. Open Discussion
Jim asked members about their remit notices and if they are looking at the notepad messages that are on the remits.
Member Feedback
- I do not think we get it.
- That is not on my file either.
- I do not get it either from the clearinghouse.
- I am not sure, I will check.
- Just a quick note to express my thanks for all your support and help to keep our facilities in compliance!
Michael Dorris asked the members if they would like to see these notepad messages.
Member Feedback
- Our billing and reimbursement departments are outsourced so the information would not come back to other departments.
- We are good with reading the emails from NGS for updates.
Jim mentioned the Consolidated Appropriation Bill signed by the President and stated that as of now, NGS does not know what the bill entails; but as soon as we know NGS will notify our provider community.
One member said the conversion factor is changing so the fee schedule amounts will change.
Open discussion questions by POE AG members:
Question: The split shared visit changes for 2024 when the visit is based on MDM. What is the minimum the MD must document to be the billing provider?
Answer: When a split/shared service is billed by the physician as the substantive provider, the physician’s analysis and MDM decisions must clearly reflect his/her work in developing the MDM.
Question: If our providers are providing on-call night coverage for several facilities in the area, and patients call in after hours with problems, can we bill for the phone call (99441–99443) if the patient is not established to our practice or TIN but to a practice we are covering call services for?
Answer: 99441–99443 are only billable for established patients so they may not be used for new patient services. Revised 4/18/2024
Question: Is virtual supervision of resident E/M service limited to telemedicine services only in an MSA?
Answer: MSA and non MSA
Lori requested members check our website to ensure that all their contact information is correct and to notify her if there are any changes needed.
VII. 2024 Meeting Dates
Lori Langevin, POE Consultant, NGS
- 6/12/2024 (Wednesday)
- 9/18/2024 (Wednesday)
- 12/12/2024 (Thursday)
Members thanked us for a great meeting, and we thanked them for their feedback and the meeting adjourned.
Revised 4/18/2024