January 2011

HAPPY HOLIDAYS, Medicare fee schedule, and Red Flags rule

We hope you enjoyed the holidays!

Congress & President Obama did provide 2 nice “gifts” for the new year:
1) Medicare Fee Schedule changes that were to end on 11/30 have been extended thru 12/31/11, and
2) Physicians and other healthcare providers (including ambulance) were exempted from the Red Flags Rule.

As you know, Medicare payment rates under the Medicare Physician Fee Schedule (MPFS) are set according to statutory criteria. Even though the SGR rate will remain stable thru 12/31/11, there are other factors (e.g., RVU updates) that can change the amount paid for individual CPT codes. Once the new rates are published, we will know better how payments will be affected in 2011.


Medicare 2011 Preventive services

Medicare implemented a new Annual Wellness Visit (AWV) service which does NOT require a deductible or co-insurance for the patient. The current Initial Preventive Physical Exam (IPPE) which is available within the first 6 months of Medicare eligibility has a 2010 Allowed Amount of $146.88. The Allowed Amounts for all 2011 codes, including the new AWV, are being recalculated by Medicare based on the 0% change in the SGR and should be re-published any day now (still not available 1/3/11).

Another preventive service that will not have a deductible or co-insurance is Counseling to Prevent Tobacco Use (includes counseling to stop smoking) (codes G0436 & G0437). CMS allows 2 separate attempts and up to 4 visits each attempt per year.


Medicare EMs changes

As you already know from an email from me in November, beginning January 1, 2011 CMS will require ambulance services to track and report mileage to the nearest tenth of a load mile for all trips up to 100 load miles. CMS stated that ambulance services which do not currently have the ability to track tenths of miles must acquire that ability. CMS says this policy change could "save" Medicare - up to $80 million per year.
Additionally, the Rule will decrease annual reimbursement updates by a so-called "productivity adjustment." Beginning in 2011, the Ambulance Fee Schedule will be subject to this adjustment and is expected to reduce Medicare reimbursement to the ambulance industry by around $30 million in the first year that it takes effect.

The Final Rule also talks about CMS's intention to develop a "course of action" to implement the retroactive 2% urban, 3% rural, and 22.6% super rural bonus payments. Ambulance services have being waiting for months for CMS to reprocess these claims.


AMBULANCE FEE SCHEDULE
The Ambulance Inflation Factor (AIF) for 2011 is -0.1%. The AIF in 2010 was 0.0%.


Physical / occupational therapy Medicare fee cut

Just a reminder and as a follow-up to the email last month with a copy of the Medicare MLN Matters article, effective 1/1/11 Medicare will be decreasing their payment when:
· The same patient is seen the same day by more than 1 therapist in the same practice (e.g., PT & OT), or
· A patient receives more than 1 service or unit of service, or both, on the same day.

The modality with the highest RVU’s will be paid in full for the first unit, with all additional units and services paid at the lower rate to reflect the 20% reduction in the Practice Expense portion of the service(s).

Medicare 2011 ePRESCRIPTION (eRx) & PQRI

We have reviewed the 2011 CMS eRx requirements – the same code will be used in 2011.

If you plan to do PQRI in 2011, be sure to check with Rich for 2011 PQRI requirements. They do change each year and the current year’s codes MUST be used in order to get paid.


EMR / EHR
Just a reminder that CMB will assist you with selection at no cost. The time to negotiate fees, including future options that you may or may not want, is before signing the purchase agreement.


MEDICARE EDITING FOR ORDERING/REFERRING PROVIDER FOR DME

As you know, CMS backed off their 1/1/11 date to implement their requirement for all ordering and/or referring providers to be in the PECOS system due to the significant current backlog in processing provider enrollment applications. CMS announced in December 16th that the new “Placeholder” date for compliance is July 5, 2011.

December 2010

CPB Holiday schedule

CPB will be closed on Christmas Eve (Friday, December 24th), and New Years Day Eve, Friday, December 31st. We hope you enjoy the holidays!


PECOS – cms just “blinked”

CMS announced on November 24th that the automated edits will not be turned on effective January 3, 2011. They are working diligently to resolve enrollment backlogs and other system issues and will provide ample advanced notice to the provider and beneficiary communities before we begin any automatic nonpayment actions.


Medicare 2011 Fee Schedule

As you know, Medicare payment rates under the Medicare Physician Fee Schedule (MPFS) are set according to statutory criteria. Medicare has released the 2011 MPFS payment rates which are reflective of the 2011 Physician Fee Schedule Final Rule and are based on current law which provides a negative update for 2011. Before Thanksgiving, the House approved a 1 month delay in a 23% decrease that will take effect on December 1, 2010. The House approved the same measure on November 29 and the President is expected to sign the bill. However, this is only a 1 month reprieve while Congress attempts a permanent fix. Highmark Medicare has suggested affected practitioners consider the possibility of this legislation as you evaluate decisions related to your annual participation election. We will notify you about the 2011 physician update as more information becomes available at the end of December.


EMR’s

I just returned from a 3 day EHR/EMR conference with multiple seminars and reviewed 7 different EMR programs. Each had its own unique approach with different features and ways to use and access them. Purchasing an EMR is a BIG decision. If you haven't already, I strongly recommend that you review at least 5 different vendors to make sure your money is well spent and you can see what the range of quality is. It is important for you to look at each as it would work for your own practice - does the workflow match your office? If you dictate, does it support it?

You and your staff that will use the EMR needs to view it - is it easy to use? Does it capture data the way you practice medicine? Does it support eRx and PQRI? Does it give you the flexibility to use any clearinghouse, patient statement vendor, or export claims to a billing service? You may not choose to use those options, but by having them you retain the ability to make changes if your payments are not what they need to be.

And, very importantly, is it certified as meeting the CURRENT "meaningful use" (MU) criteria? No 2011 certification means no incentive payment from CMS! If it has never been certified, it would be wise to be very careful.

We are also hearing that some vendors are offering to contractually "guarantee" they will meet the current MU criteria. That may not be very good - if they cannot afford to get the certification before you purchase, then what guarantee can they provide if they do not get the certification or go out of business? If they don’t you lose the incentive payment and have to buy new EMR software!


2010 PART B DEDUCTIBLE

The Centers for Medicare & Medicaid Services (CMS) announced the Part B annual deductible for 2010 is $162.00 (it was $155 in 2010). With the poor economy, it is more important than ever to make every effort to collect all co-pays, deductibles (if known), and co-insurances on the date of service. The key is getting the payment before they receive your services, or at worst, before they leave your office.

Also, just a reminder that cash flow will be slow for the first 2-3 months of the year due to the current economy and patients showing greater reluctance to visit their physicians.


Medicare ALLOWABLE FEES

Each year CPB prepares a table with the Medicare Allowable Amounts for your commonly used office CPT codes. If you would like to receive this again in 2011, please notify Rich by December 13th.

2010 MEDICARE PHYSICAL, OCCUPATIONAL & SPEECH THERAPY CAP

The Therapy Cap for 2011 is $1,870 through for 2011. The Medicare Cap Exceptions process for independently practicing physical, speech and occupational therapists appears to have been extended 2011. However, as it currently stands for 2011, Medicare PT/OT fees will be cut for multiple services during a single episode of care after the first CPT code to 75% of the Allowed Amount for the Practice Expense component of the remaining approved CPT codes. The US Senate has approved a reduction in the decrease from 25% to 20% (paying 80%) but we will need to see what the House does.