There has been much discussion and controversy over the new CMS position on billing for split/shared services in facility settings. As originally proposed, and starting in January 2022, if the service was shared among providers (such as physicians and physician assistants), the provider who performed the substantive portion of the visit would be the provider … Continue Reading
Under the Federal Ethics in Patient Referrals Act (more commonly known as “Stark”), if a physician[1] has a financial relationship with an entity, the physician may not refer patients to the entity for medical services payable by Medicare unless the financial relationship complies with the Stark safe harbors. Thus, entities that lease or sublease space or … Continue Reading
In MLN Matters article MM 12159, CMS has published summaries of the following: Updates to payment policies and Medicare payment rates for services provided by physicians and non-physician practitioners (NPP) Updates to Medicare telehealth services and telehealth originating site facility fee payment amounts Billing for a physician assistant (PA) services … Continue Reading
MLN Connects, on Monday August 16, 2021, published a special edition on COVID-19 vaccines codes and payment. It references the CMS explanation entitled “Medicare COVID-19 Vaccine Shot Payment”. I have also attached a PDF of both documents if you cannot access the links.… Continue Reading
The 2022 Medicare Physician Fee Schedule was proposed and published by CMS on Friday, July 23, 2021. Here is the link: https://www.govinfo.gov/content/pkg/FR-2021-07-23/pdf/2021-14973.pdf… Continue Reading
Click here to read the article on the 2021 Medicare Physician Fee changes which appeared in the March 2021 edition of the Allegheny County Medical Society Bulletin. … Continue Reading
CY 2021 Physician Fee Schedule Update On December 27, 2020, the Consolidated Appropriations Act modified the Calendar Year (CY) 2021 Medicare Physician Fee Schedule (MPFS): Provided a 3.75% increase in MPFS payments for CY 2021 Suspended the 2% payment adjustment (sequestration) through March 31, 2021 Reinstated the 1.0 floor on the work Geographic Practice Cost … Continue Reading
This article written by Michael A. Cassidy and Jerry J. Russo appeared in the October 2020 Issue of the Allegheny County Medical Society Bulletin.… Continue Reading
On September 24, 2020, President Trump issued an Executive Order encouraging Congress to restrict surprise billing and prevent third party payors from denying care to patients with pre-existing conditions. President Trump wants Congress to act prior to the end of the year, but obviously there is not much chance of that happening.… Continue Reading
Attached is a link to the fact sheet for “proposed policy, payment, and quality provisions changes to Medicare physician fee schedule for calendar year 2021”. Among other things, Centers for Medicare & Medicaid Services (CMS) proposes to: Significantly decrease the Medicare Work Relative Value Unit (WRVU) conversion factor from $36.09 to $32.26 Significantly revise the … Continue Reading
Centers for Medicare & Medicaid Services (CMS) published the new hospital outpatient and ambulatory surgical center fee schedule for 2021 on August 12, 2020 at this this link: https://www.federalregister.gov/documents/2020/08/12/2020-17086/medicare-program-hospital-outpatient-prospective-payment-and-ambulatory-surgical-center-payment As part of the proposed revisions, CMS intends to transfer over 1,500 procedures from the “inpatient only” category, including 266 musculo-skeletal procedures as of 2021, the … Continue Reading
Click here to read Mike Cassidy’s article which was featured in the Legal Report section of the September 2019 edition of the Allegheny County Medical Society Bulletin.… Continue Reading
On April 4, 2019, CMS issued the final Medicare Advantage Rule for calendar year 2020, announcing it will allow Medicare Advantage carriers to significantly increase the range of telehealth services beyond traditional Medicare Part B covered services, stipulating only that, if a service is to be covered as a telehealth service, it must also be … Continue Reading
On Thursday, March 28, CMS issued a new MLN Connects article, which included updates for ambulatory surgery center payments. A link is attached below: https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/downloads/MM11232.pdf … Continue Reading
As part of the 2019 Medicare annual inpatient prospective payment system (PPS) fee schedule update, CMS has added a “rule” requiring hospitals to publish a list of standard charges beginning January 2019. CMS explained this initiative under the “Transparency” and “Request for Information” topics in the following link: https://www.cms.gov/newsroom/fact-sheets/fiscal-year-fy-2019-medicare-hospital-inpatient-prospective-payment-system-ipps-and-long-term-acute-0 CMS subsequently issued two sets of … Continue Reading
The final Medicare 2019 Physician Fee Schedule https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/PhysicianFeeSched/index.html rule was posted on November 1, 2019, to be effective January 1, 2019. It includes Section II(D) entitled “Modernizing Medicare Physician Payment by Recognizing Communication Technology-Based Services”, with several subsections. Brief communication technology-based services (EG Virtual Check-In) (HCPCS Code G2012) Remote evaluation of prerecorded patient information (HCPCS … Continue Reading
The 2019 proposed Medicare Fee Schedule was published on July 27, 2018 by CMS at https://s3.amazonaws.com/public-inspection.federalregister.gov/2018-14985.pdf. Pages 61 through 91 of the Executive Summary are devoted to: Modernizing Medicare Physician Payment by Recognizing Communication Technology-Based Services. Click here to read: Modernizing Medicare Physician Payment by Recognizing Communication Technology-Based Services. This subsection is devoted to explaining both … Continue Reading
Just as a point of providing information, please note that CMS has revised its Medicare Learning Network (MLN) booklet for telehealth services. The February 2018 edition is included in this link. https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/downloads/TelehealthSrvcsfctsht.pdf The 2019 proposed Medicare Physician Fee Schedule Rule also seeks comments on proposed expansion of telehealth services. That will be the subject of … Continue Reading
On January 11, 2018, CMS announced a new voluntary episode payment model (bundled payments for care improvement advanced–BPCI Advanced) that will test a new iteration of bundled payment for the following thirty-two (32) clinical episodes: 29 Inpatient Clinical Episodes Acute myocardial infarction Back & neck except spinal fusion Cardiac arrhythmia Cardiac defibrillator Cardiac valve Cellulitis … Continue Reading
In the January 11, 2018 issue of MLN Connects, CMS has now widely publicized that it issued billing guidance for major joint replacements (hip or knee) in May 2017 at ICN909065. CMS reports that major joint replacement is one of Medicare’s top volume DRGs and, that due to the high volume of these claims, CMS … Continue Reading
In Robie v. Price, Dr. Robie successfully obtained a temporary restraining order prohibiting CMS from terminating his Medicare billing privileges prior to the exhaustion of his administrative remedies by the U.S. District Court for the Sothern District of West Virginia. As most realize, exhaustion of administrative remedies is usually a prerequisite to further litigation for … Continue Reading
The 2017 Medicare Physician Fee Schedule finalizes the CMS changes for Telehealth reimbursement and coverage for 2017. The CMS fee schedule document also provides a comprehensive explanation of Medicare Telehealth reimbursement and coverage. I have excerpted those 35 pages and linked them as a PDF to this post: Medicare Telehealth Services. The essential takeaways are as … Continue Reading
The Centers for Medicare & Medicaid Services (CMS) has finalized the 60-day overpayment rule. I have attached the article I prepared for ACMS Legal Bulletin here.… Continue Reading
