4/4/2024 Part A and FQHC POE Advisory Group Meeting
Meeting Minutes
Meeting Time: 9:30–11:30 a.m. ET
Member Attendees: Mary Altieri, Todd Bergstrom, Gloria Beazley, Mike Currie (for Vera Loftin), Dolores Dire, Jon Dunker, Matthew Felton, Cindy Kennedy, Christine Leibold, Sara Luther, Catherine Nolin, Larisa Orlando, Nancy Richman, Joanne Shade-Boyce, Kathleen Tieppo, Denise Winsock (CGS)
National Government Services Associates: Laura Brown, Adela Deal, Emma Eno, Emily Fox-Squairs, Andrea Freibauer, Jeanine Gombos, Alison Hamilton, Christine Janiszcak, Casey Jones, Nathan Kennedy, Laura Kiker, Julia Meehan, Kathy Mersch, Cheryl Papalia, Jean Roberts, Nena Rodrigues, Susan Stafford, John Stoll, Auburn Sutton-Puckett, Michelle Vannatter-Johnson, Mimi Vier, Pat Walker, Christine Warshel
Agenda
- Welcome/Introductions/Approval of Minutes from Previous Meeting
- Updates
- Review of Educational Material
- POE AG Members Suggestions for Education and Open Forum
- Upcoming Events and Additional Information
- 2024 POE AG Meeting Schedule
I. Welcome/Introductions/Approval of Minutes from Previous Meeting
Jean Roberts, POE Consultant, NGS
Jean welcomed everyone to the meeting, introduced herself and Christine Janiszcak, indicated everyone received a link to the handouts and added she posted a revised agenda in the webinar handout box. She asked for approval of the meeting minutes from 12/7/2023 posted on our website which she received. She explained all lines are muted but members can unmute their lines.
II. Updates
Opening Remarks
Emily Fox-Squairs, POE Manager, NGS
For anyone not at the last meeting, Emily introduced herself as the manager of the POE Part A team and added she is looking forward to hearing suggestions for education improvement.
Durable Medical Equipment
Denise Winsock, Provider Relations Senior Analyst, CGS - DME MAC Jurisdiction B
Denise reviewed her Medicare Updates handout:
- On slide 3 (ACO REACH), she explained, as of 10/1/2023, ACO Reach allows NPs/PAs to certify orders for diabetic shoes. NPs/PAs participating in the ACO REACH model are eligible to serve as a certifying physician. The ACO REACH model was redesigned to increase predictability for participants, protect against inappropriate risk score growth, maintain consistency and advance health equity. Information on participant registration is on the ACO Reach page on the CMS website.
- On slide 4 (Know the Roles of the NP and PA as the “Certifying Physician”), she explained the roles of the NPs and PAs participating in the ACO REACH model
- On slide 5 (NEW! Dear Physician Letters), she discussed therapeutic shoes for persons with diabetes, tips for certifying physicians and podiatrist suppliers, Medicare record authentication and tips for physicians. Providers can review Dear Physician Letters.
- On slide 6 (New! Ostomy Supplies Documentation Checklist) she reviewed the checklist.
- On slide 7 (Lymphedema Compression Items New Benefit Category), she provided an article Lymphedema Compression Treatment Items – Correct Coding and Billing – Revised.
- On slide 8 (Home Health Consolidated Billing: Urological, Ostomy, Tracheostomy, Surgical Supplies Claim Alert for DME MAC Suppliers), she explained claims are not processing correctly but they are working on this, and it should be corrected by October of 2024.
- On slide 9 (CERT – Common Causes of Improper Payments), she provided the common causes of improper payments and the payment rate error categories by percentage.
- On slide 10 (CERT Program), she provided the 2023 DME MAC Top 10 policies with error rates as well as the 2023 improper payment rates by state. She also made a slide correction to the parenteral nutrition percentage from 242.9% to 42.9%.
- On slide 11 (DME MAC and A/B MAC Collaborative Education), she mentioned the educational topics for 2024 include documentation requirements, nebulizer and related drugs, PAP devices and lower limb orthotics. She provided registration information.
- On slide 12 (Collaborative Patient Care is a Partnership), she provided a link to the resource MLN® Fact Sheet: Collaborative Patient Care is a Partnership
- Denise asked if anyone had any questions and she received none.
Prior Authorization Updates
Michelle Vannatter-Johnson BSN, RN, Clinical Review Nurse Lead, Clinical Operations, NGS
Michelle reviewed her PA OPD handout:
- On slide 2 (Quarterly Trends), she provided trends for affirmations, non-affirmations, partial affirmations and rejections for the third/fourth quarters of 2023 and the first quarter of 2024.
- On slide 3 (Facet Update), she provided the percentages of cases for affirmations, non-affirmations, partial affirmations and rejections.
- On slide 4 (Facet Joint Interventions – Non-Affirmations), she listed non-affirmation reasons:
- Missing support of a covered condition or medical indication. Use of the same pain or disability scale for the baseline pain assessment and the follow up pain assessment after each facet joint intervention.
- For subsequent RFAs: Missing a follow-up assessment that supports a 50% consistent pain relief with the previous RFA.
- For subsequent diagnostic injections (medial branch block or intraarticular): Missing a follow up assessment that supports an 80% consistent pain relief with the previous diagnostic injection (that is consistent with the agent used for the injection).
- Documentation supports there is a limitation or contraindication considered not reasonable and necessary.
- On slide 5 (Upcoming Educational Opportunities) she advised providers to register for PA educational events on our website including a webinar on 5/7/2024, 11:00 a.m.–12:00 p.m. ET, PA Program for Certain HOPD Services and a webinar on 6/11/2024, 11:00 a.m.–12:00 p.m. ET, Exemption Process for PA Program for Certain HOPD Services.
Michelle asked if anyone had any questions and she received none.
Medical Review and Case Management Team Updates
Alison Hamilton, Clinical Review Nurse Senior, JK Medical Review Case Manager, NGS
Alison reviewed her handout Medical Review and Case Management Team Update:
- On slide 2 (NGSMedicare.com), she reminded members to use our website as a resource. She explained we added many resources in 2023 and there are many sections of our website that can help providers learn about current review topics, denial trends, and FAQs for Part A and Part B. She stated we have an Events page with upcoming webinars that may assist with questions. She advised members can find our contact and fax information: Contact Us. She asked members to follow us on LinkedIn.
- On slide 3 (NGSConnex Self-Service Options), she reminded members about our NGSConnex application and its features including those providers can use to:
- Monitor for ADRs rather than waiting for them to come in the mail, adding that responding timely prevents reason code 56900 denials.
- Submit documentation, which is the most efficient and secure way to do so.
- Monitor claim review decisions, find the denial narratives and address trending issues.
- Check the status of appeals if you submitted a claim appeal.
- Communicate with us via electronic inquires.
- View results letters.
- On slide 4 (Where Can I Get Answers to Billing Questions), she explained our PCC can assist with Medicare information and billing questions and suggested to have the necessary information ready when you call: NPI, PTAN and last five digits of your TIN.
- For Connecticut, Maine, Massachusetts, New Hampshire, New York, Vermont, Rhode Island: 888-855-4356.
- For Illinois, Minnesota, Wisconsin: 877-702-0990.
- On slide 5 (Case Management Team), she added our CM team is available should you have questions or concerns related to MR and/or CBRs. Email: JKACaseManagement@elevancehealth.com or J6ACaseManagement@elevancehealth.com.
Alison asked if anyone had any questions and she received none.
Part A Comprehensive Error Rate Updates
Laura Brown, POE Consultant, NGS
Laura reviewed her CERT handout and reminded everyone not to share the data out of this meeting.
- On slide 2 (J6 CERT Error Rate), she provided the J6 CERT data for the November 2024 reporting period, for claims received 7/1/2022 to 6/30/2023.
- On slide 3 (J6 Part A CERT Errors), she provided a chart with the error codes, the code definitions and the number of claims for each error.
- On slide 4 (JK CERT Error Rate), she provided the JK CERT data for the November 2024 reporting period, for claims received 7/1/2022 to 6/30/2023.
- On slide 5 (JK Part A CERT Errors), she provided a chart with the error codes, the code definitions and the number of claims for each error.
- On slide 6 (CERT Resources) are CERT resources:
- CERT Provider Website – C3HUB
- Submit records to CERT
- Document Request Listings
- Claim Status Search (NGS CERT Representative)
- NGSMedicare.com website
- Resources > Medicare Compliance > Comprehensive Error Rate Testing
- CERT Alerts
- CERT Tools
- Documentation Submission Responsibilities
- CERT Task Force (Under Related Links: CMS View all Fast Facts)
- CERT Denial Finder
- CERT Provider Website – C3HUB
- On slide 7 are the following helpful links:
- CERT Reports | CMS
- 2023 Medicare Fee-for-Service Supplemental Improper Payment Data
- HHS Agency Financial Reports (AFR) | HHS.gov
- Medicare FFS information can be found in the “Other Information” portion of the AFR under the Payment Integrity Report section. (page 223)
- 2023 national Medicare FFS improper payment rate is 7.38% or $31.23 billion in improper payments
- CERT Reports | CMS
Laura asked if anyone had any questions and she received none.
Part A Provider Enrollment Updates
Laura Brown, POE Consultant, NGS
Laura reviewed the Provider Enrollment handout:
- On slide 2 (Provider Enrollment Updates), are the following updates:
- CMS website Introducing PECOS 2.0
- Page Last Modified: 09/13/2023
- Subscribe to the weekly CMS MLN® Connects Newsletter or NGS Email Updates
- Receive notification of updates and training opportunities
- CMS 588 EFT version 11/23 effective 4/30/2024
- CMS 855A – Ownership Interest and/or Managing Control Information (Individual)
- SNF and Hospice – Identify Medical Director and Administrator
- Indicate authorized officials titles (appointed official; for example, chief executive officer, chief financial officer, general partner, chairman of the board, or direct owner)
- Web Content
- Added MFT and MHC specialties to
- Learn About PECOS Web
- Added description of each to CMS PE systems, PECOS, NPPES and I&A
- CMS website Introducing PECOS 2.0
- On slide 3 (Provider Enrollment Updates) are the following updates:
- New PE Status: Refer to MLN Matters® MM13449: Stay of Enrollment
- Requirements:
- Is noncompliant with at least one Medicare enrollment requirement and
- can remedy the noncompliance by submitting, as applicable, a Form CMS-855, Form CMS-20134 or Form CMS-588. We refer to these forms as applicable (ACFs).
- Examples:
- Nonresponse to revalidation
- Ownership discrepancy
- Practice locations or banking information not up-to-date
- Stay of Enrollment Status
- Letters will be mailed or emailed
- Claims will be rejected until submission of the CMS application is received
- No response after time frame is over, enrollment deactivated
- On slide 4 are the following resources:
- Medicare Requirements for Marriage and Family Therapists and Mental Health Counselors (Reassigning to CAH Method II and CMS 855O – Order and referring)
- Institutional Providers: Revised CMS-855A Medicare Enrollment Paper Application Required 12/17/2023
- Provider Enrollment: Resumed Revalidation Activities
- Provider Enrollment: NGSMedicare.com Website Resources to Help Reduce Development on CMS-855A Application
- Provider Enrollment: Reduce Development Requests for Additional Action
- Provide Enrollment Application Fee Amount for CY 2024
- Provider Enrollment: Verify Bank Account Information to Prevent Interruption in Medicare Payment
Laura asked if anyone had any questions and she received none.
New Education Options: LinkedIn, Podcasts and Medicare Mobile News!
Jeanine Gombos, LPN, POE Consultant, NGS
Jeanine advised the members our Part A POE team is expanding our educational platforms to target all types of learners and provide options for those who may not be able to attend our webinars.
Jeanine reminded everyone about the platforms we use, whether for a long or short time:
- Medicare Mobile News – Texts we send twice a month. To sign up, text NEWS to 37702.
- LinkedIn – We post a lot of Medicare information including educational events such as webinars, podcasts, virtual conferences and more. Follow us and share this information.
- Podcasts for Part A – Our Part A POE team is new at conducting podcasts as we just launched in February 2024. We will conduct podcasts on a variety of Medicare topics the first and third Wednesday of every month. We’ve done podcasts on our Part A POE staff, preventive services, SNF billing and more. We will be collaborating with other departments in NGS including MR, Appeals and others. They are available on Spotify and Apple (see links below).
- YouTube – We’ve had our YouTube channel for many years for all LOB. So, we do post a variety of content on our channel, but we would like to expand. We are considering making videos for all preventive services, but this may take us some time.
Jeanine added that with expanding our platforms, we are not replacing our webinars; we want to use additional platforms to accommodate the needs of our providers and focus on smaller topics. She asked the members to check within their facilities and discuss with their staff members any topic suggestions they may have for any of our platforms. Members can email Jean and Christine.
Spring 2024 Part A Virtual Conference
Mary (Mimi) Vier, POE Team Lead, NGS
Mimi advised the members we conduct VCs twice a year in the Spring and in the Fall. The upcoming Spring VC dates are 6/4/2024 and 6/6/2024 and each day will run from 9 a.m. to 4:30 p.m. ET. All sessions are free and they are for all Part A providers except for HH+H providers who are offered a Summit each year. The Spring VC topics include self-service tools, the intake process on helping providers have a good and effective registration process, verifying Medicare eligibility, local coverage determinations/national coverage determinations (LCDs/NCDs), ABNs, ADRs in which we collaborate with our MR department, NCCI edits and MUEs, preventing common errors, MSP billing and a listening session. In the listening session, which will be the last session on day two, we will be having an open dialogue during which providers can speak with us and let us know what your burdens are, what your pain points are and how we can better assist you with tools and resources.
Question: Will the Spring VC include any sessions or information on post PHE? And, if not, can we consider this as a webinar topic?
Answer: Jean advised It does not include post PHE because most of the PHE extensions ended or will end at the end of 2024. But, if there is something needed, email Jean with any topics of interest.
Credit Balance
Andrea Freibauer, NGS POE Consultant
Andrea advised our members we started a new initiative to send out additional reminders and information about credit balance reporting via various platforms. She reminded members we are in a CB due date month (April 2024) and to ensure that by the end of the month, they need to complete the CB certification page, which can be done in NGSConnex, or complete the 838 report which can be done in NGSConnex as well (and various other ways).
Andrea asked if anyone had any questions on credit balance.
Question: Can you speak about withholds and penalties if you don’t get the CB report done by the end of the quarter?
Answer: Per Andrea, your facility could be subject to payment withholdings so be careful about responding by the due date. We have a section on our website on how to submit the CB report. Note: Andrea sent the members information about timeframes and penalties in the chat.
III. Review of Educational Material
Medicare Secondary Payer Article
Christine Janiszcak, POE Consultant, NGS
Christine reviewed the MSP article Identify the Proper Order of Payers for a Beneficiary’s Services. She explained we changed our website articles in late October of 2023 (CMS eNews 10/25/2023) to indicate providers should not call the BCRC per CMS but we have recently begun updating all of our MSP-related articles to provide clarification on the impact of this on MSP-related instructions.
Question: Will Medicare’s system update the MSP record to show liability coverage if we submit an MSP liability claim since we are not permitted to call the BCRC to set up a liability record?
Answer: Christine advised the member to submit an MSP or conditional claim to us depending on whether or not the liability insurer paid the claim and include all of the primary insurer’s information on it. Ensure you bill the primary insurer first. Clearly report on the MSP or conditional claim who is the liability insurer as well as all other required claim coding and we will send that data to the BCRC to set the MSP record up. Unless there is a problem when the BCRC conducts its investigation, we should be able to process the claim. Review Prepare and Submit an MSP Claim and Prepare and Submit an MSP Conditional Claim. Note that when a provider decides to bill Medicare conditionally in a liability situation because the liability insurer did not pay promptly within 120 days of the date you billed them, the provider must withdraw the liability claim before billing Medicare.
Question: Is it correct that we do not need to complete an MSP questionnaire with a beneficiary if we review their MSP record information with them and they indicate no changes have occurred?
Answer: Christine indicated It is correct, however, if the MSP/CWF record, for example, is an EGHP record and the beneficiary is receiving services because of an accident, then you would at least still need to ask the beneficiary the accident-related questions. Refer to CMS IOM Publication 100-05, Medicare Secondary Payer Manual, Chapter 3, Section 20.
Polling Questions
Jean Roberts, POE Consultant, NGS
Jean administered the following polling questions and shared the below results:
- Are you subscribed to NGS email updates (list serves)?
- 100% of the participants replied yes.
- Do you listen to podcasts?
- 30% of participants replied yes.
- Do you listen to work-related podcasts?
- 27% of participants replied yes.
- Do you listen to NGS podcasts? Part A? HH+H?
- The majority of participants indicated no.
- Do you read the NGS Self-Service Pulse?
- The majority of participants replied yes but one responded they were not sure what this newsletter was.
- Does your facility use NGSConnex?
- 90% of participants responded yes.
- Are you enrolled to receive our Medicare Monthly Review newsletter?
- 18% of participants replied yes.
- Do you subscribe to LinkedIn?
- 64% of participants replied yes.
Digital Solutions: We Want Your Input!
Jean Roberts, POE Consultant, NGS
Jean asked the members for their feedback on the following digital solutions:
- You Tube
- Medicare Mobile (Text News to 37702 and/or Text Games to 37702)
- NGS Self-service Pulse Newsletter
- Podcasts (Spotify or Apple Podcasts) Typically, 15 or 20 minute segments.
- Medicare University
Comment: Emily commented the polling was awesome as it has given us some insight that we could use. For those who do not listen to work-related or NGS podcasts, please still promote podcasts to your staff so they are aware of these digital options.
Comment: I love the idea of NGS collaborating with providers to do podcast episodes. Jean replied that if anyone wants to be involved, contact her and Christine.
Comment: I have been listening to the podcast episodes and think they are great. I like all of them including the one in which POE introduced themselves and was impressed by how many years of service each POE consultant has. I like the SNF episode and feel they are all they are going well. I listen in my car on my way to work. Jean thanked the member for listening and for the feedback.
Comment: I like NGSConnex and use it for everything. But, I have run into an issue when trying to do a MBI lookup where I had to write down the MBI and then do the lookup when I usually can just do the lookup after the system asks if you want to use this MBI. Jean replied she would send the feedback to our NGSConnex team. Kathy Mersch later provided an explanation she received from Charity Bright but indicated she would contact the member directly with the information. Jeanine also replied to the member indicating that we are going to collaborate with the NGSConnex team on a podcast.
Jean asked anyone with additional feedback to email her and Christine.
IV. POE AG Members Suggestions for Education and Open Forum
POE AG Education Tracker
Jean Roberts, POE Consultant, NGS
Jean reviewed the 2024 POE AG Education Tracker handout and provided the following information:
The topics members suggest for education are placed in our tracker.
The first suggestion was behavioral health and we have indicted we completed PHP Basics at the Fall 2023 VC and completed IOP on 3/13/2024.
For the topic of duplicates/overlaps, we believe this may have been more of an inquiry than a request for education but if the person who requested this topic still needs information, or would like to request formal education, let Jean know.
For the topic of CAH Method II billing, this is under consideration for the future. We do not have formal education planned at this time but this topic is on our radar.
2024 Education Suggestions
Jean Roberts, POE Consultant, NGS
Jean asked if anyone has any additional suggestions for topics?
Suggestion: One of our SNFs was selected for a Part B audit and the results were not what we hoped for regarding documentation. Could NGS offer a documentation session for Part B therapy services? We bill on a CMS-1450 claim form. Our therapists disagreed with the decisions and had to appeal so it would be beneficial for us to understand what NGS is looking for so we can avoid SNF therapy issues. Jean asked him to send her the information on what the documentation issues were. This will help drive the education. He agreed but added he feels the education they are receiving during the “five claim audits” is very good. Jean will let MR know when we have the information.
Suggestion: When we enroll new staff for NGSConnex access, the security officers are saying it takes 25 days for it to be implemented. Is there a new process? If so, is there a better process? We are getting the signatures we need internally. We have a new hospital coming on board and now we wonder how long it will take for us to have access to hospital information when they open in May. Jean asked for examples of this issue.
Question: A member asked a billing question that would need to be researched outside of this meeting, so she is going to send an email to Jean and include the resources they have checked.
Comment: We are very happy with the TPE letters in NGSConnex.
Suggestion: We’d like to suggest you conduct a session on drugs with a high denial rate such as Botox injections. Jean requested claim examples so she can see if the cause of the denials is medical necessity, billing or something else. She asked the member to send DCNs with no PHI included.
Suggestion: We have an idea for a provider self-service tool, a SNF PDPM calculator we have seen on another MAC’s website. It breaks down components and brings up per day calculations. NGS takes us to the CMS’ Pricer but this does not provide a breakdown per day, just a total for a specific date span. Jean will look into this suggestion with various NGS departments.
One member asked if we could discuss MA plans and how they must comply with the CMS’ guidelines. Jean explained we cannot since CMS oversees MA plans. Andrea sent a link to members via chat about contacting CMS’ Regional Office if they are having trouble.
V. Upcoming Events and Additional Information
Events
Jean Roberts, POE Consultant, NGS
Jean advised everyone to review available education on our Events calendar and noted the Spring Virtual Conference is on 6/4/2024 and 6/6/2024. Registration is open as Mimi explained earlier.
Additional Information
Jean Roberts, POE Consultant, NGS
Jean provided a high-level overview of the resources included on the agenda.
VI. 2024 POE AG Meeting Schedule
Jean Roberts, POE Consultant, NGS
The remaining 2024 meeting schedule is:
- 8/1/2024 9:30 a.m.–11:30 a.m. CT/10:30 a.m.–12:30 p.m. ET
- 12/5/2024 9:30 a.m.–11:30 a.m. CT/10:30 a.m.–12:30 p.m. ET
Meeting Adjourned
Posted 5/15/2024