mhha presentation final (2) -sm april 2017 · the presentation herein was prepared as a tool to...

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4/19/2017 1 © 2017 Copyright, CGS Administrators, LLC. 1 January 30, 2017 Michigan Home Care & Hospice Association 2017 Annual Conference CGS JB Medicare Update Session May 4, 2017 © 2017 Copyright, CGS Administrators, LLC. 2 January 30, 2017 © 2017 Copyright, CGS Administrators, LLC. January 30, 2017 Disclaimer The presentation herein was current at the time it was published or uploaded onto the web. Medicare policy changes frequently so links to the source documents have been provided within the document for your reference. The presentation herein was prepared as a tool to assist providers and is not intended to grant rights or impose obligations. Although every reasonable effort has been made to assure the accuracy of the information within these pages, the ultimate responsibility for the correct submission of claims and response to any remittance advice lies with the provider of services. The Centers for Medicare & Medicaid Services (CMS) employees and agents, including CGS and its staff, make no representation, warranty, or guarantee that this compilation of Medicare information is error free and will bear no responsibility or liability for the results or consequences of the use of this guide. This publication is a general summary that explains certain aspects of the Medicare Program, but is not a legal document. Official Medicare Program provisions are contained in relevant laws, regulations, and rulings. © 2017 Copyright, CGS Administrators, LLC. 3 January 30, 2017 © 2017 Copyright, CGS Administrators, LLC. January 30, 2017 General Medicare Updates 21 st Century Cures Act Sequencing of Modifiers Assignment Agreement Advanced Beneficiary Notice of Noncoverage Standard Documentation Jurisdiction B DME MAC Updates Agenda

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Page 1: MHHA Presentation Final (2) -SM April 2017 · The presentation herein was prepared as a tool to assist providers and is not intended to grant rights or impose obligations. Although

4/19/2017

1

© 2017 Copyright, CGS Administrators, LLC. 1January 30, 2017

Michigan Home Care & Hospice Association 2017

Annual Conference

CGS JB Medicare Update Session

May 4, 2017

© 2017 Copyright, CGS Administrators, LLC. 2January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

DisclaimerThe presentation herein was current at the time it was published or uploaded onto the web. Medicare policy changes frequently so links to the source documents have been provided within the document for your reference. The presentation herein was prepared as a tool to assist providers and is not intended to grant rights or impose obligations. Although every reasonable effort has been made to assure the accuracy of the information within these pages, the ultimate responsibility for the correct submission of claims and response to any remittance advice lies with the provider of services.

The Centers for Medicare & Medicaid Services (CMS) employees and agents, including CGS and its staff, make no representation, warranty, or guarantee that this compilation of Medicare information is error free and will bear no responsibility or liability for the results or consequences of the use of this guide. This publication is a general summary that explains certain aspects of the Medicare Program, but is not a legal document. Official Medicare Program provisions are contained in relevant laws, regulations, and rulings.

© 2017 Copyright, CGS Administrators, LLC. 3January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

General Medicare Updates

21st Century Cures Act

Sequencing of Modifiers

Assignment Agreement

Advanced Beneficiary Notice of Noncoverage

Standard Documentation

Jurisdiction B DME MAC Updates

Agenda

Page 2: MHHA Presentation Final (2) -SM April 2017 · The presentation herein was prepared as a tool to assist providers and is not intended to grant rights or impose obligations. Although

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© 2017 Copyright, CGS Administrators, LLC. 4January 30, 2017

General Medicare Updates

MLN Matters

© 2017 Copyright, CGS Administrators, LLC. 5January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Condition of Payment Prior Authorization Program for K0856/K0861

• Submit Prior Authorization Request to DME MAC March 6, 2017 Illinois (JB) and West Virginia (JC) beneficiaries and suppliers

• Claims submitted for K0856 or K0861 are subject to prior authorization decision for payment Date of Service on or after March 20, 2017 Nationwide on July 17, 2017

• Additional Information https://www.cms.gov/Research-Statistics-Data-and-

Systems/Monitoring-Programs/Medicare-FFS-Compliance-Programs/DMEPOS/Prior-Authorization-Process-for-Certain-Durable-Medical-Equipment-Prosthetic-Orthotics-Supplies-Items.html

© 2017 Copyright, CGS Administrators, LLC. 6January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Continuous Glucose Monitors (CGM) Effective January 12th 2017 one CGM approved as DME

Dexcom G5 Mobile CGM

Inexpensive and routinely purchased (IRP)

E1399

Dexcom G5 Mobile CGM durable receiver

Furnished on or after 1/12/17

Narrative “Dexcom G5 Receiver”

A9999

All supplies and accessories furnished on a monthly basis for use with a Dexcom G5 Mobile CGM receiver

Furnished on or after 1/12/17

Narrative “Supplies used with Dexcom G5 Receiver”

Page 3: MHHA Presentation Final (2) -SM April 2017 · The presentation herein was prepared as a tool to assist providers and is not intended to grant rights or impose obligations. Although

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© 2017 Copyright, CGS Administrators, LLC. 7January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Continuous Glucose Monitors (2)Therapeutic CGM may be covered when all of the following criteria are met:

Beneficiary has diabetes mellitus; and,

Beneficiary has been using a home blood glucose monitor (BGM) and performing frequent (four or more times a day) BGM testing; and,

Beneficiary is insulin-treated with multiple daily injections (MDI) of insulin or a continuous subcutaneous insulin infusion (CSII) pump; and,

Beneficiary's insulin treatment regimen requires frequent adjustment by the beneficiary on the basis of therapeutic CGM testing results.

© 2017 Copyright, CGS Administrators, LLC. 8January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

MLN Matters MM 9848

Payment for Oxygen Volume Adjustments and Portable Oxygen Equipment

When a beneficiary is receiving both stationary and portable equipment with High Liter Flow (HLF)

• The portable is now separately payable

In order to receive payment for the portable

• The supplier must append the QF modifier to both the stationary and the portable

• Effective on or after Dates of Service April 1, 2017

© 2017 Copyright, CGS Administrators, LLC. 9January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Social Security Number Removal Initiative (SSNRI)

Requires the removal of Social Security Numbers from Medicare cards by April 2019

Replaced with a Medicare Beneficiary Identifier (MBI)

Distribution of new cards will begin April 2018

CMS Overview webpage:

https://www.cms.gov/Medicare/SSNRI/Index.html

Page 4: MHHA Presentation Final (2) -SM April 2017 · The presentation herein was prepared as a tool to assist providers and is not intended to grant rights or impose obligations. Although

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© 2017 Copyright, CGS Administrators, LLC. 10January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

• CGS conducting a review of the data utilized to establish reimbursement

• Review may or may not result in a change in the reimbursement

• While reviewing data, CGS will not be reverting to individual pricing consideration

• CMS’s intent is for contractors to establish prices for established HCPCs codes

• Once review is complete, CGS will share the results

Custom Cushion Codes E2609/E2617

© 2017 Copyright, CGS Administrators, LLC. 11January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

MLN Matters MM9886 DMEPOS Order Requirements for Changing Suppliers

Accept timley order and medical documentation (so long as it meets Medicare requirements), regardless of whether the supplier received the documentation directly from the beneficiary’s eligible practitioner or from another, transfer supplier.

There is a change in the order for the accessory, supply, drug and so forth

On a regular basis, only if it so specified in the documentation section of a particular medical policy

When an item is replaced

When there is a change in supplier, if the recipient supplier did not obtain a valid order for the DMEPOS item form the transferring supplier.

© 2017 Copyright, CGS Administrators, LLC. 12January 30, 2017

21st Century Cures Act

Page 5: MHHA Presentation Final (2) -SM April 2017 · The presentation herein was prepared as a tool to assist providers and is not intended to grant rights or impose obligations. Although

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© 2017 Copyright, CGS Administrators, LLC. 13January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Section 16005 KU Informational modifier used to receive the

unadjusted fee schedule amount

Group 3 Complex Rehabilitative Power Wheelchair

Accessory

Seat

Back Cushion

KU Modifier use extended through June 30, 2017

Spreadsheets are no longer accepted for adjustments to claims with DOS on or after January 1st, 2017

Spreadsheets still accepted for DOS 1/1/2016 – 6/30/2016

© 2017 Copyright, CGS Administrators, LLC. 14January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Section 16007

CMS is currently working to implement this section and will be providing contractor instructions for re-processing the applicable claims. There is no action required for the suppliers at this time. Formal instructions will be issued in the near future.

© 2017 Copyright, CGS Administrators, LLC. 15January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Resources for 21st Cures Act Questions

Complete list of the wheelchair accessories and cushions used with the Group 3 complex wheelchairs

https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/DMEPOSFeeSched/Downloads/PAMPA-Code-List.zip

Medicare Claims Processing Manual, Chapter 17, Section 20.1.3

https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/clm104c17.pdf

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© 2017 Copyright, CGS Administrators, LLC. 16January 30, 2017

Sequencing of Modifiers

For Capped Rental items paid as a Lump Sum Purchase

© 2017 Copyright, CGS Administrators, LLC. 17January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

MLN Matters MM9579

Effective date – October 1, 2016

Repair parts billed with RB modifier paid as purchase, regardless of the following:

Competitive bidding item or not

Within or outside a CBA

Payment category of repair part

Rented grandfathered equipment

Supplies and accessories used with grandfathered equipment can continue to be provided by grandfathered supplier through the end of the capped rental period.

© 2017 Copyright, CGS Administrators, LLC. 18January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Lump Sum Payment for Repair Parts Effective October 1, 2016, repair parts used to make

medically necessary beneficiary-owned base equipment serviceable is paid on a lump sum purchase basis.

Repairs of medically necessary beneficiary-owned items can be performed by any Medicare-enrolled supplier.

Applies to all repair parts billed with RB modifier, including beneficiaries residing in a CBA.

Page 7: MHHA Presentation Final (2) -SM April 2017 · The presentation herein was prepared as a tool to assist providers and is not intended to grant rights or impose obligations. Although

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© 2017 Copyright, CGS Administrators, LLC. 19January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Modifiers

RB modifier

NU pricing modifier

Appropriate informational modifiers

KX, RT and/or LT modifiers

KH modifier (if the HCPCS is in the capped rental category)

Do not report KY, KE or RR modifier with RB modifier.

© 2017 Copyright, CGS Administrators, LLC. 20January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Modifier Sequencing

NU modifier – must be first modifier listed

RT and LT modifiers must appear in the 2nd and 3rd positions when billing for a capped rental HCPCS code and 2 units of service are billed on the same line

99 modifier is required when more than 4 modifiers are reported

NU, RT and LT (as needed) modifiers, and the 99 modifier (as needed) must all appear on the claim line.

Additional Modifiers listed in narrative of claim.

© 2017 Copyright, CGS Administrators, LLC. 21January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Examples

Example (99 modifier not needed)

E0992 NU RB KX

Example (99 modifier needed)

E2370 NU RT LT 99 (Narrative includes KH, RB, KX, and sometimes KU)

RTLT must be in 2nd and 3rd place for bilateral items with a number of units of 2

Page 8: MHHA Presentation Final (2) -SM April 2017 · The presentation herein was prepared as a tool to assist providers and is not intended to grant rights or impose obligations. Although

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© 2017 Copyright, CGS Administrators, LLC. 22January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

References

MLN Matters® Number: MM9579

MLN Matters®Number: MM8822

MLN Matters®Number: MM8566

Update to MM8822

© 2017 Copyright, CGS Administrators, LLC. 23January 30, 2017

Assignment Agreement

© 2017 Copyright, CGS Administrators, LLC. 24January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Assignment Agreement

Assignment-

Written agreement

Beneficiaries, physicians/suppliers, Medicare

Participating Suppliers

Signed contract

Accept assignment on all services

Nonparticipating Suppliers

Assignment on claim-by-claim basis

Page 9: MHHA Presentation Final (2) -SM April 2017 · The presentation herein was prepared as a tool to assist providers and is not intended to grant rights or impose obligations. Although

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© 2017 Copyright, CGS Administrators, LLC. 25January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Nature and Effect of Assignment on Claims

Participating Physician / Supplier

Agrees to accept Medicare allowed amount on all claims

Cannot determine assignment on claim by claim basis

Can only charge deductible / coinsurance

© 2017 Copyright, CGS Administrators, LLC. 26January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Mandatory Assignment for Covered Drugs Billed to Medicare

Section 114 BIPA- Mandatory assignment applies to Medicare-covered drugs

Claims billed unassigned will process assigned

Suppliers may not bill charges to anyone beyond the Medicare Part B deductible and coinsurance

Does not apply to dispensing fees

© 2017 Copyright, CGS Administrators, LLC. 27January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Violation of Assignment

Physician / Supplier

Collects or attempts to collect from enrollee or anyone else

Any amount plus benefit

Exceeds Medicare allowed amount

Charges enrollee for paperwork involved in filing an assigned claim

Page 10: MHHA Presentation Final (2) -SM April 2017 · The presentation herein was prepared as a tool to assist providers and is not intended to grant rights or impose obligations. Although

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© 2017 Copyright, CGS Administrators, LLC. 28January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Supplementary Medical Insurance (SMI)

Enrollee has private insurance in addition to Medicare

Physician / Supplier

Accepts assignment of SMI

May not bill or collect amount that exceeds Medicare allowed amount

Enrollee or private insurance

Refunds will be requested by MAC

© 2017 Copyright, CGS Administrators, LLC. 29January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Fragmented Billing

Non-participating physician / supplier

Accepts assignment for some services

Claims payment from enrollee

Services performed at the same place / same occasion

Must accept assignment or bill enrollee for all services performed at the same place / same occasion

© 2017 Copyright, CGS Administrators, LLC. 30January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Fragmented Billing Exception

Mandatory Assignment Situations

Physician / Supplier may choose to not accept assignment for other services at the same place or occasion

Page 11: MHHA Presentation Final (2) -SM April 2017 · The presentation herein was prepared as a tool to assist providers and is not intended to grant rights or impose obligations. Although

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© 2017 Copyright, CGS Administrators, LLC. 31January 30, 2017

Advanced Beneficiary Notice of Noncoverage

Special Guidance for Unassigned Claims

© 2017 Copyright, CGS Administrators, LLC. 32January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

New ABN Form

© 2017 Copyright, CGS Administrators, LLC. 33January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Unassigned Claims Only

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© 2017 Copyright, CGS Administrators, LLC. 34January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Instructions – Blank G, Option 1

Single line strike

ABNs printed specifically for issuance of unassigned items or

Line can be hand-penned on an already printed ABN

Sentence must be stricken

May not be entirely concealed or deleted

No CMS requirement for initial or date annotated

If changes to Blank G, Option 1 are completed before issuing the ABN to the beneficiary

© 2017 Copyright, CGS Administrators, LLC. 35January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Unassigned Claims Only

© 2017 Copyright, CGS Administrators, LLC. 36January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Instructions – Blank H

Statement can be included on ABNs for unassigned items

May also be hand written

ABNs with the sentence stricken out in Option 1 mustcontain the CMS-approved unassigned claim statement in Blank H

If not, then it is not considered a valid notice

If Blank H consists of the CMS-approved statement, then the last sentence in Option 1 should be stricken.

Page 13: MHHA Presentation Final (2) -SM April 2017 · The presentation herein was prepared as a tool to assist providers and is not intended to grant rights or impose obligations. Although

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© 2017 Copyright, CGS Administrators, LLC. 37January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Resources

Supplier Manual Chapter 6

Assignment agreement

CMS Internet Only Manual (IOM)100-04, Chapter 1, Section 30.3.2

Enrollment

Participating / Non-Participating

Social Security Act Section 1842(h); 42 U.S.C. Section 1395u (h); 42 C.F.R. Sections 400.202, 424.55 (1999)

ABN Instruction

https://www.cms.gov/Medicare/Medicare-General-Information/BNI/Downloads/ABN-Form-Instructions.pdf

© 2017 Copyright, CGS Administrators, LLC. 38January 30, 2017

Standard DocumentationSLD Update

Dispensing Orders

Detailed Written Orders

Written Orders Prior to Delivery

© 2017 Copyright, CGS Administrators, LLC. 39January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Standard Documentation Language Update

Standard Documentation Language

Removed from LCD

Coming 2017 with LCD updates

Standard Documentation Requirement Article (A55426)

Separate article linked to LCD

More efficient updates when standard documentation is updated

Shortens LCD for easier reading

Allows for emphasis of policy requirements in the LCD and PA

Page 14: MHHA Presentation Final (2) -SM April 2017 · The presentation herein was prepared as a tool to assist providers and is not intended to grant rights or impose obligations. Although

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© 2017 Copyright, CGS Administrators, LLC. 40January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Overview Authorized to Order

Physician, Nurse practitioner (NP), Clinical Nurse Specialist (CNS), Physician Assistant (PA)

Dispensing Orders

Can be verbal or written

Obtained prior to delivery

Must be followed up with DWO prior to billing

Detailed Written Order (DWO)

Includes Beneficiary Name, Prescribers Name, Order date, Detailed Description of the item,

Prescriber’s signature and date

Obtained prior to billing

© 2017 Copyright, CGS Administrators, LLC. 41January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

For all items bulleted on this slide prior to delivery

Pressure reducing support surfaces (Group I, II, III), including mattress overlays, mattresses and air-fluidized beds

Seat lift mechanisms

TENS

PMD

Wheelchair seating

NPWT

A date stamp (or similar) is required which clearly indicates the supplier’s date of receipt of the completed WOPD with the prescribing practitioner’s signature and signature date.

Written Order Prior to Delivery

© 2017 Copyright, CGS Administrators, LLC. 42January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

5 Element Order (5EO) for ACA 6407The 5EO must include all of the following elements:

Beneficiary's name

Item of DME ordered - this may be general

Signature of the prescribing practitioner

Prescribing practitioner's National Practitioner Identifier (NPI)

The date of the order

Must be completed within six (6) months after the required ACA 6407 face-to-face examination; and,

Must be received by the supplier before delivery of the listed item(s); and,

A date stamp or equivalent is encouraged to be used to document the 5EO receipt date by the supplier.

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© 2017 Copyright, CGS Administrators, LLC. 43January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

The 7EO must meet all of the requirements below:

•Beneficiary's name

•Description of the item that is ordered. This may be general –e.g., "power operated vehicle", "power wheelchair", or "power mobility device"– or may be more specific.

•Date of the face-to-face examination

•Pertinent diagnoses/conditions that relate to the need for the POV or power wheelchair

•Length of need

•Prescribing physician's signature

•Date of prescribing physician's signature

7 Element Order for Power Mobility Devices(PMD)

© 2017 Copyright, CGS Administrators, LLC. 44January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Order Type Guidance Requirements Evidence of Receipt

Supplies /Accessories to the base equipment

Standard WOPD CMS or DME MACs

Must meet the requirement of a DWO

Date Stamp or Equivalent

Must obtain a DWO  if not included on the 

5‐Element Order (ACA 6407 items)

42 CFR 410.38(c), 

All Elements Date Stamp or Equivalent

Must obtain and DWO

7‐Element Order (PMDS)

42 CFR 410.38(c), 

All Elements N/A Must  obtain aDetailed Product Description (DPD)

Written Orders Prior to Delivery

© 2017 Copyright, CGS Administrators, LLC. 45January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

There is a change in the order for the accessory, supply, drug, etc.

On a regular basis (even if there is no change in the order) only if it is so specified in the documentation section of a particular medical policy

When an item is replaced

When there is a change in the supplier

When is a New Order Required?

Page 16: MHHA Presentation Final (2) -SM April 2017 · The presentation herein was prepared as a tool to assist providers and is not intended to grant rights or impose obligations. Although

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© 2017 Copyright, CGS Administrators, LLC. 46January 30, 2017

Standard Documentation

Continued Medical Need

Continued Use

Request for Refill

© 2017 Copyright, CGS Administrators, LLC. 47January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

“Medicare Contractors shall establish appropriate safeguards to assure that payments are not made beyond the last month of medical necessity.”

Safeguards in Making Payments

© 2017 Copyright, CGS Administrators, LLC. 48January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

For ongoing supplies and rental DME items

Beneficiary’s medical record must support that the item continues to be used by the beneficiary and remains reasonable and necessary

Continued Medical Need Ongoing Supplies/Rental DME

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© 2017 Copyright, CGS Administrators, LLC. 49January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

A recent order by the treating physician for refills

A recent change in prescription

A properly completed CMN with an appropriate length of need specified

Timely documentation in the beneficiary’s

Medical record showing usage of the item

Timely documentation is defined as a record in the preceding 12 months unless otherwise specified elsewhere in the policy

Medical Record Documentation to Support Continued Need

© 2017 Copyright, CGS Administrators, LLC. 50January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Continued use describes the ongoing utilization of supplies or a rental item by a beneficiary

Suppliers are responsible for monitoring utilization to make sure the DMEPOS item continues to be used by the beneficiary.

What is Continued Use?

© 2017 Copyright, CGS Administrators, LLC. 51January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Any of the following may serve as documentation that an item submitted for reimbursement continues to be used by the beneficiary

Timely documentation in the beneficiary's medical record showing usage of the item, related option/accessories and supplies

Valid request for refill documentation

Supplier records documenting beneficiary confirmation of continued use of a rental item

Timely documentation is defined as a record in the preceding 12 months unless otherwise specified

Continued Use Documentation

Page 18: MHHA Presentation Final (2) -SM April 2017 · The presentation herein was prepared as a tool to assist providers and is not intended to grant rights or impose obligations. Although

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© 2017 Copyright, CGS Administrators, LLC. 52January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

CMS IOM Publication 100-08, Medicare Program Integrity Manual, Chapter 4, Section 4.26.1

For DMEPOS products that are supplied as refills to the original order, suppliers must contact the beneficiary prior to dispensing the refill

Jurisdiction B Supplier Manual, Chapter 8, “Documentation”

Request for Refill

© 2017 Copyright, CGS Administrators, LLC. 53January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

For all items and accessories supplied as refills to the original order:

Suppliers must contact the beneficiary prior to dispensing

Suppliers must not automatically ship on pre-determined basis

Contact with the beneficiary must not take place no sooner than 14 calendar days prior to delivery/shipping date

Supplier must deliver the items no sooner than 10 calendar days prior to the end of the usage of the current product

Contact may be written or telephone

Retrospective attestation statement not sufficient

Request for Refill Documentation

© 2017 Copyright, CGS Administrators, LLC. 54January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Documentation must include

Beneficiary’s name or authorized representative

A description of each item that is being requested

Quantity of supplies remaining on hand (or)

Functionality of accessory being replaced

Date of refill request

Request for Refill Documentation

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© 2017 Copyright, CGS Administrators, LLC. 55January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Refill Documentation RequirementsObtained In Person 

@ Retail StoreWritten Request From Beneficiary

Telephone Contact Between Supplier and Beneficiary

Signed delivery slip or copy of itemized sales receipt

Beneficiary name and/or authorized rep (indicate relationship)

Beneficiary name and/or authorized rep (indicate relationship)

Delivery slip/receiptshould indicate items were picked

Statement the beneficiary is requesting a refill

Name of person contacting/receiving call from beneficiary

Description of each item requested Statement the beneficiary is requesting a refill

Signature of requestor Description of each item requested

Date of request Date of contact

Quantity/functional condition of each item still remaining

Quantity/functional condition of each item still remaining

Contact no sooner than 14 calendar days prior to delivery/shipping

Shipment/delivery occurred no sooner than 10 calendar days prior to current supply exhausting

© 2017 Copyright, CGS Administrators, LLC. 56January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Consumable Supplies (supplies that get “used up”)

Examples are surgical dressings, urological supplies or diabetic testing supplies

Supplier should assess and document the remaining supplies

Quantifiable

Determine if the supplies is nearly exhausted and/or compare to the last order filled

Consumable Supplies

© 2017 Copyright, CGS Administrators, LLC. 57January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Nonconsumable supplies (supply items that are more durable in nature, but may require periodic replacement)

Examples – PAP supplies, nebulizer supplies, RAD supplies

The supplier should assess whether the supply item remains functional

Replacement should be provided only when the item is no longer functional

The supplier should document the condition of the item being replaced in sufficient detail to indicate why the replacement is necessary at that time.

Nonconsumable Supplies

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© 2017 Copyright, CGS Administrators, LLC. 58January 30, 2017

Standard Documentation

Proof of Delivery

© 2017 Copyright, CGS Administrators, LLC. 59January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Proof of Delivery (POD)

Supplier Standard 12

Signed POD required to verify beneficiary received DMEPOS item

Required to verify beneficiary received item

Must be available upon request

If not provided, claim denied, overpayment requested

If no documentation provided on consistent basis, may be referred to Office of Inspector General (OIG)

Maintain documentation for seven years

© 2017 Copyright, CGS Administrators, LLC. 60January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Method 1 - Direct Delivery

Delivery directly to a beneficiary by a supplier

The POD record must include:

Beneficiary's name

Delivery address

Sufficiently detailed description to identify the item(s) being delivered (e.g., brand name, serial number, narrative description)

Quantity delivered

Date delivered

Beneficiary (or designee) signature

Date of service is the date of delivery

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© 2017 Copyright, CGS Administrators, LLC. 61January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Method 2 – Deliver/Shipping Service

Delivery to beneficiary via shipping service

The POD record must include:

Beneficiary's name

Delivery address

Package invoice and delivery confirmation

Detailed description of the item(s) being delivered

Quantity delivered

Date delivered

Evidence of delivery

Date of service is the shipping date61

© 2017 Copyright, CGS Administrators, LLC. 62January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Method 3 – Delivery to Nursing Facility

Delivery to a nursing facility on the beneficiary’s behalf

The POD record is based on delivery via Method 1 (direct delivery) or Method 2 (shipping service)

Documentation from the nursing facility

© 2017 Copyright, CGS Administrators, LLC. 63January 30, 2017

POD Exception: Anticipation of Discharge

Delivery to Facility Delivered for the purpose

of fitting/training

Two days prior to discharge from hospital or nursing facility

DOS equals discharge date

POS 12 (beneficiary’s home)

Delivery to Home Two days prior to

discharge from hospital or nursing facility

DOS equals discharge date

POS 12 (beneficiary’s home)

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© 2017 Copyright, CGS Administrators, LLC. 64January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

POD Exception:Part A Covered Inpatient Stay

May not be billed to DME MAC:

Drugs or other DMEPOS used by the beneficiary prior to discharge

For purposes other than training and/or fitting

Surgical Dressings, Urological Supplies or Ostomy Supplies provided by facility

These items are payable to the facility under Part A Medicare

Applies to beneficiaries in:

Hospitals

Skilled nursing facilities (POS 31)

Nursing facilities (POS 32)

© 2017 Copyright, CGS Administrators, LLC. 65January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

POD: Beneficiaries Entering Medicare

Statement of item(s) in beneficiary’s possession:

Date of delivery

Information that supplier examined item

Information that the item(s) meet Medicare requirements

Signed and dated by beneficiary or designee

Rented items

Reasonable Useful Lifetime (RUL) begins first day of first rental month

DOS

Match signature date of beneficiary or designee

© 2017 Copyright, CGS Administrators, LLC. 66January 30, 2017

POD Signature

POD can be signed by:

Beneficiary

Beneficiary’s designee

Relationship to beneficiary must be noted on delivery slip

POD cannot be signed by:

Suppliers

Employees of suppliers

Anyone with financial interest in delivery of item

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© 2017 Copyright, CGS Administrators, LLC. 67January 30, 2017

CGS Administrators, LLC

Jurisdiction B DME MAC Updates

© 2017 Copyright, CGS Administrators, LLC. 68January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Voluntary Check Refunds

Jurisdiction B and C refunds should not be combined on one check

Jurisdiction B Refunds:

CGSDME MAC Jurisdiction BP.O. Box 953479St. Louis, MO 63195‐3479

Jurisdiction C Refunds:

CGS DME MAC Jurisdiction CP.O. Box 955152St. Louis, MO 63195‐5152

© 2017 Copyright, CGS Administrators, LLC. 69January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

As a result of data demonstrating a high claims payment error rate, MR conducted complex service-specific prepayment reviews

Data is from the time period of October 1through December 31, 2016

Total percentage in Top Reasons for Denials section could be greater than 100% because some claims were denied for multiple reasons

Complex Service-Specific Reviews

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© 2017 Copyright, CGS Administrators, LLC. 70January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

HCPCS Code A4253 – Blood Glucose Test Strips

93% of claims denied

Increase from previous quarter of 6%

Top Reasons for Denials

The medical record documentation does not document the specific reason for the additional testing materials for this particular beneficiary (73.71%)

Payment for supplies billed above normal policy usage is being denied due to lack of documentation to support that they are reasonable and necessary (38.01%)

The medical record documentation does not establish that the treating physician saw the beneficiary and evaluated the beneficiary's diabetes control within 6 months before ordering the quantities of supplies exceeding utilization guidelines (27.72%)

Complex Service-Specific Reviews

© 2017 Copyright, CGS Administrators, LLC. 71January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

HCPCS Code E0277 – Powered Pressure-Reducing Support Surface

75% of claims denied

Increase from previous quarter of 12%

Top Reasons for Denials

The medical record documentation provided indicates one small stage 3 or 4 pressure ulcer on the trunk or pelvis (60%)

The medical record documentation provided only indicates stage 2 pressure ulcers on the trunk or pelvis (40%)

The medical record documentation provided only indicates one stage 2 pressure ulcer on the trunk or pelvis (40%)

Complex Service-Specific Reviews

© 2017 Copyright, CGS Administrators, LLC. 72January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

HCPCS Code E1390 – Oxygen Concentrator

60% of claims denied

Decrease from previous quarter of 2%

Top Reasons for Denials

The medical record documentation does not support the treating physician has determined that the beneficiary has a severe lung disease or hypoxia related symptoms that might be expected to improve with oxygen therapy(30.92%)

The medical record documentation does not support the blood gas study was obtained while the beneficiary was in a chronic stable state (26.82%)

Medical records do not verify that the standard treatment regimen associated with the disease condition producing the hypoxia-related symptoms was tried or considered and deemed clinically ineffective (22.79%)

Complex Service-Specific Reviews

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© 2017 Copyright, CGS Administrators, LLC. 73January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Jurisdiction B ResourcesInteractive Voice Response (IVR) Unit Phone: 1.877.299.7900

Customer Service Phone:Hours of Operation:

1.866.590.6727Monday – Friday, 8:00 a.m. – 5:00 p.m. ET

Telephone Re-openings Phone:Hours of Operation:

1.844.240.7490Monday – Friday, 8:00 a.m. – 5:00 p.m. ET

Paper Claim Submission Address: CGSPO Box 20013Nashville, TN 37202

Adjustment Requests (Reopenings), EFT Form Submission, and Written Inquiries

Address: CGSPO Box 20007Nashville, TN 37202

Redetermination Requests Fax:

Address:

1.615.660.5976

CGSPO Box 20007Nashville, TN 37202

Also accepted through esMD

Overpayment Appeals Fax:

Address:

1.615.782.4514

CGSOverpayment AppealsPO Box 23070Nashville, TN 37202

© 2017 Copyright, CGS Administrators, LLC. 74January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

DME MAC Jurisdiction B: Online Resourceshttp://www.cgsmedicare.com/jb/index.html

© 2017 Copyright, CGS Administrators, LLC. 75January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Jurisdiction B Resources Supplier Manual

http://cgsmedicare.com/jb/pubs/supman/index.html

Local Coverage Determinations

http://cgsmedicare.com/jb/coverage/lcdinfo.html

Medical Review Resources

http://cgsmedicare.com/jb/mr/resources.html

Online Tools

http://cgsmedicare.com/jb/help/tools.html

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© 2017 Copyright, CGS Administrators, LLC. 76January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Educational Opportunities Online Educational Welcome Center

New Supplier Center

Dear Physician Letters

Calendar of Events

Online Education

Podcasts

MLNs

Video Education

Workshops

http://cgsmedicare.com/jb/education/index.html

© 2017 Copyright, CGS Administrators, LLC. 77January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

2017 Jurisdiction B Workshops

http://www.cgsmedicare.com/jb/education/workshops.html

Educational Opportunities

Chicago, ILIndianapolis, IN

Cleveland, OH

Nashville, TN

JURISDICTION B

© 2017 Copyright, CGS Administrators, LLC. 78January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Upcoming Policy Webinars May 4 Lower Limb Prosthetics

May 5 External Infusion

May 11 Manual Wheelchair Bases

May 12 Surgical Dressings

May 17 Hospital Beds

May 19 Respiratory Assist Devices

May 23 Oxygen

May 25 Oxygen – LiveLine Plus

May 30 Enteral Nutrition

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© 2017 Copyright, CGS Administrators, LLC. 79January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Upcoming General Topic Webinars May 2 Documentation Requirements – General Principles

May 9 Documentation Requirements – Orders and CMNs

May 9 Medicare 101

May 10 Medicare 102

May 16 Documentation Requirements – Refill and Delivery

May 18 Reopenings and Redeterminations

May 24 Participation and Assignment

May 31 Prior Authorization (PAR) Process

© 2017 Copyright, CGS Administrators, LLC. 80January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

CGS Website Surveys When visiting http://www.cgsmedicare.com

and you see the survey, please take a moment to provide feedback.

Use ForeSee to give us your thoughts about the CGS website.

Website enhancements are based on your requests.

Once you complete a survey, you will not be asked again for 30 days. Complete a survey then complete another in a few months to let us know changes have been made.

© 2017 Copyright, CGS Administrators, LLC. 81January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

MSI Live

Evaluate Our Services!

The MAC Satisfaction Indicator (MSI) is the best way to share your opinions directly with the Centers for Medicare & Medicaid Services (CMS) about your experience with us.

These survey results will help us find ways to better serve you.

https://cfigroup.qualtrics.com/jfe/form/SV_3WeVjGWpc5NQXOJ?MAC_BRNC=2&MAC=JB DME

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© 2017 Copyright, CGS Administrators, LLC. 82January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

myCGS Web PortalmyCGS provides access to beneficiary eligibility, claim status,

claim denial information, and much more.

The myCGS portal mirrors all of the functionality currently contained in the Interactive Voice Response (IVR) unit.

myCGS includes several additional and more detailed features than the IVR can provide.

FAQs, Registration Guides, and User Manuals are available.

To learn more, visit: http://www.cgsmedicare.com, select JB DME or JC DME, then select the myCGS link from the left navigation menu.

Register today!

© 2017 Copyright, CGS Administrators, LLC. 83January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

CGS ListServ

Stay updated on DME MAC Jurisdiction B news!

Sign up for the DME MAC Jurisdiction B ListServ: http://www.cgsmedicare.com/medicare_dynamic/ls/001.asp?wb48617274=890F20EF

Enter your name, location, email address, and company

Choose the contract and/or specialty information that fits your business

Click “Submit”

© 2017 Copyright, CGS Administrators, LLC. 84January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

MR WIZARD

MR WIZARD takes the mystery out of CGS Medical Review denials

Detailed claim line denials

Instant access to denial detail

Available 24/7 with no registration needed

Just enter the CCN in the appropriate field!

If an ADR is associated, status of the ADR will be provided

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© 2017 Copyright, CGS Administrators, LLC. 85January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Social Media

© 2017 Copyright, CGS Administrators, LLC. 86January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

Find Us on Facebook® and Twitter ®!

Find the CGS DME MAC POE page on Facebook®.

Like our page and get all of the latest DME MAC POE information and more on the CGS DME POE Facebook®

page at: http://www.facebook.com/CGSadminDME

Provider Outreach and Education is now on Twitter®.

Search “@JBDMEPOE” on your Twitter account to follow us.

Our tweets will include reminders about Medicare requirements, helpful tips, and POE events.

© 2017 Copyright, CGS Administrators, LLC. 87January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

GO Mobile CGS GO MOBILE IS KEEPING

YOU CONNECTED!

CGS Go Mobile works on Apple and Android phones and tablets!

The download is free!

Access and share important CGS Medicare information from the convenience of your mobile device!

www.cgsmedicare.com/jb/onlinetools/gomobile.html

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© 2017 Copyright, CGS Administrators, LLC. 88January 30, 2017 © 2017 Copyright, CGS Administrators, LLC.January 30, 2017

CGS Connect Jurisdiction BCGS ConnectTM is a unique concierge-level service for suppliers

seeking professional review and evaluation of pre-claim documentation before submitting an initial claim to Medicare.

Clinical Reviews

Urological Supplies (A4353)

PAP (E0601)

Oxygen and Oxygen Equipment (E1390)

Manual Wheelchairs (K0004)

Hospital Beds and Accessories (E0260/E0394/E0301/E0303/E0912)

Estimated MR Response Times: 10-15 days

Routine Reviews Glucose Monitors (A4253/E0607NU)

Nebulizers (E0570)

Oxygen and Oxygen Equipment (E1390)

Knee Orthoses (K0901)

Knee Orthoses (L1832/L1833/L1843

© 2017 Copyright, CGS Administrators, LLC. 89January 30, 2017

Questions?

© 2017 Copyright, CGS Administrators, LLC. 90January 30, 2017

Thank you for inviting us!