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
Mike was published in this month’s Allegheny County Medical Society Bulletin regarding the Medicare reform. You can find the article here.… Continue Reading
HHS is gearing up to design and implement a revised Medicare payment system. The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) has designated a merit based incentive payment system (MIPS) as a goal. CMS is tasked to design a value based payment system based upon quality, resource use, clinical practice improvement, and meaningful … Continue Reading
The ink was barely dry on the Medicare Physician Sustainable Growth Rate (SGR) fix, and it has already been changed. One component of the SGR fix, which was just passed in April of this year, was freezing Medicare physician payments from 2019 through 2025, and then allowing a .75% increase for physicians participating in alternative … Continue Reading
The Internal Revenue Code was amended in April 2015 as part of the Medicare Access and CHIP Reauthorization Act of 2015 to increase allowable IRS levies against federal payments, such as Medicare receivables, from 30% to 100% effective October 16, 2015. CMS has issued MLM Matters – MLM number MM9285, to explain these changes. … Continue Reading
CMS issued a special edition MLN Matters meant to be effective August 1, 2015. The guidance reflects CMS instructions to Medicare Administrative Contractors (MACs) and Qualified Independent Contractors (QICs) regarding the scope of review for redeterminations and reconsiderations of certain claims. CMS acknowledges its concern that MACs and QICs were using their discretion to conduct … Continue Reading
CMS has acknowledged that arrangements among providers to satisfy the Stark exceptions need not be created in a single document. Although a single written document memorializing the key facts of an arrangement could provide the surest and most straightforward means of establishing compliance with the applicable exception, there is no requirement under the physician self-referral … Continue Reading
In July 2015, CMS released proposals to provide several new Stark Law exceptions and to clarify issues regarding existing exceptions. Over the next few days, I will post comment on what I consider the most significant new exceptions and clarifications. The full text of these proposal and CMS comments and explanations is available at: https://www.federalregister.gov/articles/2015/07/15/2015-16875/medicare-program-revisions-to-payment-policies-under-the-physician-fee-schedule-and-other-revisions … Continue Reading
In July 2015, CMS released proposals to provide several new Stark Law exceptions and to clarify issues regarding existing exceptions. Over the next few days, I will post comments on what I consider the most significant new exceptions and clarifications. The full text of these proposals and CMS comments and explanations are available at: https://www.federalregister.gov/articles/2015/07/15/2015-16875/medicare-program-revisions-to-payment-policies-under-the-physician-fee-schedule-and-other-revisions … Continue Reading
By now, everyone knows ICD-10 coding starts October 1, 2015. Starting October 1, 2015, Medicare claims with dates of service after October 1, 2015 will only be accepted if they contain a valid ICD-10 code. The Medicare claims system will be programmed not to accept ICT-9 codes after September 30, 2015. However, Medicare announced in … Continue Reading
Medicare Regulations allows CRNA’s to administer anesthesia without physician supervision if the state governor opts out of the regular physician supervision requirement. Governor Ritter of Colorado opted out in 2010, and his action was challenged by the Colorado Medical Society and the Colorado Society of Anesthesiologists. That challenge was dismissed by Colorado trial courts, which … Continue Reading
Click the link below to read Michael A. Cassidy’s article on Medicare Sustainable Growth which appeared on the Allegheny County Medical Society’s website on Tuesday, April 21, 2015 http://www.acms.org/ … Continue Reading
MGMA has published the following alert: Congress repeals SGR! In a significant victory for physician group practices and MGMA, late this evening the Senate voted (92-8) to approve the Medicare Access and CHIP Reauthorization Act, H.R. 2. This legislation, which passed the House of Representatives on March 26, permanently repeals the Medicare Sustainable Growth … Continue Reading
March 27, 2015 – Special Alert Senate leaves for recess with no action on SGR repeal Despite a successful vote in the House yesterday, the Senate failed to bring to a vote legislation to repeal the flawed Medicare Sustainable Growth Rate (SGR) formula before leaving for April recess early this morning. MGMA is extremely … Continue Reading
Historic SGR repeal passes in House Today, the House of Representatives passed the Medicare Access and CHIP Reauthorization Act, H.R. 2, by a vote of 392–37. This legislation permanently repeals the SGR and returns stability to physicians and Medicare patients. MGMA President and CEO Halee Fischer-Wright released the following statement: “The House of Representatives … Continue Reading
The Centers for Medicare and Medicaid Services (CMS) released a proposed rule intended to make ACOs and Medicare Shared Savings Plans more practical and attractive to potential providers. The proposed rule was released on December 1, 2014, along with a CMS Fact Sheet. Longer Lead Time to Develop In order to provide more development time, … Continue Reading
On July 21, 2014, I posted the proposed Medicare Physician Fee Schedule, and described the intent by CMS to eliminate global surgery. On November 13, 2014, CMS issued the final 2015 Medicare Physician Fee Schedule, and CMS incorporated the changes regarding global surgery. Global Surgery There are three primary categories of global surgery packages that … Continue Reading
On October 27, 2014, the Governor signed Pennsylvania General Assembly enacted House Bill 1846, which limits both the authority and the reimbursement of physicians and providers other than pharmacies for prescription drugs. It provides as follows: Physicians dispensing prescription drugs from their offices shall receive no more than 110% of the original average wholesale price … Continue Reading
CMS has announced its concern regarding the level of compliance for documenting the face-to-face elements necessary for home health care certification. Attached is an educational piece published by Novitas Solutions on its Part B website. It lists the qualification criteria for home health benefits: Be confined to a home; Under the care of a physician; … Continue Reading
In the proposed 2015 Medicare Physician Fee Schedule, CMS is seeking comments regarding expanding coverage for secondary interpretation of diagnostic imaging. I’m enclosing pages 40370 and 40371 of the proposed Medicare Physician Fee Schedule. The enclosed material sites the Medicare Claims Processing Manual provisions which make is clear that a professional component interpretation service should … Continue Reading
