This week in Medicare updates—3/24/2021
CLIA SARS-CoV-2 Variant Testing FAQ
On March 10, CMS published an FAQ regarding whether facilities need a CLIA certificate if they perform surveillance testing to identify SARS-CoV-2 genetic variants. The CMS response states that facilities do not need a CLIA certificate for variant testing if they are not using the testing to diagnose, prevent, assess, or treat an individual and if they are only reporting patient-specific results to a public health department for public health purposes.
MLN Provider Compliance Products
On March 15, CMS published an MLN Listing regarding a range of provider compliance products available to help educate Medicare health care professionals on how to avoid common billing errors and prevent claim denials. The listing contains a 15-page table listing various MLN publications with brief notes about what information each publication contains.
Updated Billing Requirements for Home Infusion Therapy (HIT) Services on or After January 1, 2021
On March 15, CMS published Medicare Claims Processing Transmittal 10621 regarding guidance and claims processing instructions necessary to implement changes for HIT services. Medicare started making separate payment for HIT services under the permanent HIT benefit to qualified home infusion suppliers effective January 1, 2021. Drugs are assigned to three payment categories as determined by HCPCS J-code. Effective for services on or after January 1, 2021, MACs may determine payment categories for any new home infusion drug additions to the LCD for External Infusion Pumps as identified by NOC codes J7799 and J7999. When either one of these codes are reported, the HIT supplier must identify the name of the drug in the comment section of the professional service claim for the corresponding HIT service G-code.
CMS published MLN Matters 12108 on the same date.
Effective date: January 1, 2021
Implementation date: July 6, 2021
CMS Increases Payment for COVID-19 Vaccine Administration
On March 15, CMS published a Press Release to announce it is increasing the payment rate for COVID-19 vaccine administration. Effective for vaccines administered on or after March 15, 2021, the national average payment per dose will be $40. This increases the payment for the single dose Johnson & Johnson vaccine administration from approximately $28 to $40. It increases the payment for administration of the two-dose Moderna and Pfizer vaccines from approximately $45 to $80. Exact payment amounts depend on the entity furnishing the service and geographic adjustments. The geographically adjusted rates are available as a ZIP file from the COVID-19 Vaccines and Monoclonal Antibodies webpage. CMS said the change in payment is due to new information about the costs involved in administering the vaccine.
Primary Care First Model Cohort 2 CY 2021 Fact Sheet
On March 16, CMS published a Fact Sheet regarding the second cohort of the Primary Care First (PCF) Model. CMS is now launching the PCF Cohort 2 Request for Applications for practices and for payer partners. The deadline for practices to apply is April 30. The deadline for payers to apply is May 28. Practices will begin participation in January 2022 for a five-year performance period.
April 2021 Quarterly Update to HCPCS Codes Used for Skilled Nursing Facility (SNF) Consolidated Billing Enforcement
On March 16, CMS published Medicare Claims Processing Transmittal 10678 regarding updates to the lists of HCPCS codes subject to consolidated billing provisions under the SNF PPS.
Effective date: April 1, 2021
Implementation date: April 5, 2021
Update to Rural Health Clinic (RHC) Payment Limits
On March 16, CMS published One-Time Notification Transmittal 10679 regarding updates to payment limits for RHCs. Beginning April 1, RHCs will begin to have payment limits increased over the course of eight years. The April increase will set the limit at $100 per visit. By 2028, the payment limit will be updated to $190. RHCs that are provider-based to a hospital will have payment limits set via a different method which is discussed in the transmittal.
CMS published MLN Matters 12185 on the same date.
Effective date: April 1, 2021
Implementation date: April 5, 2021
Updates to Medicare Benefit Policy Manual and Medicare Claims Processing Manual for Opioid Treatment Programs
On March 16, CMS published Medicare Claims Processing Transmittal 10665 and Medicare Benefit Policy Transmittal 10665 regarding updates to chapter 17 of the Benefit Policy Manual and chapter 39 of the Claims Processing Manual to reflect changes pertaining to Opioid Treatment Programs from the CY 2021 MPFS final rule. These are manual changes only; the policies had been finalized in the 2021 MPFS final rule.
Effective date: January 1, 2021
Implementation date: April 15, 2021
Implementation of Changes in the End Stage Renal Disease (ESRD) PPS and Payment for Dialysis Furnished for Acute Kidney Injury (AKI) in ESRD Facilities for CY 2021
On March 16, CMS published Medicare Benefit Policy Transmittal 10671 regarding implementation of rate updates and policies for the ESRD PPS and payment for renal dialysis services furnished to beneficiaries with AKI in ESRD facilities. These include updates to the ESRD PPS base rate, wage index, outlier policy, and more.
CMS published MLN Matters 12188 on the same date.
Effective date: January 1, 2021
Implementation date: April 5, 2021
CWF Edits for Medicare Telehealth Services and Manual Update
On March 16, CMS published Medicare Claims Processing Transmittal 10618 regarding the implementation of a change to frequency edits for the CWF due to a change in the limitation for subsequent nursing facility care services. Medicare is limiting the patient’s admitting physician or non-physician practitioner to one telehealth visit every 14 days for those services.
CMS published MLN Matters 12068 on the same date.
Effective date: January 1, 2021
Implementation date: July 6, 2021
Correction to Period Sequence Edits on Home Health Claims
On March 16, CMS published One-Time Notification Transmittal 10596 regarding a revision to CWF home health period sequence edits to no longer exclude low utilization payment adjustment claims. This change is being made due to the impact of certain PDGM processes.
CMS published MLN Matters 12085 on the same date.
Effective date: January 1, 2020 - Claim “From” dates on or after this date
Implementation date: July 6, 2021
Intravenous Immune Globulin (IVIG) Demonstration: Ending December 31, 2023
On March 17, CMS published Demonstrations Transmittal 10660, which rescinds and replaces Transmittal 10307, dated August 21, 2020, to extend the demonstration’s end date to December 31, 2023 by revising the title and effective date, updating the background and policy section, and by removing the note in business requirement 11877.1. The original transmittal was issued regarding the end of the IVIG demonstration.
CMS replaced MLN Matters 11877, dated August 24, 2020, with a Fact Sheet on the IVIG demonstration.
Effective date: January 1, 2021 - Demonstration ends on December 31, 2023
Implementation date: January 4, 2021
Final Rule Delay and Public Comment Period: Medicare Coverage of Innovative Technology (MCIT) and Definition of ‘Reasonable and Necessary’
On March 17, CMS published an Interim Final Rule with Delayed Effective Date and Request for Comments in the Federal Register regarding the MCIT and Definition of “Reasonable and Necessary” final rule, which was published in the Federal Register on January 14. CMS is delaying the effective date of this rule for 60 days as part of its regulatory freeze and administrative review of policies due to the change in administrations. It is also providing a new 30-day public comment period to allow for additional comments on certain issues raised by the final rule. Based on these comments, CMS may choose to revise or rescind the rule.
Effective date: As of March 12, 2021, the effective date of the final rule amending 42 CFR part 405 published at 86 FR 2987 on January 14, 2021, is delayed by this interim final rule until May 15, 2021.
Comment period: Comments on the final rule and the interim action are due by April 16, 2021.
Announcement of the Advisory Panel on Outreach and Education (APOE) March 31, 2021 Virtual Meeting
On March 17, CMS published a Notice in the Federal Register to announce the next meeting of the APOE will be held virtually on March 31 from 12 p.m. to 5 p.m. ET. Those who wish to attend should RSVP to receive a link for the meeting.
First General Update to Chapter 10 of the Program Integrity Manual
On March 18, CMS published Medicare Program Integrity Transmittal 10672 regarding technical revisions and updates for any necessary policy changes in Chapter 10. CMS recently transferred the entirety of Chapter 15 of the manual into Chapter 10. Numerous changes were made to instructions to contractors regarding enrollment for various providers. Additionally, contractors had previously been directed not to implement the FQHC instructions in CR 11917, which had been incorporated into a new section 10.2.1(D). Contractors should implement the FQHC instructions found in the revised version of that section in this CR.
Effective date: March 12, 2021
Implementation date: March 22, 2021
Correction Notice: CY 2021 Medicare Physician Fee Schedule Final Rule
On March 18, CMS published a Correction Notice in the Federal Register regarding corrections to various technical errors in the CY 2021 MPFS Final Rule. These include issues with CPT codes related to telehealth services, incorrect RVUs in Addendum B due to a technical change applied in error to the indirect practice expense allocation for HCPCS codes G2082 and G2083, and more.
Dates: This correction is effective March 18, 2021, and is applicable beginning January 1, 2021.
North Mississippi Medical Center: Audit of Medicare Payments for Polysomnography Services
On March 18, the OIG published a Review of whether North Mississippi Medical Center complied with Medicare requirements for polysomnography services. The audit reviewed lines of polysomnography services billed using CPT codes 95810 and 95811. The OIG found that North Mississippi did not meet requirements for 12 of the 100 beneficiaries reviewed and 13 of the 155 lines of services for those beneficiaries. The OIG found issues related to incorrect coding and to invalid technician/technologist credentialing or certification. It estimated that, on the basis of the sample, North Mississippi received overpayments of at least $67,038 during the audit period for these services.
North Mississippi stated these errors occurred in part because of a misunderstanding of Medicare policy. The OIG said North Mississippi was also unable to adequately explain how to process Medicare claims for polysomnography and ensure services billed meet all Medicare requirements. The OIG recommends North Mississippi refund Medicare the estimated $67,038 in overpayments, return any similar overpayments in accordance with the 60-day rule, educate staff on properly billing for these services, and revise policies and procedures to ensure that Medicare claims are coded correctly and sleep technicians have the required credentials before billing for polysomnography services.
Medicare Enrollment Manual Renumbering and Updates
On March 19, CMS published Medicare Program Integrity Transmittal 10611, which rescinds and replaces Transmittal 10355, dated September 18, 2020, to update a number of sections of Chapter 10 of the Program Integrity Manual. The original transmittal was published regarding the removal of manual instructions in Chapter 15and movement of the instructions to Chapter 10.
Effective date: November 19, 2020
Implementation date: November 19, 2020