9/18/2024 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, Aurelia Barraco, Sheila Bembeneck, Madelon Berger, Todd Bergstrom, Louise Bertrand, Mollie Brooks, Ilka Collier, Eileen Conlan, Renay Coonan, Pam D’Apuzzo, Tracy Essling, Elizabeth Fitzgerald, Olga Gridin, Darren Goodwin, Elaine Guppy, Martha Harris, Christie Hewson, Jonna Hopwood, Allison Israelson, Kevin Kile, Cindy Kisselburgh, Jenny Kovich, Maud Lawrence, Vera Loftin, Sara Luther, Jessica Marden, Kristen McCormick, Alicja Mohamed, Ashley Mui, Sheila Mulka, Joyce Neurenberg, Susanna Patrick, Mark Polge, Maria Rivera, Gilbert Rosenblum, Debra Rossi, Allie Ruffolo, Ken Ryan, Wendy Shreve, Ekaterina Spirin, Stephanie Thebarge, Katie Tiepo, Susan Tucker, Katie Watkins, Theresa Weiland, Katie Werner
National Government Services Associates: Laura Brown, James Bavoso, Melissa Cooper, Cathy Delli Carpini, Michelle Coleman, Jennifer DeStefano, Michael Dorris, Alicia Forbes, Nathan Kennedy, Linda Klug, Lori Langevin, Jennifer Lee, Christine Obergfell, Carleen Parker, Michele Poulos, Jean Roberts, Paul Root, Susan Stafford, Gail Toussaint
Agenda
- Welcome, Introductions and Opening Remarks
- 2025 Proposed Rule Topics
- G2211 CMS FAQs
- YouTube Videos and Podcasts -Where to Find Them
- We Need Your Feedback for Part B Topics and Methods
- Medicare Diabetes Prevention Program Summit
- New Medicare University Platform (Litmos)
- Care Management Week (9/24 – 9/26/2024)
- Feedback Needed NGS Collaboration with the Recovery Audit Program
- Open Discussion
- Next Meeting 12/12/2024
I. Welcome, Introductions and Opening Remarks
Lori Langevin, POE Consultant, NGS
Jim Bavoso, POE Manager, NGS
Lori welcomed the 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. Lori reviewed the meeting agenda and turned it over to Jim for opening remarks. Jim welcomed current and new members. Jim reminded everyone that the objective of the POE advisory group, is to assist the National Government Services POE team with educational information we provide to the provider community we serve. This includes feedback on items we post, training, as well as asking for assistance on an individual basis about certain topics. During the last meeting, we discussed the dental program and what we could do to address dental services education. That’s the idea of the advisory group, to get feedback from all of you representing all the providers within the jurisdictions we serve.
II. 2025 Proposed Rule Topics
Lori Langevin, POE Consultant, NGS
Lori advised the notice and comment period for the 2025 Proposed Rule ended; however, she hoped all members had seen the topics and made comments. Lori shared a list of the topics being proposed and reminded members to take a look at them and read up on them. You can search www.CMS.gov for the 2025 Proposed Rule. Lori asked the members if they had any concerns on the proposed changes. Jim added we normally receive the Final Rule in November either the first or second week, and as this becomes final; we will then get it into hands of the group.
POE AG feedback: A member asked if the PIN navigation services were the same as the PIN care management services proposed for 2025.
NGS Response: They are different in the scope of what they are covering.
POE AG feedback: A member asked if it was NGS’ interpretation that the telehealth geographic and site restrictions would be back for 2025.
NGS Response: Yes, part of the legislation that introduced telehealth coverage through the Social Security Act, all the addendums passed throughout the PHE, everything expires the end of this year. That’s something CMS does not have the authority to override any longer unless Congress acts to pass or update this which would go into effect in 2025.
POE AG feedback: A member asked if mental health performed via telehealth for in person requirements for the six months prior and every twelve months after was changing. Telehealth and mental health changes will be huge.
NGS Response: We have not seen anything on this yet. We’ll have to wait for the Final Rule. There is legislation out there in committee, not sure if it has to do anything with telehealth. Remember the Fee Schedule Proposed Rule is an Act of Congress. CMS does not have authority to change, so it may be last minute or into the new year so don’t be surprised.
POE AG feedback: Is CMS clarifying payment for global surgery modifiers 54/55/56? What is CMS proposing to do with this?
NGS Response: We believe it’s an initiative to ensure providers are billing appropriately. There have been issues in the past, so probably making sure all providers involved are being paid appropriately. Nothing has changed with these. CMS is proposing a new add-on code for post-operative care services as an incentive for additional time and effort when transfer takes place. Currently global surgery pays certain percentages of the fee for pre/intra/and post op.
POE AG feedback: Currently transfer of care is being used on a formal documented transfer of care. CMS is proposing to require modifier use when there is an informal, non-documented, but expected transfer of care. We have asked they provide examples for this.
POE AG feedback: What would CMS do if they see a contradiction? With an add-on code created for post-op care, what if another practice bills as well? So, two people are billing if there is a discrepancy will the correct provider being paid will you go after the other that shouldn’t be paid?
NGS Response: CMS would give guidance. We process on good faith. We see a lot of post-op care for other providers, records are requested and looked at and we determine who should be paid. CMS is trying to better address this.
III. G2211 CMS FAQs
Jim Bavoso, POE Manager, NGS
Jim shared an FAQ document with the group, developed by CMS for procedure code G2211. He also reminded everyone that NGS had put together FAQs as well the beginning of this year and posted them to the NGSMedicare website because we received many questions from the provider community such as; who can use this add-on code, to what services by what type of provider and how it works. Please review the CMS and our document and advise if there is anything else we need to include on this topic. The FAQs work together with CMS’ publication MLN13473 that CMS previously released.
- MLN Matters® MM13473 How to Use the Office & Outpatient Evaluation and Management Visit Complexity Add-on Code G2211
- CMS published FAQs: Frequently Asked Questions (FAQs) About Office/Outpatient (O/O) Evaluation and Management (E/M) Visit Complexity Add-On HCPCS Code G2211
POE AG feedback: One member posed a question to the group, wondering how they are handling of the G2211 when billing, if they have a work around to let this code flow through without bogging down their denial workloads internally. Commercial insurers are not paying and denying with different reason codes. One member advised they have an edit in their system when they report to Medicare but not with other payers.
IV. YouTube Videos and Podcasts -Where to Find Them
Nathan Kennedy, POE Consultant, NGS
Nathan shared a slide on YouTube videos and podcasts with hyperlinks where to find them. The 2024 Health Equity Services are individual videos on each topic and are 15-20 minutes. Part A HH+H has a number of podcasts and Part B is launching soon. We normally focus on webinars, but we need feedback and recommendations from you for shorter smaller topics we can hit as a YouTube video or podcast. You previously recommended teaching physicians and behavioral health providers, which would entail a full webinar. Mental health providers do utilize podcasts. Think about any trainings 5-10 minutes, they don’t have to be long. The G2211 is a question, we may be asking one of you to join us. Let us know if you would like to take part.
POE AG feedback: A member asked what about any time you need patient consent on things? It would help the patients, and their families understand.
NGS Response: Years ago, we did handle education for the beneficiary community, but this isn’t something we do anymore. Every Medicare beneficiary gets a handbook, though they may not always read it. We can suggest this to CMS as they have other contractors that handle this.
POE AG feedback: Additional suggestions included ABNs for clinical staff and shared visits.
V. We Need Your Feedback for Part B Topics and Methods
Lori Langevin, POE Consultant, NGS
Lori asked the group for feedback for educational sessions and methods of delivery for 2025. Would you like longer/shorter webinars, more Let’s Chat? We try to stay on point for Let’s Chat topics, not generalized chats. We have done a lot of telehealth and had one on July 17th and we’re now waiting for the final rule changes. Its ongoing from CMS and we try to educate these changes as best as we can.
Jim added, we recently discontinued Twitter and our Gamification as not many were using it. Are there other formats out there that you see are being used? Other topics you want to see?
POE AG feedback: Additional topic recommendations included guidance on care giver training services, assistant surgery modifiers, telehealth (what is still in effect and what is not). Also how do you see ambient listening? It’s difficult to sell to providers to see that in the records with new technologies. It’s something you must attest, and everybody is going full force with it.
A member stated they still get many questions on telemedicine where some providers only use audio instead of audio and visual and say the patient can’t do audio visual.
Members agreed telehealth services should be audited. It becomes difficult how providers are interpreting. What it comes down to is what needs to be documented and until we see audits back and we have clear guidance, it must be documented.
NGS Response: There is a list of telehealth services on CMS website and providers can check that. The list tells if the service can be audio only or has to be visual also. Is it because the patient wants audio only or because the provider wants to do audio only? Basically, we need a reminder that audio only services is at the discretion of the patient, and it must be documented in the notes.
Medical Review and CMS are working on this. We will see what we can come up with for the new technology and documentation. Maybe we can see if medical review can attend one of our future meetings.
POE AG feedback: A member brought up workforces are getting older, and some people can continue their health insurance when transitioning off the employer, we need to speak to COBRA situations get some guidance. CMS and SSA need to address this when the regulations are not being followed.
NGS Response: MACs don’t administer this. We really can’t say or do anything about this. That is really a Legislative topic, so you should speak with a Congressional representative on this issue.
VI. Medicare Diabetes Prevention Program Summit
Carleen Parker, POE Consultant, NGS
Carleen shared CMS is hosting its first ever two-day Summit on 9/18- 9/19/2024 for MDPP. MDPP has been around since 2018 and is a benefit for patients with prediabetes. During these two afternoon sessions, CMS will provide information about the program, offer technical assistance, and foster networking opportunities for prospective and existing suppliers. If you can not make the Summit, please look for more NGS education in 2025.
POE AG feedback: A member asked what provider types can provide this service? If we currently have a certified diabetes program in house, only treating diabetic patients or renal patients, do we need this additional credentialling?
NGS Response: Anyone can provide these services, but credentialling is done through the CDC for full or preliminary recognition. Once you have done that you can complete the NGS application to enroll. This is a separate credentialling you will need through the CDC. This is not for patients with diabetes. It is a lot to credential, but once credentialled it’s a good program and great way to prevent diabetes. What Medicare allows for these services is on our website and we do also have specific information on this and diabetes awareness on our website under Education Topics and also under Manuals and Guides.
We would like to know if any of you have enrolled and bill these services?
POE AG feedback: Our providers are not willing to try, they say the process is too hard, takes too long.
VII. New Medicare University Platform (Litmos)
Lori Langevin, POE Consultant, NGS
Lori asked for feedback from the POE AG members on the new Medicare University platform as far as ease of use, logging in, overall use and what courses we should add. Jim indicated we had to move off the old platform and this one is more robust. We had to take down the old courses and are updating them and adding them back. Let Jim know if there are certain ones you need replaced right away.
POE AG feedback: Members had no comments at the time and were advised to forward them on via email if they think of anything.
VIII. Care Management Week (9/24/2024–9/26/2024)
Christine Obergfell, POE Consultant, NGS
Christine advised the group of the care management webinar series to be held 9/24- 9/26/2024. Two topics will be covered Tuesday and Wednesday and three on Thursday. The list of topics/dates/times of the webinars with a handout that includes links to registration was provided. Members were asked to share with others in their organization and hoped the members could attend some or all of the sessions. Members were also asked if there was anything that stood out on the topics that needed to be addressed with attendees.
POE AG feedback: Members thanked NGS for doing these and added they are great. No additional comments were given.
IX. Feedback Needed NGS Collaboration with the Recovery Audit Program
Lori Langevin, POE Consultant, NGS
Lori wanted to get feedback from the POE AG members on the webinar that NGS has collaborated on and partnered with the RAC. The sessions are called, Navigating the RAC Process – CMS Recovery Audit Contractor Activities. There was one 9/11/2024 and on 12/11/2024 there will be one from 12:00-1:00 p.m. ET. You can sign up through our events calendar and watch for emails advertising this session. Participation has been great so far. Especially during the Q&A. The presenter is Roxanne Cooksey, who is the Director of Healthcare Operations Support, Performant. Roxanne takes you out to their website to show where to find data.
Lori provided contact information for the members and asked if anyone attended the September webinar? Also advising RAC reviews are targeted and approved by CMS unlike CERT audits which are random.
POE AG feedback: A member had a comment they had an audit and have practices in two states and got a double whammy with audits. Would like to see an option other than faxing information back.
X. Open Discussion
Lori Langevin, POE Consultant, NGS
Lori opened the floor for any questions/feedback at this time.
POE AG feedback: Member stated they had a patient in a nursing home, where they live, and when they have a telehealth service, they do use place of service 10, but what address goes on the claim?
NGS Response: The address should be the nursing home address. We need to know the address where they are, where they reside. Lori recalled hearing CMS on a teleconference address this stating if the patient was in their car, home, etc., the place of service is 10. Lori stated we need to go back and have a look at that.
POE AG feedback: A member stated NGS recently had guidance on psychotherapy treatment plans (This was for Part A), they listed who can sign the treatment plan. They are wondering if this guidance also applies to Part B? The inpatient psychiatric LCD contradicts this.
NGS Response: Medical review put this out and we will have to check with them and get back to you on that.
POE AG feedback: A member had a question on NGSConnex LSOs when they remove people from access to provider accounts, or remove them altogether, they still show on a report. Would like it to show just active users. The member was wondering if there was a way to delete that person completely off or put them on an archive list. Additionally, they encountered a technical issue where there used to be boxes to check and they don’t appear but if you check in the area where they should be, once you check mark, it appears.
NGS Response: Jim thanked the member for looking at this and keeping on top of those employees that should not have access. Many LSOs do not do this. We can check and see if anything can be done with this. Also, we can get examples from the member with the check box issue and forward on to the NGSConnex technical people.
POE AG feedback: A member wondered why they could not do a reopening in NGSConnex and state the COB is being updated and then it would go through. The patient has commercial, and workers comp from over a year ago and we just want the claim processed. The person we spoke to on reopening’s said we could not do this over the phone, we had to do an appeal.
NGS Response: Jim asked for an example to be sent so we could look into this. Records need to be reviewed in order to determine the diagnosis is not related. Also, the patient’s records need to be updated first.
POE AG feedback: A member had a question for Lori on shared medical visits.
NGS Response: Lori had received information to send back to him.
XI. Next Meeting 12/12/2024
• 12/12/2024 (Thursday)
Lori asked if quarterly meetings and two-hour timeframes were good for meetings in 2025. Members agreed.
Lori advised the members to send potential agenda items before the meeting as we are always looking for suggestions.
The members thanked us for a great meeting, and we thanked the members for their attendance and feedback and the meeting adjourned.
Posted 10/23/2024