Category Archives: Medicare & Reimbursement

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CMS Issues Hospital Price Transparency Rules

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

2019 Medicare Physician Fee Schedule Provides Future “Telehealth” or “Communication-Based” Billing Opportunities

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

2019 Proposed Medicare Fee Schedule

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

Medicare Telehealth Services

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

CMS Announces Bundled Payments Care Improvement Model

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

West Virginia Doctor Secures Temporary Restraining Order Against Medicare Exclusion

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

2017 Medicare Telehealth Changes

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

Progress on Medicare Payment Reform

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

SGR Fix Already Revised and Hospital Outpatient Department $$ Reduced

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

IRS Levy Against Medicare Payments Increases to 100% Effective October 16, 2015

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 Limits Scope of Review for MACs

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 Clarifies Written Agreement Requirement

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

CMS Proposes New Stark Exceptions: Timeshare Lease

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

CMS Proposes New Stark Exception: Recruitment of Non-Physician Practitioners

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

Colorado Approves Direct Medicare Payment to CRNA’s

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

Congress Repeals Medicare Sustainable Growth Rate (SGR)

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

No SGR Action by Senate

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

News from MGMA re SGR Repeal

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

CMS Proposes Rules to Improve Accountable Care Organizations (ACOs)

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
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