north carolina mgma spring conference - th mgmt., … and mohs examination of specimens mr tip: mohs...
TRANSCRIPT
North Carolina MGMA Spring Conference
Presented by Palmetto GBA Provider
Outreach amp Education
May 13th 2015
552015 1
Disclaimer
The information provided in this presentation was current as of 05042015
Any changes or new information superseding the information in this presentation is provided in articles with
publication dates after 05042015 posted on our website at
wwwPalmettoGBAcomJ11B
552015 2
CPT only copyright 2014 American Medical Association All rights reserved
The Code on Dental Procedures and Nomenclature is published in Current Dental Terminology (CDT) Copyright copy 2014 American Dental Association
(ADA) All rights reserved
Agenda
Medicare Updates and Changes
CERT
Medical Review Spotlight
Hot Topics and Reminders
News to Use and Resources
552015 3
Updates and Changes
4
Provider Enrollment Form
CMS 855R (Reassignment of Benefits) form revised
Mandated use - May 31 2015
Current or revised form accepted from the date the revised form is published through May 31 2015
Revised form available on CMS website - December 29 2014
552015 5 MMSE1432
Laboratory Services for ESRD Claims
Effective April 1 2015
Elimination of the 5050 Payment Rule for Laboratory Services on End Stage Renal Disease (ESRD) Claims
ESRD PPS requires all renal dialysis laboratory services be paid in the ESRD facility bundled payment and therefore may only be billed by the ESRD facility
552015 6 MM8957
Health Professional Shortage Area (HPSA)
CMS 2015 HPSA Zip Code Files Applicable on claims with dates of service on
or after January 1 2015 through December 31 2015 Separate Primary Care and Mental Health Zip
Code Files
httpwwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHPSAPSAPhysicianBonusesindexhtmlredirect=HPSAPSAPhysicianBonuses01_overviewasp
552015 7 MM8942
Health Professional Shortage Areas (HPSA) Incentive
Submitting HPSA modifiers on claims that do not qualify for the HPSA incentive payment may result in Erroneous incentive payments
A referral to the Zone Program Integrity Contractor (ZPIC) for fraud and abuse investigation
bull Palmetto GBA will suppress HPSA payments for providers with four or more quarters of erroneous billing of the AQ HCPCS modifier
httpwwwpalmettogbacompalmettoprovidersnsfdocsCatProviders~Jurisdiction201120Part20B~Browse20by20Topic~Incentive20Programsopenampexpand=1ampnavmenu=Browse^by^Topic||
552015 8
Anti-Markup and Reference Laboratory Claims
Effective dates
January 1 2015 - Analysis Design and Programming
April 1 2015 - Testing and Implementation
April 6 2015 ndash Edits turned on
Anti-markup and reference laboratory claims must report
Name address and ZIP code in block 32 or electronic equivalent and
NPI of the provider who actually performed the service in block 32a or electronic equivalent
552015 9 MM8806
Documentation Requests
Effective April 1 2015
Documentation for pre-payment reviews must be submitted within 45 calendar days of request
Claims denied on day 46
552015 10
MM8583
Administrative Law Judge (ALJ) and Federal District Court Appeals
Calendar Year 2015 Amount in Controversy
ALJ requests
Filed prior to January 1 2015 - $140
Filed January 1 2015 and after - $150
Federal District Court requests
Filed prior to January 1 2015 - $1430
Filed January 1 2015 and after - $1460
552015 11
2015 Drug Testing Codes
The Centers for Medicare amp Medicaid (CMS) has announced that the 2015 drug testing CPT codes 80300 ndash 80377 will not be recognized at this time by Medicare Until further notice new HCPCs G6030 ndash G6058 should be used when reporting drug testing performed on or after January 1 2015 Claims submitted with CPT code 80300 ndash 80377 on or after January 1 2015 will be rejected as unprocessable
CMS provides details of this change in the Clinical Laboratory Fee Schedule (CLFS) Final Determinations
Document (PDF 119 KB)
Comprehensive Error Rate Testing
(CERT)
13
Partnering for Error Rate Reduction
552015 14
Evaluation and
Management Services
Laboratory Services
Minor Procedures
Advanced Imaging Services
Ambulance Services
Chiropractic Services
Lab Claim Error Impact
bull Laboratory or performing provider is responsible for working with the ordering physician to complete and document the order or intent to order all tests
bull Ordering providerrsquos revenue is not tied to completing the laboratory order when tests performed by outside lab
bull Laboratory providers struggle to obtain the needed documentation from the ordering physician
15
Corrective Action
bull Implement processes to check for signed and dated order or records to support order or intent to order for each test before rendering lab test
bull Develop relationships with ordering providers ndash Let them know what supporting documentation is
needed when ordering
ndash Request necessary documentation when it is missing
bull Check for all necessary documentation prior to submitting
bull Self audit
bull Fix known deficiencies
16
Evaluation and Management Services
Categorized into different settings depending on where the service is furnished Examples of settings include
Office or other outpatient setting
Hospital inpatient
Emergency department (ED)
Nursing facility (NF)
17
Why are Errors Occurring
bull Insufficient documentation
bull No response to documentation request
bull Illegible
bull Documentation for wrong patient or date of service submitted
bull Documentation does not support level of EM billed
bull Documentation does not adequately describe the service defined by the CPTHPCS code or HCPCS modifier billed
Signature issues - no signature (or no legible signature) and no signature log or attestation submitted
bull Does not meet key elements - medical decision making history or physical exam for billed EM service level
18
Evaluation amp Management
19
Great teaching tool
Printing Options
EM Help Center
20
EM Weekly Tips
21
CERT Tips
Review denials
Submit missing documentation directly to CERT if denial is not a medical necessity denial
Appeal medical necessity denials
‒ CERT Redetermination Request Form
Designate a CERT ldquoPoint of Contactrdquo (POC)
httpswwwcertprovidercom
552015 22
Medical Review Spotlight
23
CERT vs Palmetto GBA Medical Reviews
bull CERT
ndash Traditionally conducts post-payment reviews ndash after the claim has finalized
ndash CERT contractor selects claim sample requests records and completes the review
ndash Failure to respond to a CERT record request may result in a contact from Palmetto GBA to assist the CERT in obtaining the records
bull Palmetto GBA
ndash Medical reviews can be pre-payment or post-payment reviews
ndash Palmetto GBA selects the claim sample sends the request for medical records and completes the reviews
ndash Based on a service specific review MR may conduct a provider-specific review
24
Active Medical Reviews
552015 25
httpwwwpalmettogbacompalmettoprovidersnsfDocsCatProviders~Jurisdiction201120Part20B~Medical20Review~General~9NNJBX6701openampnavmenu=Medical^Review||||
Comparative Billing Report (CBR)
Developed by eGlobalTech (eGT) and Palmetto GBA
National CBR on use of modifier 25 by providers under family practice specialty code
CBR contains data-driven tables and graphs with an explanation of findings that compare providers billing patterns to those of their peers in the state and across the nation for claims filed with Modifier 25
httpwwwcbrinfonetcbr201409html
552015 26
Medical Review Strategy
ldquoThe Listrdquo ndash Part B
Drugs and Biologicals
Evaluation amp Management
Laboratory
Emergency Department Visits
New Providers
Hot-Spot Focus Category
27
Medical Review Strategy
Laboratory
82542 ndash Column ChromatographyMass Spectrometry
Drug testing for opioid heroin etc (costs)
Can not have standing orders for this(med necc must be specific)
Emergency Department Visits (non-signature)
99283 ndash Emergency Department Visit for the EampM of a Patient - Expanded
99284 ndash Emergency Department Visit for the EampM of a Patient - Detailed
99285 ndash Emergency Department Visit for the EampM of a Patient - Comprehensive
28 CPT only copyright 2012 American Medical Association
All rights reserved
Medical Review Strategy
New Providers
New Part B Medicare Providers
Hot-Spot Focus Category
17000 17004 17110 17311 amp 17312 Destruction of Lesions and Mohs Examination of Specimens
MR Tip MOHS has very specific guidelines Must follow guidance in codebook Pathologist amp Surgeon bill at the same time so be clear on who is billing what The most common mistake is usually no pathology report
29 CPT only copyright 2012 American Medical Association
All rights reserved
Hot Topics and Reminders
30
Enrollment Application Status
Interactive Voice Response (IVR) Unit
Use DCN number or PTAN associated with that provider enrollment application
Status information updated approximately 24 hours after each transaction
552015 31
ROADTO10ORG
552015 32
ICD-10 ndash Resources
October 1 2015
552015 34
bull httpwwwcmsgovMedicareCodingICD10indexhtmlredirect=icd10
ICD-10 - CMS
bull httpwwwpalmettogbacompalmettoicdnsfDocsCatHomeICD-10
ICD-10
Palmetto GBA
News to Use and Resources
35
GBD Blog and Twitter
Palmetto GBA is using the Going Beyond Diagnosis (GBD) blog and Twitter account to help facilitate communication on error rate reduction
httppalmgbacomgbd
BeyondDx
552015 36
Provider Enrollment Open House Available the First Tuesday of the Month
Palmetto GBArsquos Provider Enrollment Department holds an open house at our Palmetto GBA office located at 17 Technology Circle Columbia South Carolina 29203 the first Tuesday of each month This open house is for any of Palmetto GBArsquos J11 Part B providers who would like to stop by and receive answers to their questions concerning their Medicare provider enrollment applications
Self Service Tools
552015 39
wwwPalmettoGBAcomJ11B
OPS ndash New Features
Submission of documentation to satisfy an Additional Documentation Response (ADR)
Unlimited PDF attachments (each up to 40 MB for a maximum total of 150MB)
Select lsquoMedical Reviewrsquo then lsquoMR ADR Responsersquo form
552015 40
New OPS Feature
Get Your First-Level Appeal Letters Delivered Electronically
Palmetto GBA now offers an eDelivery option for receiving your redetermination decision letters electronically Imagine getting your Medicare
redetermination notices (MRNs) the same day that they are issued delivered directly to your computer You even can choose to get an email to let you know that the letter
is waiting for you
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Disclaimer
The information provided in this presentation was current as of 05042015
Any changes or new information superseding the information in this presentation is provided in articles with
publication dates after 05042015 posted on our website at
wwwPalmettoGBAcomJ11B
552015 2
CPT only copyright 2014 American Medical Association All rights reserved
The Code on Dental Procedures and Nomenclature is published in Current Dental Terminology (CDT) Copyright copy 2014 American Dental Association
(ADA) All rights reserved
Agenda
Medicare Updates and Changes
CERT
Medical Review Spotlight
Hot Topics and Reminders
News to Use and Resources
552015 3
Updates and Changes
4
Provider Enrollment Form
CMS 855R (Reassignment of Benefits) form revised
Mandated use - May 31 2015
Current or revised form accepted from the date the revised form is published through May 31 2015
Revised form available on CMS website - December 29 2014
552015 5 MMSE1432
Laboratory Services for ESRD Claims
Effective April 1 2015
Elimination of the 5050 Payment Rule for Laboratory Services on End Stage Renal Disease (ESRD) Claims
ESRD PPS requires all renal dialysis laboratory services be paid in the ESRD facility bundled payment and therefore may only be billed by the ESRD facility
552015 6 MM8957
Health Professional Shortage Area (HPSA)
CMS 2015 HPSA Zip Code Files Applicable on claims with dates of service on
or after January 1 2015 through December 31 2015 Separate Primary Care and Mental Health Zip
Code Files
httpwwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHPSAPSAPhysicianBonusesindexhtmlredirect=HPSAPSAPhysicianBonuses01_overviewasp
552015 7 MM8942
Health Professional Shortage Areas (HPSA) Incentive
Submitting HPSA modifiers on claims that do not qualify for the HPSA incentive payment may result in Erroneous incentive payments
A referral to the Zone Program Integrity Contractor (ZPIC) for fraud and abuse investigation
bull Palmetto GBA will suppress HPSA payments for providers with four or more quarters of erroneous billing of the AQ HCPCS modifier
httpwwwpalmettogbacompalmettoprovidersnsfdocsCatProviders~Jurisdiction201120Part20B~Browse20by20Topic~Incentive20Programsopenampexpand=1ampnavmenu=Browse^by^Topic||
552015 8
Anti-Markup and Reference Laboratory Claims
Effective dates
January 1 2015 - Analysis Design and Programming
April 1 2015 - Testing and Implementation
April 6 2015 ndash Edits turned on
Anti-markup and reference laboratory claims must report
Name address and ZIP code in block 32 or electronic equivalent and
NPI of the provider who actually performed the service in block 32a or electronic equivalent
552015 9 MM8806
Documentation Requests
Effective April 1 2015
Documentation for pre-payment reviews must be submitted within 45 calendar days of request
Claims denied on day 46
552015 10
MM8583
Administrative Law Judge (ALJ) and Federal District Court Appeals
Calendar Year 2015 Amount in Controversy
ALJ requests
Filed prior to January 1 2015 - $140
Filed January 1 2015 and after - $150
Federal District Court requests
Filed prior to January 1 2015 - $1430
Filed January 1 2015 and after - $1460
552015 11
2015 Drug Testing Codes
The Centers for Medicare amp Medicaid (CMS) has announced that the 2015 drug testing CPT codes 80300 ndash 80377 will not be recognized at this time by Medicare Until further notice new HCPCs G6030 ndash G6058 should be used when reporting drug testing performed on or after January 1 2015 Claims submitted with CPT code 80300 ndash 80377 on or after January 1 2015 will be rejected as unprocessable
CMS provides details of this change in the Clinical Laboratory Fee Schedule (CLFS) Final Determinations
Document (PDF 119 KB)
Comprehensive Error Rate Testing
(CERT)
13
Partnering for Error Rate Reduction
552015 14
Evaluation and
Management Services
Laboratory Services
Minor Procedures
Advanced Imaging Services
Ambulance Services
Chiropractic Services
Lab Claim Error Impact
bull Laboratory or performing provider is responsible for working with the ordering physician to complete and document the order or intent to order all tests
bull Ordering providerrsquos revenue is not tied to completing the laboratory order when tests performed by outside lab
bull Laboratory providers struggle to obtain the needed documentation from the ordering physician
15
Corrective Action
bull Implement processes to check for signed and dated order or records to support order or intent to order for each test before rendering lab test
bull Develop relationships with ordering providers ndash Let them know what supporting documentation is
needed when ordering
ndash Request necessary documentation when it is missing
bull Check for all necessary documentation prior to submitting
bull Self audit
bull Fix known deficiencies
16
Evaluation and Management Services
Categorized into different settings depending on where the service is furnished Examples of settings include
Office or other outpatient setting
Hospital inpatient
Emergency department (ED)
Nursing facility (NF)
17
Why are Errors Occurring
bull Insufficient documentation
bull No response to documentation request
bull Illegible
bull Documentation for wrong patient or date of service submitted
bull Documentation does not support level of EM billed
bull Documentation does not adequately describe the service defined by the CPTHPCS code or HCPCS modifier billed
Signature issues - no signature (or no legible signature) and no signature log or attestation submitted
bull Does not meet key elements - medical decision making history or physical exam for billed EM service level
18
Evaluation amp Management
19
Great teaching tool
Printing Options
EM Help Center
20
EM Weekly Tips
21
CERT Tips
Review denials
Submit missing documentation directly to CERT if denial is not a medical necessity denial
Appeal medical necessity denials
‒ CERT Redetermination Request Form
Designate a CERT ldquoPoint of Contactrdquo (POC)
httpswwwcertprovidercom
552015 22
Medical Review Spotlight
23
CERT vs Palmetto GBA Medical Reviews
bull CERT
ndash Traditionally conducts post-payment reviews ndash after the claim has finalized
ndash CERT contractor selects claim sample requests records and completes the review
ndash Failure to respond to a CERT record request may result in a contact from Palmetto GBA to assist the CERT in obtaining the records
bull Palmetto GBA
ndash Medical reviews can be pre-payment or post-payment reviews
ndash Palmetto GBA selects the claim sample sends the request for medical records and completes the reviews
ndash Based on a service specific review MR may conduct a provider-specific review
24
Active Medical Reviews
552015 25
httpwwwpalmettogbacompalmettoprovidersnsfDocsCatProviders~Jurisdiction201120Part20B~Medical20Review~General~9NNJBX6701openampnavmenu=Medical^Review||||
Comparative Billing Report (CBR)
Developed by eGlobalTech (eGT) and Palmetto GBA
National CBR on use of modifier 25 by providers under family practice specialty code
CBR contains data-driven tables and graphs with an explanation of findings that compare providers billing patterns to those of their peers in the state and across the nation for claims filed with Modifier 25
httpwwwcbrinfonetcbr201409html
552015 26
Medical Review Strategy
ldquoThe Listrdquo ndash Part B
Drugs and Biologicals
Evaluation amp Management
Laboratory
Emergency Department Visits
New Providers
Hot-Spot Focus Category
27
Medical Review Strategy
Laboratory
82542 ndash Column ChromatographyMass Spectrometry
Drug testing for opioid heroin etc (costs)
Can not have standing orders for this(med necc must be specific)
Emergency Department Visits (non-signature)
99283 ndash Emergency Department Visit for the EampM of a Patient - Expanded
99284 ndash Emergency Department Visit for the EampM of a Patient - Detailed
99285 ndash Emergency Department Visit for the EampM of a Patient - Comprehensive
28 CPT only copyright 2012 American Medical Association
All rights reserved
Medical Review Strategy
New Providers
New Part B Medicare Providers
Hot-Spot Focus Category
17000 17004 17110 17311 amp 17312 Destruction of Lesions and Mohs Examination of Specimens
MR Tip MOHS has very specific guidelines Must follow guidance in codebook Pathologist amp Surgeon bill at the same time so be clear on who is billing what The most common mistake is usually no pathology report
29 CPT only copyright 2012 American Medical Association
All rights reserved
Hot Topics and Reminders
30
Enrollment Application Status
Interactive Voice Response (IVR) Unit
Use DCN number or PTAN associated with that provider enrollment application
Status information updated approximately 24 hours after each transaction
552015 31
ROADTO10ORG
552015 32
ICD-10 ndash Resources
October 1 2015
552015 34
bull httpwwwcmsgovMedicareCodingICD10indexhtmlredirect=icd10
ICD-10 - CMS
bull httpwwwpalmettogbacompalmettoicdnsfDocsCatHomeICD-10
ICD-10
Palmetto GBA
News to Use and Resources
35
GBD Blog and Twitter
Palmetto GBA is using the Going Beyond Diagnosis (GBD) blog and Twitter account to help facilitate communication on error rate reduction
httppalmgbacomgbd
BeyondDx
552015 36
Provider Enrollment Open House Available the First Tuesday of the Month
Palmetto GBArsquos Provider Enrollment Department holds an open house at our Palmetto GBA office located at 17 Technology Circle Columbia South Carolina 29203 the first Tuesday of each month This open house is for any of Palmetto GBArsquos J11 Part B providers who would like to stop by and receive answers to their questions concerning their Medicare provider enrollment applications
Self Service Tools
552015 39
wwwPalmettoGBAcomJ11B
OPS ndash New Features
Submission of documentation to satisfy an Additional Documentation Response (ADR)
Unlimited PDF attachments (each up to 40 MB for a maximum total of 150MB)
Select lsquoMedical Reviewrsquo then lsquoMR ADR Responsersquo form
552015 40
New OPS Feature
Get Your First-Level Appeal Letters Delivered Electronically
Palmetto GBA now offers an eDelivery option for receiving your redetermination decision letters electronically Imagine getting your Medicare
redetermination notices (MRNs) the same day that they are issued delivered directly to your computer You even can choose to get an email to let you know that the letter
is waiting for you
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Agenda
Medicare Updates and Changes
CERT
Medical Review Spotlight
Hot Topics and Reminders
News to Use and Resources
552015 3
Updates and Changes
4
Provider Enrollment Form
CMS 855R (Reassignment of Benefits) form revised
Mandated use - May 31 2015
Current or revised form accepted from the date the revised form is published through May 31 2015
Revised form available on CMS website - December 29 2014
552015 5 MMSE1432
Laboratory Services for ESRD Claims
Effective April 1 2015
Elimination of the 5050 Payment Rule for Laboratory Services on End Stage Renal Disease (ESRD) Claims
ESRD PPS requires all renal dialysis laboratory services be paid in the ESRD facility bundled payment and therefore may only be billed by the ESRD facility
552015 6 MM8957
Health Professional Shortage Area (HPSA)
CMS 2015 HPSA Zip Code Files Applicable on claims with dates of service on
or after January 1 2015 through December 31 2015 Separate Primary Care and Mental Health Zip
Code Files
httpwwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHPSAPSAPhysicianBonusesindexhtmlredirect=HPSAPSAPhysicianBonuses01_overviewasp
552015 7 MM8942
Health Professional Shortage Areas (HPSA) Incentive
Submitting HPSA modifiers on claims that do not qualify for the HPSA incentive payment may result in Erroneous incentive payments
A referral to the Zone Program Integrity Contractor (ZPIC) for fraud and abuse investigation
bull Palmetto GBA will suppress HPSA payments for providers with four or more quarters of erroneous billing of the AQ HCPCS modifier
httpwwwpalmettogbacompalmettoprovidersnsfdocsCatProviders~Jurisdiction201120Part20B~Browse20by20Topic~Incentive20Programsopenampexpand=1ampnavmenu=Browse^by^Topic||
552015 8
Anti-Markup and Reference Laboratory Claims
Effective dates
January 1 2015 - Analysis Design and Programming
April 1 2015 - Testing and Implementation
April 6 2015 ndash Edits turned on
Anti-markup and reference laboratory claims must report
Name address and ZIP code in block 32 or electronic equivalent and
NPI of the provider who actually performed the service in block 32a or electronic equivalent
552015 9 MM8806
Documentation Requests
Effective April 1 2015
Documentation for pre-payment reviews must be submitted within 45 calendar days of request
Claims denied on day 46
552015 10
MM8583
Administrative Law Judge (ALJ) and Federal District Court Appeals
Calendar Year 2015 Amount in Controversy
ALJ requests
Filed prior to January 1 2015 - $140
Filed January 1 2015 and after - $150
Federal District Court requests
Filed prior to January 1 2015 - $1430
Filed January 1 2015 and after - $1460
552015 11
2015 Drug Testing Codes
The Centers for Medicare amp Medicaid (CMS) has announced that the 2015 drug testing CPT codes 80300 ndash 80377 will not be recognized at this time by Medicare Until further notice new HCPCs G6030 ndash G6058 should be used when reporting drug testing performed on or after January 1 2015 Claims submitted with CPT code 80300 ndash 80377 on or after January 1 2015 will be rejected as unprocessable
CMS provides details of this change in the Clinical Laboratory Fee Schedule (CLFS) Final Determinations
Document (PDF 119 KB)
Comprehensive Error Rate Testing
(CERT)
13
Partnering for Error Rate Reduction
552015 14
Evaluation and
Management Services
Laboratory Services
Minor Procedures
Advanced Imaging Services
Ambulance Services
Chiropractic Services
Lab Claim Error Impact
bull Laboratory or performing provider is responsible for working with the ordering physician to complete and document the order or intent to order all tests
bull Ordering providerrsquos revenue is not tied to completing the laboratory order when tests performed by outside lab
bull Laboratory providers struggle to obtain the needed documentation from the ordering physician
15
Corrective Action
bull Implement processes to check for signed and dated order or records to support order or intent to order for each test before rendering lab test
bull Develop relationships with ordering providers ndash Let them know what supporting documentation is
needed when ordering
ndash Request necessary documentation when it is missing
bull Check for all necessary documentation prior to submitting
bull Self audit
bull Fix known deficiencies
16
Evaluation and Management Services
Categorized into different settings depending on where the service is furnished Examples of settings include
Office or other outpatient setting
Hospital inpatient
Emergency department (ED)
Nursing facility (NF)
17
Why are Errors Occurring
bull Insufficient documentation
bull No response to documentation request
bull Illegible
bull Documentation for wrong patient or date of service submitted
bull Documentation does not support level of EM billed
bull Documentation does not adequately describe the service defined by the CPTHPCS code or HCPCS modifier billed
Signature issues - no signature (or no legible signature) and no signature log or attestation submitted
bull Does not meet key elements - medical decision making history or physical exam for billed EM service level
18
Evaluation amp Management
19
Great teaching tool
Printing Options
EM Help Center
20
EM Weekly Tips
21
CERT Tips
Review denials
Submit missing documentation directly to CERT if denial is not a medical necessity denial
Appeal medical necessity denials
‒ CERT Redetermination Request Form
Designate a CERT ldquoPoint of Contactrdquo (POC)
httpswwwcertprovidercom
552015 22
Medical Review Spotlight
23
CERT vs Palmetto GBA Medical Reviews
bull CERT
ndash Traditionally conducts post-payment reviews ndash after the claim has finalized
ndash CERT contractor selects claim sample requests records and completes the review
ndash Failure to respond to a CERT record request may result in a contact from Palmetto GBA to assist the CERT in obtaining the records
bull Palmetto GBA
ndash Medical reviews can be pre-payment or post-payment reviews
ndash Palmetto GBA selects the claim sample sends the request for medical records and completes the reviews
ndash Based on a service specific review MR may conduct a provider-specific review
24
Active Medical Reviews
552015 25
httpwwwpalmettogbacompalmettoprovidersnsfDocsCatProviders~Jurisdiction201120Part20B~Medical20Review~General~9NNJBX6701openampnavmenu=Medical^Review||||
Comparative Billing Report (CBR)
Developed by eGlobalTech (eGT) and Palmetto GBA
National CBR on use of modifier 25 by providers under family practice specialty code
CBR contains data-driven tables and graphs with an explanation of findings that compare providers billing patterns to those of their peers in the state and across the nation for claims filed with Modifier 25
httpwwwcbrinfonetcbr201409html
552015 26
Medical Review Strategy
ldquoThe Listrdquo ndash Part B
Drugs and Biologicals
Evaluation amp Management
Laboratory
Emergency Department Visits
New Providers
Hot-Spot Focus Category
27
Medical Review Strategy
Laboratory
82542 ndash Column ChromatographyMass Spectrometry
Drug testing for opioid heroin etc (costs)
Can not have standing orders for this(med necc must be specific)
Emergency Department Visits (non-signature)
99283 ndash Emergency Department Visit for the EampM of a Patient - Expanded
99284 ndash Emergency Department Visit for the EampM of a Patient - Detailed
99285 ndash Emergency Department Visit for the EampM of a Patient - Comprehensive
28 CPT only copyright 2012 American Medical Association
All rights reserved
Medical Review Strategy
New Providers
New Part B Medicare Providers
Hot-Spot Focus Category
17000 17004 17110 17311 amp 17312 Destruction of Lesions and Mohs Examination of Specimens
MR Tip MOHS has very specific guidelines Must follow guidance in codebook Pathologist amp Surgeon bill at the same time so be clear on who is billing what The most common mistake is usually no pathology report
29 CPT only copyright 2012 American Medical Association
All rights reserved
Hot Topics and Reminders
30
Enrollment Application Status
Interactive Voice Response (IVR) Unit
Use DCN number or PTAN associated with that provider enrollment application
Status information updated approximately 24 hours after each transaction
552015 31
ROADTO10ORG
552015 32
ICD-10 ndash Resources
October 1 2015
552015 34
bull httpwwwcmsgovMedicareCodingICD10indexhtmlredirect=icd10
ICD-10 - CMS
bull httpwwwpalmettogbacompalmettoicdnsfDocsCatHomeICD-10
ICD-10
Palmetto GBA
News to Use and Resources
35
GBD Blog and Twitter
Palmetto GBA is using the Going Beyond Diagnosis (GBD) blog and Twitter account to help facilitate communication on error rate reduction
httppalmgbacomgbd
BeyondDx
552015 36
Provider Enrollment Open House Available the First Tuesday of the Month
Palmetto GBArsquos Provider Enrollment Department holds an open house at our Palmetto GBA office located at 17 Technology Circle Columbia South Carolina 29203 the first Tuesday of each month This open house is for any of Palmetto GBArsquos J11 Part B providers who would like to stop by and receive answers to their questions concerning their Medicare provider enrollment applications
Self Service Tools
552015 39
wwwPalmettoGBAcomJ11B
OPS ndash New Features
Submission of documentation to satisfy an Additional Documentation Response (ADR)
Unlimited PDF attachments (each up to 40 MB for a maximum total of 150MB)
Select lsquoMedical Reviewrsquo then lsquoMR ADR Responsersquo form
552015 40
New OPS Feature
Get Your First-Level Appeal Letters Delivered Electronically
Palmetto GBA now offers an eDelivery option for receiving your redetermination decision letters electronically Imagine getting your Medicare
redetermination notices (MRNs) the same day that they are issued delivered directly to your computer You even can choose to get an email to let you know that the letter
is waiting for you
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Updates and Changes
4
Provider Enrollment Form
CMS 855R (Reassignment of Benefits) form revised
Mandated use - May 31 2015
Current or revised form accepted from the date the revised form is published through May 31 2015
Revised form available on CMS website - December 29 2014
552015 5 MMSE1432
Laboratory Services for ESRD Claims
Effective April 1 2015
Elimination of the 5050 Payment Rule for Laboratory Services on End Stage Renal Disease (ESRD) Claims
ESRD PPS requires all renal dialysis laboratory services be paid in the ESRD facility bundled payment and therefore may only be billed by the ESRD facility
552015 6 MM8957
Health Professional Shortage Area (HPSA)
CMS 2015 HPSA Zip Code Files Applicable on claims with dates of service on
or after January 1 2015 through December 31 2015 Separate Primary Care and Mental Health Zip
Code Files
httpwwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHPSAPSAPhysicianBonusesindexhtmlredirect=HPSAPSAPhysicianBonuses01_overviewasp
552015 7 MM8942
Health Professional Shortage Areas (HPSA) Incentive
Submitting HPSA modifiers on claims that do not qualify for the HPSA incentive payment may result in Erroneous incentive payments
A referral to the Zone Program Integrity Contractor (ZPIC) for fraud and abuse investigation
bull Palmetto GBA will suppress HPSA payments for providers with four or more quarters of erroneous billing of the AQ HCPCS modifier
httpwwwpalmettogbacompalmettoprovidersnsfdocsCatProviders~Jurisdiction201120Part20B~Browse20by20Topic~Incentive20Programsopenampexpand=1ampnavmenu=Browse^by^Topic||
552015 8
Anti-Markup and Reference Laboratory Claims
Effective dates
January 1 2015 - Analysis Design and Programming
April 1 2015 - Testing and Implementation
April 6 2015 ndash Edits turned on
Anti-markup and reference laboratory claims must report
Name address and ZIP code in block 32 or electronic equivalent and
NPI of the provider who actually performed the service in block 32a or electronic equivalent
552015 9 MM8806
Documentation Requests
Effective April 1 2015
Documentation for pre-payment reviews must be submitted within 45 calendar days of request
Claims denied on day 46
552015 10
MM8583
Administrative Law Judge (ALJ) and Federal District Court Appeals
Calendar Year 2015 Amount in Controversy
ALJ requests
Filed prior to January 1 2015 - $140
Filed January 1 2015 and after - $150
Federal District Court requests
Filed prior to January 1 2015 - $1430
Filed January 1 2015 and after - $1460
552015 11
2015 Drug Testing Codes
The Centers for Medicare amp Medicaid (CMS) has announced that the 2015 drug testing CPT codes 80300 ndash 80377 will not be recognized at this time by Medicare Until further notice new HCPCs G6030 ndash G6058 should be used when reporting drug testing performed on or after January 1 2015 Claims submitted with CPT code 80300 ndash 80377 on or after January 1 2015 will be rejected as unprocessable
CMS provides details of this change in the Clinical Laboratory Fee Schedule (CLFS) Final Determinations
Document (PDF 119 KB)
Comprehensive Error Rate Testing
(CERT)
13
Partnering for Error Rate Reduction
552015 14
Evaluation and
Management Services
Laboratory Services
Minor Procedures
Advanced Imaging Services
Ambulance Services
Chiropractic Services
Lab Claim Error Impact
bull Laboratory or performing provider is responsible for working with the ordering physician to complete and document the order or intent to order all tests
bull Ordering providerrsquos revenue is not tied to completing the laboratory order when tests performed by outside lab
bull Laboratory providers struggle to obtain the needed documentation from the ordering physician
15
Corrective Action
bull Implement processes to check for signed and dated order or records to support order or intent to order for each test before rendering lab test
bull Develop relationships with ordering providers ndash Let them know what supporting documentation is
needed when ordering
ndash Request necessary documentation when it is missing
bull Check for all necessary documentation prior to submitting
bull Self audit
bull Fix known deficiencies
16
Evaluation and Management Services
Categorized into different settings depending on where the service is furnished Examples of settings include
Office or other outpatient setting
Hospital inpatient
Emergency department (ED)
Nursing facility (NF)
17
Why are Errors Occurring
bull Insufficient documentation
bull No response to documentation request
bull Illegible
bull Documentation for wrong patient or date of service submitted
bull Documentation does not support level of EM billed
bull Documentation does not adequately describe the service defined by the CPTHPCS code or HCPCS modifier billed
Signature issues - no signature (or no legible signature) and no signature log or attestation submitted
bull Does not meet key elements - medical decision making history or physical exam for billed EM service level
18
Evaluation amp Management
19
Great teaching tool
Printing Options
EM Help Center
20
EM Weekly Tips
21
CERT Tips
Review denials
Submit missing documentation directly to CERT if denial is not a medical necessity denial
Appeal medical necessity denials
‒ CERT Redetermination Request Form
Designate a CERT ldquoPoint of Contactrdquo (POC)
httpswwwcertprovidercom
552015 22
Medical Review Spotlight
23
CERT vs Palmetto GBA Medical Reviews
bull CERT
ndash Traditionally conducts post-payment reviews ndash after the claim has finalized
ndash CERT contractor selects claim sample requests records and completes the review
ndash Failure to respond to a CERT record request may result in a contact from Palmetto GBA to assist the CERT in obtaining the records
bull Palmetto GBA
ndash Medical reviews can be pre-payment or post-payment reviews
ndash Palmetto GBA selects the claim sample sends the request for medical records and completes the reviews
ndash Based on a service specific review MR may conduct a provider-specific review
24
Active Medical Reviews
552015 25
httpwwwpalmettogbacompalmettoprovidersnsfDocsCatProviders~Jurisdiction201120Part20B~Medical20Review~General~9NNJBX6701openampnavmenu=Medical^Review||||
Comparative Billing Report (CBR)
Developed by eGlobalTech (eGT) and Palmetto GBA
National CBR on use of modifier 25 by providers under family practice specialty code
CBR contains data-driven tables and graphs with an explanation of findings that compare providers billing patterns to those of their peers in the state and across the nation for claims filed with Modifier 25
httpwwwcbrinfonetcbr201409html
552015 26
Medical Review Strategy
ldquoThe Listrdquo ndash Part B
Drugs and Biologicals
Evaluation amp Management
Laboratory
Emergency Department Visits
New Providers
Hot-Spot Focus Category
27
Medical Review Strategy
Laboratory
82542 ndash Column ChromatographyMass Spectrometry
Drug testing for opioid heroin etc (costs)
Can not have standing orders for this(med necc must be specific)
Emergency Department Visits (non-signature)
99283 ndash Emergency Department Visit for the EampM of a Patient - Expanded
99284 ndash Emergency Department Visit for the EampM of a Patient - Detailed
99285 ndash Emergency Department Visit for the EampM of a Patient - Comprehensive
28 CPT only copyright 2012 American Medical Association
All rights reserved
Medical Review Strategy
New Providers
New Part B Medicare Providers
Hot-Spot Focus Category
17000 17004 17110 17311 amp 17312 Destruction of Lesions and Mohs Examination of Specimens
MR Tip MOHS has very specific guidelines Must follow guidance in codebook Pathologist amp Surgeon bill at the same time so be clear on who is billing what The most common mistake is usually no pathology report
29 CPT only copyright 2012 American Medical Association
All rights reserved
Hot Topics and Reminders
30
Enrollment Application Status
Interactive Voice Response (IVR) Unit
Use DCN number or PTAN associated with that provider enrollment application
Status information updated approximately 24 hours after each transaction
552015 31
ROADTO10ORG
552015 32
ICD-10 ndash Resources
October 1 2015
552015 34
bull httpwwwcmsgovMedicareCodingICD10indexhtmlredirect=icd10
ICD-10 - CMS
bull httpwwwpalmettogbacompalmettoicdnsfDocsCatHomeICD-10
ICD-10
Palmetto GBA
News to Use and Resources
35
GBD Blog and Twitter
Palmetto GBA is using the Going Beyond Diagnosis (GBD) blog and Twitter account to help facilitate communication on error rate reduction
httppalmgbacomgbd
BeyondDx
552015 36
Provider Enrollment Open House Available the First Tuesday of the Month
Palmetto GBArsquos Provider Enrollment Department holds an open house at our Palmetto GBA office located at 17 Technology Circle Columbia South Carolina 29203 the first Tuesday of each month This open house is for any of Palmetto GBArsquos J11 Part B providers who would like to stop by and receive answers to their questions concerning their Medicare provider enrollment applications
Self Service Tools
552015 39
wwwPalmettoGBAcomJ11B
OPS ndash New Features
Submission of documentation to satisfy an Additional Documentation Response (ADR)
Unlimited PDF attachments (each up to 40 MB for a maximum total of 150MB)
Select lsquoMedical Reviewrsquo then lsquoMR ADR Responsersquo form
552015 40
New OPS Feature
Get Your First-Level Appeal Letters Delivered Electronically
Palmetto GBA now offers an eDelivery option for receiving your redetermination decision letters electronically Imagine getting your Medicare
redetermination notices (MRNs) the same day that they are issued delivered directly to your computer You even can choose to get an email to let you know that the letter
is waiting for you
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Provider Enrollment Form
CMS 855R (Reassignment of Benefits) form revised
Mandated use - May 31 2015
Current or revised form accepted from the date the revised form is published through May 31 2015
Revised form available on CMS website - December 29 2014
552015 5 MMSE1432
Laboratory Services for ESRD Claims
Effective April 1 2015
Elimination of the 5050 Payment Rule for Laboratory Services on End Stage Renal Disease (ESRD) Claims
ESRD PPS requires all renal dialysis laboratory services be paid in the ESRD facility bundled payment and therefore may only be billed by the ESRD facility
552015 6 MM8957
Health Professional Shortage Area (HPSA)
CMS 2015 HPSA Zip Code Files Applicable on claims with dates of service on
or after January 1 2015 through December 31 2015 Separate Primary Care and Mental Health Zip
Code Files
httpwwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHPSAPSAPhysicianBonusesindexhtmlredirect=HPSAPSAPhysicianBonuses01_overviewasp
552015 7 MM8942
Health Professional Shortage Areas (HPSA) Incentive
Submitting HPSA modifiers on claims that do not qualify for the HPSA incentive payment may result in Erroneous incentive payments
A referral to the Zone Program Integrity Contractor (ZPIC) for fraud and abuse investigation
bull Palmetto GBA will suppress HPSA payments for providers with four or more quarters of erroneous billing of the AQ HCPCS modifier
httpwwwpalmettogbacompalmettoprovidersnsfdocsCatProviders~Jurisdiction201120Part20B~Browse20by20Topic~Incentive20Programsopenampexpand=1ampnavmenu=Browse^by^Topic||
552015 8
Anti-Markup and Reference Laboratory Claims
Effective dates
January 1 2015 - Analysis Design and Programming
April 1 2015 - Testing and Implementation
April 6 2015 ndash Edits turned on
Anti-markup and reference laboratory claims must report
Name address and ZIP code in block 32 or electronic equivalent and
NPI of the provider who actually performed the service in block 32a or electronic equivalent
552015 9 MM8806
Documentation Requests
Effective April 1 2015
Documentation for pre-payment reviews must be submitted within 45 calendar days of request
Claims denied on day 46
552015 10
MM8583
Administrative Law Judge (ALJ) and Federal District Court Appeals
Calendar Year 2015 Amount in Controversy
ALJ requests
Filed prior to January 1 2015 - $140
Filed January 1 2015 and after - $150
Federal District Court requests
Filed prior to January 1 2015 - $1430
Filed January 1 2015 and after - $1460
552015 11
2015 Drug Testing Codes
The Centers for Medicare amp Medicaid (CMS) has announced that the 2015 drug testing CPT codes 80300 ndash 80377 will not be recognized at this time by Medicare Until further notice new HCPCs G6030 ndash G6058 should be used when reporting drug testing performed on or after January 1 2015 Claims submitted with CPT code 80300 ndash 80377 on or after January 1 2015 will be rejected as unprocessable
CMS provides details of this change in the Clinical Laboratory Fee Schedule (CLFS) Final Determinations
Document (PDF 119 KB)
Comprehensive Error Rate Testing
(CERT)
13
Partnering for Error Rate Reduction
552015 14
Evaluation and
Management Services
Laboratory Services
Minor Procedures
Advanced Imaging Services
Ambulance Services
Chiropractic Services
Lab Claim Error Impact
bull Laboratory or performing provider is responsible for working with the ordering physician to complete and document the order or intent to order all tests
bull Ordering providerrsquos revenue is not tied to completing the laboratory order when tests performed by outside lab
bull Laboratory providers struggle to obtain the needed documentation from the ordering physician
15
Corrective Action
bull Implement processes to check for signed and dated order or records to support order or intent to order for each test before rendering lab test
bull Develop relationships with ordering providers ndash Let them know what supporting documentation is
needed when ordering
ndash Request necessary documentation when it is missing
bull Check for all necessary documentation prior to submitting
bull Self audit
bull Fix known deficiencies
16
Evaluation and Management Services
Categorized into different settings depending on where the service is furnished Examples of settings include
Office or other outpatient setting
Hospital inpatient
Emergency department (ED)
Nursing facility (NF)
17
Why are Errors Occurring
bull Insufficient documentation
bull No response to documentation request
bull Illegible
bull Documentation for wrong patient or date of service submitted
bull Documentation does not support level of EM billed
bull Documentation does not adequately describe the service defined by the CPTHPCS code or HCPCS modifier billed
Signature issues - no signature (or no legible signature) and no signature log or attestation submitted
bull Does not meet key elements - medical decision making history or physical exam for billed EM service level
18
Evaluation amp Management
19
Great teaching tool
Printing Options
EM Help Center
20
EM Weekly Tips
21
CERT Tips
Review denials
Submit missing documentation directly to CERT if denial is not a medical necessity denial
Appeal medical necessity denials
‒ CERT Redetermination Request Form
Designate a CERT ldquoPoint of Contactrdquo (POC)
httpswwwcertprovidercom
552015 22
Medical Review Spotlight
23
CERT vs Palmetto GBA Medical Reviews
bull CERT
ndash Traditionally conducts post-payment reviews ndash after the claim has finalized
ndash CERT contractor selects claim sample requests records and completes the review
ndash Failure to respond to a CERT record request may result in a contact from Palmetto GBA to assist the CERT in obtaining the records
bull Palmetto GBA
ndash Medical reviews can be pre-payment or post-payment reviews
ndash Palmetto GBA selects the claim sample sends the request for medical records and completes the reviews
ndash Based on a service specific review MR may conduct a provider-specific review
24
Active Medical Reviews
552015 25
httpwwwpalmettogbacompalmettoprovidersnsfDocsCatProviders~Jurisdiction201120Part20B~Medical20Review~General~9NNJBX6701openampnavmenu=Medical^Review||||
Comparative Billing Report (CBR)
Developed by eGlobalTech (eGT) and Palmetto GBA
National CBR on use of modifier 25 by providers under family practice specialty code
CBR contains data-driven tables and graphs with an explanation of findings that compare providers billing patterns to those of their peers in the state and across the nation for claims filed with Modifier 25
httpwwwcbrinfonetcbr201409html
552015 26
Medical Review Strategy
ldquoThe Listrdquo ndash Part B
Drugs and Biologicals
Evaluation amp Management
Laboratory
Emergency Department Visits
New Providers
Hot-Spot Focus Category
27
Medical Review Strategy
Laboratory
82542 ndash Column ChromatographyMass Spectrometry
Drug testing for opioid heroin etc (costs)
Can not have standing orders for this(med necc must be specific)
Emergency Department Visits (non-signature)
99283 ndash Emergency Department Visit for the EampM of a Patient - Expanded
99284 ndash Emergency Department Visit for the EampM of a Patient - Detailed
99285 ndash Emergency Department Visit for the EampM of a Patient - Comprehensive
28 CPT only copyright 2012 American Medical Association
All rights reserved
Medical Review Strategy
New Providers
New Part B Medicare Providers
Hot-Spot Focus Category
17000 17004 17110 17311 amp 17312 Destruction of Lesions and Mohs Examination of Specimens
MR Tip MOHS has very specific guidelines Must follow guidance in codebook Pathologist amp Surgeon bill at the same time so be clear on who is billing what The most common mistake is usually no pathology report
29 CPT only copyright 2012 American Medical Association
All rights reserved
Hot Topics and Reminders
30
Enrollment Application Status
Interactive Voice Response (IVR) Unit
Use DCN number or PTAN associated with that provider enrollment application
Status information updated approximately 24 hours after each transaction
552015 31
ROADTO10ORG
552015 32
ICD-10 ndash Resources
October 1 2015
552015 34
bull httpwwwcmsgovMedicareCodingICD10indexhtmlredirect=icd10
ICD-10 - CMS
bull httpwwwpalmettogbacompalmettoicdnsfDocsCatHomeICD-10
ICD-10
Palmetto GBA
News to Use and Resources
35
GBD Blog and Twitter
Palmetto GBA is using the Going Beyond Diagnosis (GBD) blog and Twitter account to help facilitate communication on error rate reduction
httppalmgbacomgbd
BeyondDx
552015 36
Provider Enrollment Open House Available the First Tuesday of the Month
Palmetto GBArsquos Provider Enrollment Department holds an open house at our Palmetto GBA office located at 17 Technology Circle Columbia South Carolina 29203 the first Tuesday of each month This open house is for any of Palmetto GBArsquos J11 Part B providers who would like to stop by and receive answers to their questions concerning their Medicare provider enrollment applications
Self Service Tools
552015 39
wwwPalmettoGBAcomJ11B
OPS ndash New Features
Submission of documentation to satisfy an Additional Documentation Response (ADR)
Unlimited PDF attachments (each up to 40 MB for a maximum total of 150MB)
Select lsquoMedical Reviewrsquo then lsquoMR ADR Responsersquo form
552015 40
New OPS Feature
Get Your First-Level Appeal Letters Delivered Electronically
Palmetto GBA now offers an eDelivery option for receiving your redetermination decision letters electronically Imagine getting your Medicare
redetermination notices (MRNs) the same day that they are issued delivered directly to your computer You even can choose to get an email to let you know that the letter
is waiting for you
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Laboratory Services for ESRD Claims
Effective April 1 2015
Elimination of the 5050 Payment Rule for Laboratory Services on End Stage Renal Disease (ESRD) Claims
ESRD PPS requires all renal dialysis laboratory services be paid in the ESRD facility bundled payment and therefore may only be billed by the ESRD facility
552015 6 MM8957
Health Professional Shortage Area (HPSA)
CMS 2015 HPSA Zip Code Files Applicable on claims with dates of service on
or after January 1 2015 through December 31 2015 Separate Primary Care and Mental Health Zip
Code Files
httpwwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHPSAPSAPhysicianBonusesindexhtmlredirect=HPSAPSAPhysicianBonuses01_overviewasp
552015 7 MM8942
Health Professional Shortage Areas (HPSA) Incentive
Submitting HPSA modifiers on claims that do not qualify for the HPSA incentive payment may result in Erroneous incentive payments
A referral to the Zone Program Integrity Contractor (ZPIC) for fraud and abuse investigation
bull Palmetto GBA will suppress HPSA payments for providers with four or more quarters of erroneous billing of the AQ HCPCS modifier
httpwwwpalmettogbacompalmettoprovidersnsfdocsCatProviders~Jurisdiction201120Part20B~Browse20by20Topic~Incentive20Programsopenampexpand=1ampnavmenu=Browse^by^Topic||
552015 8
Anti-Markup and Reference Laboratory Claims
Effective dates
January 1 2015 - Analysis Design and Programming
April 1 2015 - Testing and Implementation
April 6 2015 ndash Edits turned on
Anti-markup and reference laboratory claims must report
Name address and ZIP code in block 32 or electronic equivalent and
NPI of the provider who actually performed the service in block 32a or electronic equivalent
552015 9 MM8806
Documentation Requests
Effective April 1 2015
Documentation for pre-payment reviews must be submitted within 45 calendar days of request
Claims denied on day 46
552015 10
MM8583
Administrative Law Judge (ALJ) and Federal District Court Appeals
Calendar Year 2015 Amount in Controversy
ALJ requests
Filed prior to January 1 2015 - $140
Filed January 1 2015 and after - $150
Federal District Court requests
Filed prior to January 1 2015 - $1430
Filed January 1 2015 and after - $1460
552015 11
2015 Drug Testing Codes
The Centers for Medicare amp Medicaid (CMS) has announced that the 2015 drug testing CPT codes 80300 ndash 80377 will not be recognized at this time by Medicare Until further notice new HCPCs G6030 ndash G6058 should be used when reporting drug testing performed on or after January 1 2015 Claims submitted with CPT code 80300 ndash 80377 on or after January 1 2015 will be rejected as unprocessable
CMS provides details of this change in the Clinical Laboratory Fee Schedule (CLFS) Final Determinations
Document (PDF 119 KB)
Comprehensive Error Rate Testing
(CERT)
13
Partnering for Error Rate Reduction
552015 14
Evaluation and
Management Services
Laboratory Services
Minor Procedures
Advanced Imaging Services
Ambulance Services
Chiropractic Services
Lab Claim Error Impact
bull Laboratory or performing provider is responsible for working with the ordering physician to complete and document the order or intent to order all tests
bull Ordering providerrsquos revenue is not tied to completing the laboratory order when tests performed by outside lab
bull Laboratory providers struggle to obtain the needed documentation from the ordering physician
15
Corrective Action
bull Implement processes to check for signed and dated order or records to support order or intent to order for each test before rendering lab test
bull Develop relationships with ordering providers ndash Let them know what supporting documentation is
needed when ordering
ndash Request necessary documentation when it is missing
bull Check for all necessary documentation prior to submitting
bull Self audit
bull Fix known deficiencies
16
Evaluation and Management Services
Categorized into different settings depending on where the service is furnished Examples of settings include
Office or other outpatient setting
Hospital inpatient
Emergency department (ED)
Nursing facility (NF)
17
Why are Errors Occurring
bull Insufficient documentation
bull No response to documentation request
bull Illegible
bull Documentation for wrong patient or date of service submitted
bull Documentation does not support level of EM billed
bull Documentation does not adequately describe the service defined by the CPTHPCS code or HCPCS modifier billed
Signature issues - no signature (or no legible signature) and no signature log or attestation submitted
bull Does not meet key elements - medical decision making history or physical exam for billed EM service level
18
Evaluation amp Management
19
Great teaching tool
Printing Options
EM Help Center
20
EM Weekly Tips
21
CERT Tips
Review denials
Submit missing documentation directly to CERT if denial is not a medical necessity denial
Appeal medical necessity denials
‒ CERT Redetermination Request Form
Designate a CERT ldquoPoint of Contactrdquo (POC)
httpswwwcertprovidercom
552015 22
Medical Review Spotlight
23
CERT vs Palmetto GBA Medical Reviews
bull CERT
ndash Traditionally conducts post-payment reviews ndash after the claim has finalized
ndash CERT contractor selects claim sample requests records and completes the review
ndash Failure to respond to a CERT record request may result in a contact from Palmetto GBA to assist the CERT in obtaining the records
bull Palmetto GBA
ndash Medical reviews can be pre-payment or post-payment reviews
ndash Palmetto GBA selects the claim sample sends the request for medical records and completes the reviews
ndash Based on a service specific review MR may conduct a provider-specific review
24
Active Medical Reviews
552015 25
httpwwwpalmettogbacompalmettoprovidersnsfDocsCatProviders~Jurisdiction201120Part20B~Medical20Review~General~9NNJBX6701openampnavmenu=Medical^Review||||
Comparative Billing Report (CBR)
Developed by eGlobalTech (eGT) and Palmetto GBA
National CBR on use of modifier 25 by providers under family practice specialty code
CBR contains data-driven tables and graphs with an explanation of findings that compare providers billing patterns to those of their peers in the state and across the nation for claims filed with Modifier 25
httpwwwcbrinfonetcbr201409html
552015 26
Medical Review Strategy
ldquoThe Listrdquo ndash Part B
Drugs and Biologicals
Evaluation amp Management
Laboratory
Emergency Department Visits
New Providers
Hot-Spot Focus Category
27
Medical Review Strategy
Laboratory
82542 ndash Column ChromatographyMass Spectrometry
Drug testing for opioid heroin etc (costs)
Can not have standing orders for this(med necc must be specific)
Emergency Department Visits (non-signature)
99283 ndash Emergency Department Visit for the EampM of a Patient - Expanded
99284 ndash Emergency Department Visit for the EampM of a Patient - Detailed
99285 ndash Emergency Department Visit for the EampM of a Patient - Comprehensive
28 CPT only copyright 2012 American Medical Association
All rights reserved
Medical Review Strategy
New Providers
New Part B Medicare Providers
Hot-Spot Focus Category
17000 17004 17110 17311 amp 17312 Destruction of Lesions and Mohs Examination of Specimens
MR Tip MOHS has very specific guidelines Must follow guidance in codebook Pathologist amp Surgeon bill at the same time so be clear on who is billing what The most common mistake is usually no pathology report
29 CPT only copyright 2012 American Medical Association
All rights reserved
Hot Topics and Reminders
30
Enrollment Application Status
Interactive Voice Response (IVR) Unit
Use DCN number or PTAN associated with that provider enrollment application
Status information updated approximately 24 hours after each transaction
552015 31
ROADTO10ORG
552015 32
ICD-10 ndash Resources
October 1 2015
552015 34
bull httpwwwcmsgovMedicareCodingICD10indexhtmlredirect=icd10
ICD-10 - CMS
bull httpwwwpalmettogbacompalmettoicdnsfDocsCatHomeICD-10
ICD-10
Palmetto GBA
News to Use and Resources
35
GBD Blog and Twitter
Palmetto GBA is using the Going Beyond Diagnosis (GBD) blog and Twitter account to help facilitate communication on error rate reduction
httppalmgbacomgbd
BeyondDx
552015 36
Provider Enrollment Open House Available the First Tuesday of the Month
Palmetto GBArsquos Provider Enrollment Department holds an open house at our Palmetto GBA office located at 17 Technology Circle Columbia South Carolina 29203 the first Tuesday of each month This open house is for any of Palmetto GBArsquos J11 Part B providers who would like to stop by and receive answers to their questions concerning their Medicare provider enrollment applications
Self Service Tools
552015 39
wwwPalmettoGBAcomJ11B
OPS ndash New Features
Submission of documentation to satisfy an Additional Documentation Response (ADR)
Unlimited PDF attachments (each up to 40 MB for a maximum total of 150MB)
Select lsquoMedical Reviewrsquo then lsquoMR ADR Responsersquo form
552015 40
New OPS Feature
Get Your First-Level Appeal Letters Delivered Electronically
Palmetto GBA now offers an eDelivery option for receiving your redetermination decision letters electronically Imagine getting your Medicare
redetermination notices (MRNs) the same day that they are issued delivered directly to your computer You even can choose to get an email to let you know that the letter
is waiting for you
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Health Professional Shortage Area (HPSA)
CMS 2015 HPSA Zip Code Files Applicable on claims with dates of service on
or after January 1 2015 through December 31 2015 Separate Primary Care and Mental Health Zip
Code Files
httpwwwcmsgovMedicareMedicare-Fee-for-Service-PaymentHPSAPSAPhysicianBonusesindexhtmlredirect=HPSAPSAPhysicianBonuses01_overviewasp
552015 7 MM8942
Health Professional Shortage Areas (HPSA) Incentive
Submitting HPSA modifiers on claims that do not qualify for the HPSA incentive payment may result in Erroneous incentive payments
A referral to the Zone Program Integrity Contractor (ZPIC) for fraud and abuse investigation
bull Palmetto GBA will suppress HPSA payments for providers with four or more quarters of erroneous billing of the AQ HCPCS modifier
httpwwwpalmettogbacompalmettoprovidersnsfdocsCatProviders~Jurisdiction201120Part20B~Browse20by20Topic~Incentive20Programsopenampexpand=1ampnavmenu=Browse^by^Topic||
552015 8
Anti-Markup and Reference Laboratory Claims
Effective dates
January 1 2015 - Analysis Design and Programming
April 1 2015 - Testing and Implementation
April 6 2015 ndash Edits turned on
Anti-markup and reference laboratory claims must report
Name address and ZIP code in block 32 or electronic equivalent and
NPI of the provider who actually performed the service in block 32a or electronic equivalent
552015 9 MM8806
Documentation Requests
Effective April 1 2015
Documentation for pre-payment reviews must be submitted within 45 calendar days of request
Claims denied on day 46
552015 10
MM8583
Administrative Law Judge (ALJ) and Federal District Court Appeals
Calendar Year 2015 Amount in Controversy
ALJ requests
Filed prior to January 1 2015 - $140
Filed January 1 2015 and after - $150
Federal District Court requests
Filed prior to January 1 2015 - $1430
Filed January 1 2015 and after - $1460
552015 11
2015 Drug Testing Codes
The Centers for Medicare amp Medicaid (CMS) has announced that the 2015 drug testing CPT codes 80300 ndash 80377 will not be recognized at this time by Medicare Until further notice new HCPCs G6030 ndash G6058 should be used when reporting drug testing performed on or after January 1 2015 Claims submitted with CPT code 80300 ndash 80377 on or after January 1 2015 will be rejected as unprocessable
CMS provides details of this change in the Clinical Laboratory Fee Schedule (CLFS) Final Determinations
Document (PDF 119 KB)
Comprehensive Error Rate Testing
(CERT)
13
Partnering for Error Rate Reduction
552015 14
Evaluation and
Management Services
Laboratory Services
Minor Procedures
Advanced Imaging Services
Ambulance Services
Chiropractic Services
Lab Claim Error Impact
bull Laboratory or performing provider is responsible for working with the ordering physician to complete and document the order or intent to order all tests
bull Ordering providerrsquos revenue is not tied to completing the laboratory order when tests performed by outside lab
bull Laboratory providers struggle to obtain the needed documentation from the ordering physician
15
Corrective Action
bull Implement processes to check for signed and dated order or records to support order or intent to order for each test before rendering lab test
bull Develop relationships with ordering providers ndash Let them know what supporting documentation is
needed when ordering
ndash Request necessary documentation when it is missing
bull Check for all necessary documentation prior to submitting
bull Self audit
bull Fix known deficiencies
16
Evaluation and Management Services
Categorized into different settings depending on where the service is furnished Examples of settings include
Office or other outpatient setting
Hospital inpatient
Emergency department (ED)
Nursing facility (NF)
17
Why are Errors Occurring
bull Insufficient documentation
bull No response to documentation request
bull Illegible
bull Documentation for wrong patient or date of service submitted
bull Documentation does not support level of EM billed
bull Documentation does not adequately describe the service defined by the CPTHPCS code or HCPCS modifier billed
Signature issues - no signature (or no legible signature) and no signature log or attestation submitted
bull Does not meet key elements - medical decision making history or physical exam for billed EM service level
18
Evaluation amp Management
19
Great teaching tool
Printing Options
EM Help Center
20
EM Weekly Tips
21
CERT Tips
Review denials
Submit missing documentation directly to CERT if denial is not a medical necessity denial
Appeal medical necessity denials
‒ CERT Redetermination Request Form
Designate a CERT ldquoPoint of Contactrdquo (POC)
httpswwwcertprovidercom
552015 22
Medical Review Spotlight
23
CERT vs Palmetto GBA Medical Reviews
bull CERT
ndash Traditionally conducts post-payment reviews ndash after the claim has finalized
ndash CERT contractor selects claim sample requests records and completes the review
ndash Failure to respond to a CERT record request may result in a contact from Palmetto GBA to assist the CERT in obtaining the records
bull Palmetto GBA
ndash Medical reviews can be pre-payment or post-payment reviews
ndash Palmetto GBA selects the claim sample sends the request for medical records and completes the reviews
ndash Based on a service specific review MR may conduct a provider-specific review
24
Active Medical Reviews
552015 25
httpwwwpalmettogbacompalmettoprovidersnsfDocsCatProviders~Jurisdiction201120Part20B~Medical20Review~General~9NNJBX6701openampnavmenu=Medical^Review||||
Comparative Billing Report (CBR)
Developed by eGlobalTech (eGT) and Palmetto GBA
National CBR on use of modifier 25 by providers under family practice specialty code
CBR contains data-driven tables and graphs with an explanation of findings that compare providers billing patterns to those of their peers in the state and across the nation for claims filed with Modifier 25
httpwwwcbrinfonetcbr201409html
552015 26
Medical Review Strategy
ldquoThe Listrdquo ndash Part B
Drugs and Biologicals
Evaluation amp Management
Laboratory
Emergency Department Visits
New Providers
Hot-Spot Focus Category
27
Medical Review Strategy
Laboratory
82542 ndash Column ChromatographyMass Spectrometry
Drug testing for opioid heroin etc (costs)
Can not have standing orders for this(med necc must be specific)
Emergency Department Visits (non-signature)
99283 ndash Emergency Department Visit for the EampM of a Patient - Expanded
99284 ndash Emergency Department Visit for the EampM of a Patient - Detailed
99285 ndash Emergency Department Visit for the EampM of a Patient - Comprehensive
28 CPT only copyright 2012 American Medical Association
All rights reserved
Medical Review Strategy
New Providers
New Part B Medicare Providers
Hot-Spot Focus Category
17000 17004 17110 17311 amp 17312 Destruction of Lesions and Mohs Examination of Specimens
MR Tip MOHS has very specific guidelines Must follow guidance in codebook Pathologist amp Surgeon bill at the same time so be clear on who is billing what The most common mistake is usually no pathology report
29 CPT only copyright 2012 American Medical Association
All rights reserved
Hot Topics and Reminders
30
Enrollment Application Status
Interactive Voice Response (IVR) Unit
Use DCN number or PTAN associated with that provider enrollment application
Status information updated approximately 24 hours after each transaction
552015 31
ROADTO10ORG
552015 32
ICD-10 ndash Resources
October 1 2015
552015 34
bull httpwwwcmsgovMedicareCodingICD10indexhtmlredirect=icd10
ICD-10 - CMS
bull httpwwwpalmettogbacompalmettoicdnsfDocsCatHomeICD-10
ICD-10
Palmetto GBA
News to Use and Resources
35
GBD Blog and Twitter
Palmetto GBA is using the Going Beyond Diagnosis (GBD) blog and Twitter account to help facilitate communication on error rate reduction
httppalmgbacomgbd
BeyondDx
552015 36
Provider Enrollment Open House Available the First Tuesday of the Month
Palmetto GBArsquos Provider Enrollment Department holds an open house at our Palmetto GBA office located at 17 Technology Circle Columbia South Carolina 29203 the first Tuesday of each month This open house is for any of Palmetto GBArsquos J11 Part B providers who would like to stop by and receive answers to their questions concerning their Medicare provider enrollment applications
Self Service Tools
552015 39
wwwPalmettoGBAcomJ11B
OPS ndash New Features
Submission of documentation to satisfy an Additional Documentation Response (ADR)
Unlimited PDF attachments (each up to 40 MB for a maximum total of 150MB)
Select lsquoMedical Reviewrsquo then lsquoMR ADR Responsersquo form
552015 40
New OPS Feature
Get Your First-Level Appeal Letters Delivered Electronically
Palmetto GBA now offers an eDelivery option for receiving your redetermination decision letters electronically Imagine getting your Medicare
redetermination notices (MRNs) the same day that they are issued delivered directly to your computer You even can choose to get an email to let you know that the letter
is waiting for you
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Health Professional Shortage Areas (HPSA) Incentive
Submitting HPSA modifiers on claims that do not qualify for the HPSA incentive payment may result in Erroneous incentive payments
A referral to the Zone Program Integrity Contractor (ZPIC) for fraud and abuse investigation
bull Palmetto GBA will suppress HPSA payments for providers with four or more quarters of erroneous billing of the AQ HCPCS modifier
httpwwwpalmettogbacompalmettoprovidersnsfdocsCatProviders~Jurisdiction201120Part20B~Browse20by20Topic~Incentive20Programsopenampexpand=1ampnavmenu=Browse^by^Topic||
552015 8
Anti-Markup and Reference Laboratory Claims
Effective dates
January 1 2015 - Analysis Design and Programming
April 1 2015 - Testing and Implementation
April 6 2015 ndash Edits turned on
Anti-markup and reference laboratory claims must report
Name address and ZIP code in block 32 or electronic equivalent and
NPI of the provider who actually performed the service in block 32a or electronic equivalent
552015 9 MM8806
Documentation Requests
Effective April 1 2015
Documentation for pre-payment reviews must be submitted within 45 calendar days of request
Claims denied on day 46
552015 10
MM8583
Administrative Law Judge (ALJ) and Federal District Court Appeals
Calendar Year 2015 Amount in Controversy
ALJ requests
Filed prior to January 1 2015 - $140
Filed January 1 2015 and after - $150
Federal District Court requests
Filed prior to January 1 2015 - $1430
Filed January 1 2015 and after - $1460
552015 11
2015 Drug Testing Codes
The Centers for Medicare amp Medicaid (CMS) has announced that the 2015 drug testing CPT codes 80300 ndash 80377 will not be recognized at this time by Medicare Until further notice new HCPCs G6030 ndash G6058 should be used when reporting drug testing performed on or after January 1 2015 Claims submitted with CPT code 80300 ndash 80377 on or after January 1 2015 will be rejected as unprocessable
CMS provides details of this change in the Clinical Laboratory Fee Schedule (CLFS) Final Determinations
Document (PDF 119 KB)
Comprehensive Error Rate Testing
(CERT)
13
Partnering for Error Rate Reduction
552015 14
Evaluation and
Management Services
Laboratory Services
Minor Procedures
Advanced Imaging Services
Ambulance Services
Chiropractic Services
Lab Claim Error Impact
bull Laboratory or performing provider is responsible for working with the ordering physician to complete and document the order or intent to order all tests
bull Ordering providerrsquos revenue is not tied to completing the laboratory order when tests performed by outside lab
bull Laboratory providers struggle to obtain the needed documentation from the ordering physician
15
Corrective Action
bull Implement processes to check for signed and dated order or records to support order or intent to order for each test before rendering lab test
bull Develop relationships with ordering providers ndash Let them know what supporting documentation is
needed when ordering
ndash Request necessary documentation when it is missing
bull Check for all necessary documentation prior to submitting
bull Self audit
bull Fix known deficiencies
16
Evaluation and Management Services
Categorized into different settings depending on where the service is furnished Examples of settings include
Office or other outpatient setting
Hospital inpatient
Emergency department (ED)
Nursing facility (NF)
17
Why are Errors Occurring
bull Insufficient documentation
bull No response to documentation request
bull Illegible
bull Documentation for wrong patient or date of service submitted
bull Documentation does not support level of EM billed
bull Documentation does not adequately describe the service defined by the CPTHPCS code or HCPCS modifier billed
Signature issues - no signature (or no legible signature) and no signature log or attestation submitted
bull Does not meet key elements - medical decision making history or physical exam for billed EM service level
18
Evaluation amp Management
19
Great teaching tool
Printing Options
EM Help Center
20
EM Weekly Tips
21
CERT Tips
Review denials
Submit missing documentation directly to CERT if denial is not a medical necessity denial
Appeal medical necessity denials
‒ CERT Redetermination Request Form
Designate a CERT ldquoPoint of Contactrdquo (POC)
httpswwwcertprovidercom
552015 22
Medical Review Spotlight
23
CERT vs Palmetto GBA Medical Reviews
bull CERT
ndash Traditionally conducts post-payment reviews ndash after the claim has finalized
ndash CERT contractor selects claim sample requests records and completes the review
ndash Failure to respond to a CERT record request may result in a contact from Palmetto GBA to assist the CERT in obtaining the records
bull Palmetto GBA
ndash Medical reviews can be pre-payment or post-payment reviews
ndash Palmetto GBA selects the claim sample sends the request for medical records and completes the reviews
ndash Based on a service specific review MR may conduct a provider-specific review
24
Active Medical Reviews
552015 25
httpwwwpalmettogbacompalmettoprovidersnsfDocsCatProviders~Jurisdiction201120Part20B~Medical20Review~General~9NNJBX6701openampnavmenu=Medical^Review||||
Comparative Billing Report (CBR)
Developed by eGlobalTech (eGT) and Palmetto GBA
National CBR on use of modifier 25 by providers under family practice specialty code
CBR contains data-driven tables and graphs with an explanation of findings that compare providers billing patterns to those of their peers in the state and across the nation for claims filed with Modifier 25
httpwwwcbrinfonetcbr201409html
552015 26
Medical Review Strategy
ldquoThe Listrdquo ndash Part B
Drugs and Biologicals
Evaluation amp Management
Laboratory
Emergency Department Visits
New Providers
Hot-Spot Focus Category
27
Medical Review Strategy
Laboratory
82542 ndash Column ChromatographyMass Spectrometry
Drug testing for opioid heroin etc (costs)
Can not have standing orders for this(med necc must be specific)
Emergency Department Visits (non-signature)
99283 ndash Emergency Department Visit for the EampM of a Patient - Expanded
99284 ndash Emergency Department Visit for the EampM of a Patient - Detailed
99285 ndash Emergency Department Visit for the EampM of a Patient - Comprehensive
28 CPT only copyright 2012 American Medical Association
All rights reserved
Medical Review Strategy
New Providers
New Part B Medicare Providers
Hot-Spot Focus Category
17000 17004 17110 17311 amp 17312 Destruction of Lesions and Mohs Examination of Specimens
MR Tip MOHS has very specific guidelines Must follow guidance in codebook Pathologist amp Surgeon bill at the same time so be clear on who is billing what The most common mistake is usually no pathology report
29 CPT only copyright 2012 American Medical Association
All rights reserved
Hot Topics and Reminders
30
Enrollment Application Status
Interactive Voice Response (IVR) Unit
Use DCN number or PTAN associated with that provider enrollment application
Status information updated approximately 24 hours after each transaction
552015 31
ROADTO10ORG
552015 32
ICD-10 ndash Resources
October 1 2015
552015 34
bull httpwwwcmsgovMedicareCodingICD10indexhtmlredirect=icd10
ICD-10 - CMS
bull httpwwwpalmettogbacompalmettoicdnsfDocsCatHomeICD-10
ICD-10
Palmetto GBA
News to Use and Resources
35
GBD Blog and Twitter
Palmetto GBA is using the Going Beyond Diagnosis (GBD) blog and Twitter account to help facilitate communication on error rate reduction
httppalmgbacomgbd
BeyondDx
552015 36
Provider Enrollment Open House Available the First Tuesday of the Month
Palmetto GBArsquos Provider Enrollment Department holds an open house at our Palmetto GBA office located at 17 Technology Circle Columbia South Carolina 29203 the first Tuesday of each month This open house is for any of Palmetto GBArsquos J11 Part B providers who would like to stop by and receive answers to their questions concerning their Medicare provider enrollment applications
Self Service Tools
552015 39
wwwPalmettoGBAcomJ11B
OPS ndash New Features
Submission of documentation to satisfy an Additional Documentation Response (ADR)
Unlimited PDF attachments (each up to 40 MB for a maximum total of 150MB)
Select lsquoMedical Reviewrsquo then lsquoMR ADR Responsersquo form
552015 40
New OPS Feature
Get Your First-Level Appeal Letters Delivered Electronically
Palmetto GBA now offers an eDelivery option for receiving your redetermination decision letters electronically Imagine getting your Medicare
redetermination notices (MRNs) the same day that they are issued delivered directly to your computer You even can choose to get an email to let you know that the letter
is waiting for you
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Anti-Markup and Reference Laboratory Claims
Effective dates
January 1 2015 - Analysis Design and Programming
April 1 2015 - Testing and Implementation
April 6 2015 ndash Edits turned on
Anti-markup and reference laboratory claims must report
Name address and ZIP code in block 32 or electronic equivalent and
NPI of the provider who actually performed the service in block 32a or electronic equivalent
552015 9 MM8806
Documentation Requests
Effective April 1 2015
Documentation for pre-payment reviews must be submitted within 45 calendar days of request
Claims denied on day 46
552015 10
MM8583
Administrative Law Judge (ALJ) and Federal District Court Appeals
Calendar Year 2015 Amount in Controversy
ALJ requests
Filed prior to January 1 2015 - $140
Filed January 1 2015 and after - $150
Federal District Court requests
Filed prior to January 1 2015 - $1430
Filed January 1 2015 and after - $1460
552015 11
2015 Drug Testing Codes
The Centers for Medicare amp Medicaid (CMS) has announced that the 2015 drug testing CPT codes 80300 ndash 80377 will not be recognized at this time by Medicare Until further notice new HCPCs G6030 ndash G6058 should be used when reporting drug testing performed on or after January 1 2015 Claims submitted with CPT code 80300 ndash 80377 on or after January 1 2015 will be rejected as unprocessable
CMS provides details of this change in the Clinical Laboratory Fee Schedule (CLFS) Final Determinations
Document (PDF 119 KB)
Comprehensive Error Rate Testing
(CERT)
13
Partnering for Error Rate Reduction
552015 14
Evaluation and
Management Services
Laboratory Services
Minor Procedures
Advanced Imaging Services
Ambulance Services
Chiropractic Services
Lab Claim Error Impact
bull Laboratory or performing provider is responsible for working with the ordering physician to complete and document the order or intent to order all tests
bull Ordering providerrsquos revenue is not tied to completing the laboratory order when tests performed by outside lab
bull Laboratory providers struggle to obtain the needed documentation from the ordering physician
15
Corrective Action
bull Implement processes to check for signed and dated order or records to support order or intent to order for each test before rendering lab test
bull Develop relationships with ordering providers ndash Let them know what supporting documentation is
needed when ordering
ndash Request necessary documentation when it is missing
bull Check for all necessary documentation prior to submitting
bull Self audit
bull Fix known deficiencies
16
Evaluation and Management Services
Categorized into different settings depending on where the service is furnished Examples of settings include
Office or other outpatient setting
Hospital inpatient
Emergency department (ED)
Nursing facility (NF)
17
Why are Errors Occurring
bull Insufficient documentation
bull No response to documentation request
bull Illegible
bull Documentation for wrong patient or date of service submitted
bull Documentation does not support level of EM billed
bull Documentation does not adequately describe the service defined by the CPTHPCS code or HCPCS modifier billed
Signature issues - no signature (or no legible signature) and no signature log or attestation submitted
bull Does not meet key elements - medical decision making history or physical exam for billed EM service level
18
Evaluation amp Management
19
Great teaching tool
Printing Options
EM Help Center
20
EM Weekly Tips
21
CERT Tips
Review denials
Submit missing documentation directly to CERT if denial is not a medical necessity denial
Appeal medical necessity denials
‒ CERT Redetermination Request Form
Designate a CERT ldquoPoint of Contactrdquo (POC)
httpswwwcertprovidercom
552015 22
Medical Review Spotlight
23
CERT vs Palmetto GBA Medical Reviews
bull CERT
ndash Traditionally conducts post-payment reviews ndash after the claim has finalized
ndash CERT contractor selects claim sample requests records and completes the review
ndash Failure to respond to a CERT record request may result in a contact from Palmetto GBA to assist the CERT in obtaining the records
bull Palmetto GBA
ndash Medical reviews can be pre-payment or post-payment reviews
ndash Palmetto GBA selects the claim sample sends the request for medical records and completes the reviews
ndash Based on a service specific review MR may conduct a provider-specific review
24
Active Medical Reviews
552015 25
httpwwwpalmettogbacompalmettoprovidersnsfDocsCatProviders~Jurisdiction201120Part20B~Medical20Review~General~9NNJBX6701openampnavmenu=Medical^Review||||
Comparative Billing Report (CBR)
Developed by eGlobalTech (eGT) and Palmetto GBA
National CBR on use of modifier 25 by providers under family practice specialty code
CBR contains data-driven tables and graphs with an explanation of findings that compare providers billing patterns to those of their peers in the state and across the nation for claims filed with Modifier 25
httpwwwcbrinfonetcbr201409html
552015 26
Medical Review Strategy
ldquoThe Listrdquo ndash Part B
Drugs and Biologicals
Evaluation amp Management
Laboratory
Emergency Department Visits
New Providers
Hot-Spot Focus Category
27
Medical Review Strategy
Laboratory
82542 ndash Column ChromatographyMass Spectrometry
Drug testing for opioid heroin etc (costs)
Can not have standing orders for this(med necc must be specific)
Emergency Department Visits (non-signature)
99283 ndash Emergency Department Visit for the EampM of a Patient - Expanded
99284 ndash Emergency Department Visit for the EampM of a Patient - Detailed
99285 ndash Emergency Department Visit for the EampM of a Patient - Comprehensive
28 CPT only copyright 2012 American Medical Association
All rights reserved
Medical Review Strategy
New Providers
New Part B Medicare Providers
Hot-Spot Focus Category
17000 17004 17110 17311 amp 17312 Destruction of Lesions and Mohs Examination of Specimens
MR Tip MOHS has very specific guidelines Must follow guidance in codebook Pathologist amp Surgeon bill at the same time so be clear on who is billing what The most common mistake is usually no pathology report
29 CPT only copyright 2012 American Medical Association
All rights reserved
Hot Topics and Reminders
30
Enrollment Application Status
Interactive Voice Response (IVR) Unit
Use DCN number or PTAN associated with that provider enrollment application
Status information updated approximately 24 hours after each transaction
552015 31
ROADTO10ORG
552015 32
ICD-10 ndash Resources
October 1 2015
552015 34
bull httpwwwcmsgovMedicareCodingICD10indexhtmlredirect=icd10
ICD-10 - CMS
bull httpwwwpalmettogbacompalmettoicdnsfDocsCatHomeICD-10
ICD-10
Palmetto GBA
News to Use and Resources
35
GBD Blog and Twitter
Palmetto GBA is using the Going Beyond Diagnosis (GBD) blog and Twitter account to help facilitate communication on error rate reduction
httppalmgbacomgbd
BeyondDx
552015 36
Provider Enrollment Open House Available the First Tuesday of the Month
Palmetto GBArsquos Provider Enrollment Department holds an open house at our Palmetto GBA office located at 17 Technology Circle Columbia South Carolina 29203 the first Tuesday of each month This open house is for any of Palmetto GBArsquos J11 Part B providers who would like to stop by and receive answers to their questions concerning their Medicare provider enrollment applications
Self Service Tools
552015 39
wwwPalmettoGBAcomJ11B
OPS ndash New Features
Submission of documentation to satisfy an Additional Documentation Response (ADR)
Unlimited PDF attachments (each up to 40 MB for a maximum total of 150MB)
Select lsquoMedical Reviewrsquo then lsquoMR ADR Responsersquo form
552015 40
New OPS Feature
Get Your First-Level Appeal Letters Delivered Electronically
Palmetto GBA now offers an eDelivery option for receiving your redetermination decision letters electronically Imagine getting your Medicare
redetermination notices (MRNs) the same day that they are issued delivered directly to your computer You even can choose to get an email to let you know that the letter
is waiting for you
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Documentation Requests
Effective April 1 2015
Documentation for pre-payment reviews must be submitted within 45 calendar days of request
Claims denied on day 46
552015 10
MM8583
Administrative Law Judge (ALJ) and Federal District Court Appeals
Calendar Year 2015 Amount in Controversy
ALJ requests
Filed prior to January 1 2015 - $140
Filed January 1 2015 and after - $150
Federal District Court requests
Filed prior to January 1 2015 - $1430
Filed January 1 2015 and after - $1460
552015 11
2015 Drug Testing Codes
The Centers for Medicare amp Medicaid (CMS) has announced that the 2015 drug testing CPT codes 80300 ndash 80377 will not be recognized at this time by Medicare Until further notice new HCPCs G6030 ndash G6058 should be used when reporting drug testing performed on or after January 1 2015 Claims submitted with CPT code 80300 ndash 80377 on or after January 1 2015 will be rejected as unprocessable
CMS provides details of this change in the Clinical Laboratory Fee Schedule (CLFS) Final Determinations
Document (PDF 119 KB)
Comprehensive Error Rate Testing
(CERT)
13
Partnering for Error Rate Reduction
552015 14
Evaluation and
Management Services
Laboratory Services
Minor Procedures
Advanced Imaging Services
Ambulance Services
Chiropractic Services
Lab Claim Error Impact
bull Laboratory or performing provider is responsible for working with the ordering physician to complete and document the order or intent to order all tests
bull Ordering providerrsquos revenue is not tied to completing the laboratory order when tests performed by outside lab
bull Laboratory providers struggle to obtain the needed documentation from the ordering physician
15
Corrective Action
bull Implement processes to check for signed and dated order or records to support order or intent to order for each test before rendering lab test
bull Develop relationships with ordering providers ndash Let them know what supporting documentation is
needed when ordering
ndash Request necessary documentation when it is missing
bull Check for all necessary documentation prior to submitting
bull Self audit
bull Fix known deficiencies
16
Evaluation and Management Services
Categorized into different settings depending on where the service is furnished Examples of settings include
Office or other outpatient setting
Hospital inpatient
Emergency department (ED)
Nursing facility (NF)
17
Why are Errors Occurring
bull Insufficient documentation
bull No response to documentation request
bull Illegible
bull Documentation for wrong patient or date of service submitted
bull Documentation does not support level of EM billed
bull Documentation does not adequately describe the service defined by the CPTHPCS code or HCPCS modifier billed
Signature issues - no signature (or no legible signature) and no signature log or attestation submitted
bull Does not meet key elements - medical decision making history or physical exam for billed EM service level
18
Evaluation amp Management
19
Great teaching tool
Printing Options
EM Help Center
20
EM Weekly Tips
21
CERT Tips
Review denials
Submit missing documentation directly to CERT if denial is not a medical necessity denial
Appeal medical necessity denials
‒ CERT Redetermination Request Form
Designate a CERT ldquoPoint of Contactrdquo (POC)
httpswwwcertprovidercom
552015 22
Medical Review Spotlight
23
CERT vs Palmetto GBA Medical Reviews
bull CERT
ndash Traditionally conducts post-payment reviews ndash after the claim has finalized
ndash CERT contractor selects claim sample requests records and completes the review
ndash Failure to respond to a CERT record request may result in a contact from Palmetto GBA to assist the CERT in obtaining the records
bull Palmetto GBA
ndash Medical reviews can be pre-payment or post-payment reviews
ndash Palmetto GBA selects the claim sample sends the request for medical records and completes the reviews
ndash Based on a service specific review MR may conduct a provider-specific review
24
Active Medical Reviews
552015 25
httpwwwpalmettogbacompalmettoprovidersnsfDocsCatProviders~Jurisdiction201120Part20B~Medical20Review~General~9NNJBX6701openampnavmenu=Medical^Review||||
Comparative Billing Report (CBR)
Developed by eGlobalTech (eGT) and Palmetto GBA
National CBR on use of modifier 25 by providers under family practice specialty code
CBR contains data-driven tables and graphs with an explanation of findings that compare providers billing patterns to those of their peers in the state and across the nation for claims filed with Modifier 25
httpwwwcbrinfonetcbr201409html
552015 26
Medical Review Strategy
ldquoThe Listrdquo ndash Part B
Drugs and Biologicals
Evaluation amp Management
Laboratory
Emergency Department Visits
New Providers
Hot-Spot Focus Category
27
Medical Review Strategy
Laboratory
82542 ndash Column ChromatographyMass Spectrometry
Drug testing for opioid heroin etc (costs)
Can not have standing orders for this(med necc must be specific)
Emergency Department Visits (non-signature)
99283 ndash Emergency Department Visit for the EampM of a Patient - Expanded
99284 ndash Emergency Department Visit for the EampM of a Patient - Detailed
99285 ndash Emergency Department Visit for the EampM of a Patient - Comprehensive
28 CPT only copyright 2012 American Medical Association
All rights reserved
Medical Review Strategy
New Providers
New Part B Medicare Providers
Hot-Spot Focus Category
17000 17004 17110 17311 amp 17312 Destruction of Lesions and Mohs Examination of Specimens
MR Tip MOHS has very specific guidelines Must follow guidance in codebook Pathologist amp Surgeon bill at the same time so be clear on who is billing what The most common mistake is usually no pathology report
29 CPT only copyright 2012 American Medical Association
All rights reserved
Hot Topics and Reminders
30
Enrollment Application Status
Interactive Voice Response (IVR) Unit
Use DCN number or PTAN associated with that provider enrollment application
Status information updated approximately 24 hours after each transaction
552015 31
ROADTO10ORG
552015 32
ICD-10 ndash Resources
October 1 2015
552015 34
bull httpwwwcmsgovMedicareCodingICD10indexhtmlredirect=icd10
ICD-10 - CMS
bull httpwwwpalmettogbacompalmettoicdnsfDocsCatHomeICD-10
ICD-10
Palmetto GBA
News to Use and Resources
35
GBD Blog and Twitter
Palmetto GBA is using the Going Beyond Diagnosis (GBD) blog and Twitter account to help facilitate communication on error rate reduction
httppalmgbacomgbd
BeyondDx
552015 36
Provider Enrollment Open House Available the First Tuesday of the Month
Palmetto GBArsquos Provider Enrollment Department holds an open house at our Palmetto GBA office located at 17 Technology Circle Columbia South Carolina 29203 the first Tuesday of each month This open house is for any of Palmetto GBArsquos J11 Part B providers who would like to stop by and receive answers to their questions concerning their Medicare provider enrollment applications
Self Service Tools
552015 39
wwwPalmettoGBAcomJ11B
OPS ndash New Features
Submission of documentation to satisfy an Additional Documentation Response (ADR)
Unlimited PDF attachments (each up to 40 MB for a maximum total of 150MB)
Select lsquoMedical Reviewrsquo then lsquoMR ADR Responsersquo form
552015 40
New OPS Feature
Get Your First-Level Appeal Letters Delivered Electronically
Palmetto GBA now offers an eDelivery option for receiving your redetermination decision letters electronically Imagine getting your Medicare
redetermination notices (MRNs) the same day that they are issued delivered directly to your computer You even can choose to get an email to let you know that the letter
is waiting for you
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Administrative Law Judge (ALJ) and Federal District Court Appeals
Calendar Year 2015 Amount in Controversy
ALJ requests
Filed prior to January 1 2015 - $140
Filed January 1 2015 and after - $150
Federal District Court requests
Filed prior to January 1 2015 - $1430
Filed January 1 2015 and after - $1460
552015 11
2015 Drug Testing Codes
The Centers for Medicare amp Medicaid (CMS) has announced that the 2015 drug testing CPT codes 80300 ndash 80377 will not be recognized at this time by Medicare Until further notice new HCPCs G6030 ndash G6058 should be used when reporting drug testing performed on or after January 1 2015 Claims submitted with CPT code 80300 ndash 80377 on or after January 1 2015 will be rejected as unprocessable
CMS provides details of this change in the Clinical Laboratory Fee Schedule (CLFS) Final Determinations
Document (PDF 119 KB)
Comprehensive Error Rate Testing
(CERT)
13
Partnering for Error Rate Reduction
552015 14
Evaluation and
Management Services
Laboratory Services
Minor Procedures
Advanced Imaging Services
Ambulance Services
Chiropractic Services
Lab Claim Error Impact
bull Laboratory or performing provider is responsible for working with the ordering physician to complete and document the order or intent to order all tests
bull Ordering providerrsquos revenue is not tied to completing the laboratory order when tests performed by outside lab
bull Laboratory providers struggle to obtain the needed documentation from the ordering physician
15
Corrective Action
bull Implement processes to check for signed and dated order or records to support order or intent to order for each test before rendering lab test
bull Develop relationships with ordering providers ndash Let them know what supporting documentation is
needed when ordering
ndash Request necessary documentation when it is missing
bull Check for all necessary documentation prior to submitting
bull Self audit
bull Fix known deficiencies
16
Evaluation and Management Services
Categorized into different settings depending on where the service is furnished Examples of settings include
Office or other outpatient setting
Hospital inpatient
Emergency department (ED)
Nursing facility (NF)
17
Why are Errors Occurring
bull Insufficient documentation
bull No response to documentation request
bull Illegible
bull Documentation for wrong patient or date of service submitted
bull Documentation does not support level of EM billed
bull Documentation does not adequately describe the service defined by the CPTHPCS code or HCPCS modifier billed
Signature issues - no signature (or no legible signature) and no signature log or attestation submitted
bull Does not meet key elements - medical decision making history or physical exam for billed EM service level
18
Evaluation amp Management
19
Great teaching tool
Printing Options
EM Help Center
20
EM Weekly Tips
21
CERT Tips
Review denials
Submit missing documentation directly to CERT if denial is not a medical necessity denial
Appeal medical necessity denials
‒ CERT Redetermination Request Form
Designate a CERT ldquoPoint of Contactrdquo (POC)
httpswwwcertprovidercom
552015 22
Medical Review Spotlight
23
CERT vs Palmetto GBA Medical Reviews
bull CERT
ndash Traditionally conducts post-payment reviews ndash after the claim has finalized
ndash CERT contractor selects claim sample requests records and completes the review
ndash Failure to respond to a CERT record request may result in a contact from Palmetto GBA to assist the CERT in obtaining the records
bull Palmetto GBA
ndash Medical reviews can be pre-payment or post-payment reviews
ndash Palmetto GBA selects the claim sample sends the request for medical records and completes the reviews
ndash Based on a service specific review MR may conduct a provider-specific review
24
Active Medical Reviews
552015 25
httpwwwpalmettogbacompalmettoprovidersnsfDocsCatProviders~Jurisdiction201120Part20B~Medical20Review~General~9NNJBX6701openampnavmenu=Medical^Review||||
Comparative Billing Report (CBR)
Developed by eGlobalTech (eGT) and Palmetto GBA
National CBR on use of modifier 25 by providers under family practice specialty code
CBR contains data-driven tables and graphs with an explanation of findings that compare providers billing patterns to those of their peers in the state and across the nation for claims filed with Modifier 25
httpwwwcbrinfonetcbr201409html
552015 26
Medical Review Strategy
ldquoThe Listrdquo ndash Part B
Drugs and Biologicals
Evaluation amp Management
Laboratory
Emergency Department Visits
New Providers
Hot-Spot Focus Category
27
Medical Review Strategy
Laboratory
82542 ndash Column ChromatographyMass Spectrometry
Drug testing for opioid heroin etc (costs)
Can not have standing orders for this(med necc must be specific)
Emergency Department Visits (non-signature)
99283 ndash Emergency Department Visit for the EampM of a Patient - Expanded
99284 ndash Emergency Department Visit for the EampM of a Patient - Detailed
99285 ndash Emergency Department Visit for the EampM of a Patient - Comprehensive
28 CPT only copyright 2012 American Medical Association
All rights reserved
Medical Review Strategy
New Providers
New Part B Medicare Providers
Hot-Spot Focus Category
17000 17004 17110 17311 amp 17312 Destruction of Lesions and Mohs Examination of Specimens
MR Tip MOHS has very specific guidelines Must follow guidance in codebook Pathologist amp Surgeon bill at the same time so be clear on who is billing what The most common mistake is usually no pathology report
29 CPT only copyright 2012 American Medical Association
All rights reserved
Hot Topics and Reminders
30
Enrollment Application Status
Interactive Voice Response (IVR) Unit
Use DCN number or PTAN associated with that provider enrollment application
Status information updated approximately 24 hours after each transaction
552015 31
ROADTO10ORG
552015 32
ICD-10 ndash Resources
October 1 2015
552015 34
bull httpwwwcmsgovMedicareCodingICD10indexhtmlredirect=icd10
ICD-10 - CMS
bull httpwwwpalmettogbacompalmettoicdnsfDocsCatHomeICD-10
ICD-10
Palmetto GBA
News to Use and Resources
35
GBD Blog and Twitter
Palmetto GBA is using the Going Beyond Diagnosis (GBD) blog and Twitter account to help facilitate communication on error rate reduction
httppalmgbacomgbd
BeyondDx
552015 36
Provider Enrollment Open House Available the First Tuesday of the Month
Palmetto GBArsquos Provider Enrollment Department holds an open house at our Palmetto GBA office located at 17 Technology Circle Columbia South Carolina 29203 the first Tuesday of each month This open house is for any of Palmetto GBArsquos J11 Part B providers who would like to stop by and receive answers to their questions concerning their Medicare provider enrollment applications
Self Service Tools
552015 39
wwwPalmettoGBAcomJ11B
OPS ndash New Features
Submission of documentation to satisfy an Additional Documentation Response (ADR)
Unlimited PDF attachments (each up to 40 MB for a maximum total of 150MB)
Select lsquoMedical Reviewrsquo then lsquoMR ADR Responsersquo form
552015 40
New OPS Feature
Get Your First-Level Appeal Letters Delivered Electronically
Palmetto GBA now offers an eDelivery option for receiving your redetermination decision letters electronically Imagine getting your Medicare
redetermination notices (MRNs) the same day that they are issued delivered directly to your computer You even can choose to get an email to let you know that the letter
is waiting for you
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
2015 Drug Testing Codes
The Centers for Medicare amp Medicaid (CMS) has announced that the 2015 drug testing CPT codes 80300 ndash 80377 will not be recognized at this time by Medicare Until further notice new HCPCs G6030 ndash G6058 should be used when reporting drug testing performed on or after January 1 2015 Claims submitted with CPT code 80300 ndash 80377 on or after January 1 2015 will be rejected as unprocessable
CMS provides details of this change in the Clinical Laboratory Fee Schedule (CLFS) Final Determinations
Document (PDF 119 KB)
Comprehensive Error Rate Testing
(CERT)
13
Partnering for Error Rate Reduction
552015 14
Evaluation and
Management Services
Laboratory Services
Minor Procedures
Advanced Imaging Services
Ambulance Services
Chiropractic Services
Lab Claim Error Impact
bull Laboratory or performing provider is responsible for working with the ordering physician to complete and document the order or intent to order all tests
bull Ordering providerrsquos revenue is not tied to completing the laboratory order when tests performed by outside lab
bull Laboratory providers struggle to obtain the needed documentation from the ordering physician
15
Corrective Action
bull Implement processes to check for signed and dated order or records to support order or intent to order for each test before rendering lab test
bull Develop relationships with ordering providers ndash Let them know what supporting documentation is
needed when ordering
ndash Request necessary documentation when it is missing
bull Check for all necessary documentation prior to submitting
bull Self audit
bull Fix known deficiencies
16
Evaluation and Management Services
Categorized into different settings depending on where the service is furnished Examples of settings include
Office or other outpatient setting
Hospital inpatient
Emergency department (ED)
Nursing facility (NF)
17
Why are Errors Occurring
bull Insufficient documentation
bull No response to documentation request
bull Illegible
bull Documentation for wrong patient or date of service submitted
bull Documentation does not support level of EM billed
bull Documentation does not adequately describe the service defined by the CPTHPCS code or HCPCS modifier billed
Signature issues - no signature (or no legible signature) and no signature log or attestation submitted
bull Does not meet key elements - medical decision making history or physical exam for billed EM service level
18
Evaluation amp Management
19
Great teaching tool
Printing Options
EM Help Center
20
EM Weekly Tips
21
CERT Tips
Review denials
Submit missing documentation directly to CERT if denial is not a medical necessity denial
Appeal medical necessity denials
‒ CERT Redetermination Request Form
Designate a CERT ldquoPoint of Contactrdquo (POC)
httpswwwcertprovidercom
552015 22
Medical Review Spotlight
23
CERT vs Palmetto GBA Medical Reviews
bull CERT
ndash Traditionally conducts post-payment reviews ndash after the claim has finalized
ndash CERT contractor selects claim sample requests records and completes the review
ndash Failure to respond to a CERT record request may result in a contact from Palmetto GBA to assist the CERT in obtaining the records
bull Palmetto GBA
ndash Medical reviews can be pre-payment or post-payment reviews
ndash Palmetto GBA selects the claim sample sends the request for medical records and completes the reviews
ndash Based on a service specific review MR may conduct a provider-specific review
24
Active Medical Reviews
552015 25
httpwwwpalmettogbacompalmettoprovidersnsfDocsCatProviders~Jurisdiction201120Part20B~Medical20Review~General~9NNJBX6701openampnavmenu=Medical^Review||||
Comparative Billing Report (CBR)
Developed by eGlobalTech (eGT) and Palmetto GBA
National CBR on use of modifier 25 by providers under family practice specialty code
CBR contains data-driven tables and graphs with an explanation of findings that compare providers billing patterns to those of their peers in the state and across the nation for claims filed with Modifier 25
httpwwwcbrinfonetcbr201409html
552015 26
Medical Review Strategy
ldquoThe Listrdquo ndash Part B
Drugs and Biologicals
Evaluation amp Management
Laboratory
Emergency Department Visits
New Providers
Hot-Spot Focus Category
27
Medical Review Strategy
Laboratory
82542 ndash Column ChromatographyMass Spectrometry
Drug testing for opioid heroin etc (costs)
Can not have standing orders for this(med necc must be specific)
Emergency Department Visits (non-signature)
99283 ndash Emergency Department Visit for the EampM of a Patient - Expanded
99284 ndash Emergency Department Visit for the EampM of a Patient - Detailed
99285 ndash Emergency Department Visit for the EampM of a Patient - Comprehensive
28 CPT only copyright 2012 American Medical Association
All rights reserved
Medical Review Strategy
New Providers
New Part B Medicare Providers
Hot-Spot Focus Category
17000 17004 17110 17311 amp 17312 Destruction of Lesions and Mohs Examination of Specimens
MR Tip MOHS has very specific guidelines Must follow guidance in codebook Pathologist amp Surgeon bill at the same time so be clear on who is billing what The most common mistake is usually no pathology report
29 CPT only copyright 2012 American Medical Association
All rights reserved
Hot Topics and Reminders
30
Enrollment Application Status
Interactive Voice Response (IVR) Unit
Use DCN number or PTAN associated with that provider enrollment application
Status information updated approximately 24 hours after each transaction
552015 31
ROADTO10ORG
552015 32
ICD-10 ndash Resources
October 1 2015
552015 34
bull httpwwwcmsgovMedicareCodingICD10indexhtmlredirect=icd10
ICD-10 - CMS
bull httpwwwpalmettogbacompalmettoicdnsfDocsCatHomeICD-10
ICD-10
Palmetto GBA
News to Use and Resources
35
GBD Blog and Twitter
Palmetto GBA is using the Going Beyond Diagnosis (GBD) blog and Twitter account to help facilitate communication on error rate reduction
httppalmgbacomgbd
BeyondDx
552015 36
Provider Enrollment Open House Available the First Tuesday of the Month
Palmetto GBArsquos Provider Enrollment Department holds an open house at our Palmetto GBA office located at 17 Technology Circle Columbia South Carolina 29203 the first Tuesday of each month This open house is for any of Palmetto GBArsquos J11 Part B providers who would like to stop by and receive answers to their questions concerning their Medicare provider enrollment applications
Self Service Tools
552015 39
wwwPalmettoGBAcomJ11B
OPS ndash New Features
Submission of documentation to satisfy an Additional Documentation Response (ADR)
Unlimited PDF attachments (each up to 40 MB for a maximum total of 150MB)
Select lsquoMedical Reviewrsquo then lsquoMR ADR Responsersquo form
552015 40
New OPS Feature
Get Your First-Level Appeal Letters Delivered Electronically
Palmetto GBA now offers an eDelivery option for receiving your redetermination decision letters electronically Imagine getting your Medicare
redetermination notices (MRNs) the same day that they are issued delivered directly to your computer You even can choose to get an email to let you know that the letter
is waiting for you
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Comprehensive Error Rate Testing
(CERT)
13
Partnering for Error Rate Reduction
552015 14
Evaluation and
Management Services
Laboratory Services
Minor Procedures
Advanced Imaging Services
Ambulance Services
Chiropractic Services
Lab Claim Error Impact
bull Laboratory or performing provider is responsible for working with the ordering physician to complete and document the order or intent to order all tests
bull Ordering providerrsquos revenue is not tied to completing the laboratory order when tests performed by outside lab
bull Laboratory providers struggle to obtain the needed documentation from the ordering physician
15
Corrective Action
bull Implement processes to check for signed and dated order or records to support order or intent to order for each test before rendering lab test
bull Develop relationships with ordering providers ndash Let them know what supporting documentation is
needed when ordering
ndash Request necessary documentation when it is missing
bull Check for all necessary documentation prior to submitting
bull Self audit
bull Fix known deficiencies
16
Evaluation and Management Services
Categorized into different settings depending on where the service is furnished Examples of settings include
Office or other outpatient setting
Hospital inpatient
Emergency department (ED)
Nursing facility (NF)
17
Why are Errors Occurring
bull Insufficient documentation
bull No response to documentation request
bull Illegible
bull Documentation for wrong patient or date of service submitted
bull Documentation does not support level of EM billed
bull Documentation does not adequately describe the service defined by the CPTHPCS code or HCPCS modifier billed
Signature issues - no signature (or no legible signature) and no signature log or attestation submitted
bull Does not meet key elements - medical decision making history or physical exam for billed EM service level
18
Evaluation amp Management
19
Great teaching tool
Printing Options
EM Help Center
20
EM Weekly Tips
21
CERT Tips
Review denials
Submit missing documentation directly to CERT if denial is not a medical necessity denial
Appeal medical necessity denials
‒ CERT Redetermination Request Form
Designate a CERT ldquoPoint of Contactrdquo (POC)
httpswwwcertprovidercom
552015 22
Medical Review Spotlight
23
CERT vs Palmetto GBA Medical Reviews
bull CERT
ndash Traditionally conducts post-payment reviews ndash after the claim has finalized
ndash CERT contractor selects claim sample requests records and completes the review
ndash Failure to respond to a CERT record request may result in a contact from Palmetto GBA to assist the CERT in obtaining the records
bull Palmetto GBA
ndash Medical reviews can be pre-payment or post-payment reviews
ndash Palmetto GBA selects the claim sample sends the request for medical records and completes the reviews
ndash Based on a service specific review MR may conduct a provider-specific review
24
Active Medical Reviews
552015 25
httpwwwpalmettogbacompalmettoprovidersnsfDocsCatProviders~Jurisdiction201120Part20B~Medical20Review~General~9NNJBX6701openampnavmenu=Medical^Review||||
Comparative Billing Report (CBR)
Developed by eGlobalTech (eGT) and Palmetto GBA
National CBR on use of modifier 25 by providers under family practice specialty code
CBR contains data-driven tables and graphs with an explanation of findings that compare providers billing patterns to those of their peers in the state and across the nation for claims filed with Modifier 25
httpwwwcbrinfonetcbr201409html
552015 26
Medical Review Strategy
ldquoThe Listrdquo ndash Part B
Drugs and Biologicals
Evaluation amp Management
Laboratory
Emergency Department Visits
New Providers
Hot-Spot Focus Category
27
Medical Review Strategy
Laboratory
82542 ndash Column ChromatographyMass Spectrometry
Drug testing for opioid heroin etc (costs)
Can not have standing orders for this(med necc must be specific)
Emergency Department Visits (non-signature)
99283 ndash Emergency Department Visit for the EampM of a Patient - Expanded
99284 ndash Emergency Department Visit for the EampM of a Patient - Detailed
99285 ndash Emergency Department Visit for the EampM of a Patient - Comprehensive
28 CPT only copyright 2012 American Medical Association
All rights reserved
Medical Review Strategy
New Providers
New Part B Medicare Providers
Hot-Spot Focus Category
17000 17004 17110 17311 amp 17312 Destruction of Lesions and Mohs Examination of Specimens
MR Tip MOHS has very specific guidelines Must follow guidance in codebook Pathologist amp Surgeon bill at the same time so be clear on who is billing what The most common mistake is usually no pathology report
29 CPT only copyright 2012 American Medical Association
All rights reserved
Hot Topics and Reminders
30
Enrollment Application Status
Interactive Voice Response (IVR) Unit
Use DCN number or PTAN associated with that provider enrollment application
Status information updated approximately 24 hours after each transaction
552015 31
ROADTO10ORG
552015 32
ICD-10 ndash Resources
October 1 2015
552015 34
bull httpwwwcmsgovMedicareCodingICD10indexhtmlredirect=icd10
ICD-10 - CMS
bull httpwwwpalmettogbacompalmettoicdnsfDocsCatHomeICD-10
ICD-10
Palmetto GBA
News to Use and Resources
35
GBD Blog and Twitter
Palmetto GBA is using the Going Beyond Diagnosis (GBD) blog and Twitter account to help facilitate communication on error rate reduction
httppalmgbacomgbd
BeyondDx
552015 36
Provider Enrollment Open House Available the First Tuesday of the Month
Palmetto GBArsquos Provider Enrollment Department holds an open house at our Palmetto GBA office located at 17 Technology Circle Columbia South Carolina 29203 the first Tuesday of each month This open house is for any of Palmetto GBArsquos J11 Part B providers who would like to stop by and receive answers to their questions concerning their Medicare provider enrollment applications
Self Service Tools
552015 39
wwwPalmettoGBAcomJ11B
OPS ndash New Features
Submission of documentation to satisfy an Additional Documentation Response (ADR)
Unlimited PDF attachments (each up to 40 MB for a maximum total of 150MB)
Select lsquoMedical Reviewrsquo then lsquoMR ADR Responsersquo form
552015 40
New OPS Feature
Get Your First-Level Appeal Letters Delivered Electronically
Palmetto GBA now offers an eDelivery option for receiving your redetermination decision letters electronically Imagine getting your Medicare
redetermination notices (MRNs) the same day that they are issued delivered directly to your computer You even can choose to get an email to let you know that the letter
is waiting for you
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Partnering for Error Rate Reduction
552015 14
Evaluation and
Management Services
Laboratory Services
Minor Procedures
Advanced Imaging Services
Ambulance Services
Chiropractic Services
Lab Claim Error Impact
bull Laboratory or performing provider is responsible for working with the ordering physician to complete and document the order or intent to order all tests
bull Ordering providerrsquos revenue is not tied to completing the laboratory order when tests performed by outside lab
bull Laboratory providers struggle to obtain the needed documentation from the ordering physician
15
Corrective Action
bull Implement processes to check for signed and dated order or records to support order or intent to order for each test before rendering lab test
bull Develop relationships with ordering providers ndash Let them know what supporting documentation is
needed when ordering
ndash Request necessary documentation when it is missing
bull Check for all necessary documentation prior to submitting
bull Self audit
bull Fix known deficiencies
16
Evaluation and Management Services
Categorized into different settings depending on where the service is furnished Examples of settings include
Office or other outpatient setting
Hospital inpatient
Emergency department (ED)
Nursing facility (NF)
17
Why are Errors Occurring
bull Insufficient documentation
bull No response to documentation request
bull Illegible
bull Documentation for wrong patient or date of service submitted
bull Documentation does not support level of EM billed
bull Documentation does not adequately describe the service defined by the CPTHPCS code or HCPCS modifier billed
Signature issues - no signature (or no legible signature) and no signature log or attestation submitted
bull Does not meet key elements - medical decision making history or physical exam for billed EM service level
18
Evaluation amp Management
19
Great teaching tool
Printing Options
EM Help Center
20
EM Weekly Tips
21
CERT Tips
Review denials
Submit missing documentation directly to CERT if denial is not a medical necessity denial
Appeal medical necessity denials
‒ CERT Redetermination Request Form
Designate a CERT ldquoPoint of Contactrdquo (POC)
httpswwwcertprovidercom
552015 22
Medical Review Spotlight
23
CERT vs Palmetto GBA Medical Reviews
bull CERT
ndash Traditionally conducts post-payment reviews ndash after the claim has finalized
ndash CERT contractor selects claim sample requests records and completes the review
ndash Failure to respond to a CERT record request may result in a contact from Palmetto GBA to assist the CERT in obtaining the records
bull Palmetto GBA
ndash Medical reviews can be pre-payment or post-payment reviews
ndash Palmetto GBA selects the claim sample sends the request for medical records and completes the reviews
ndash Based on a service specific review MR may conduct a provider-specific review
24
Active Medical Reviews
552015 25
httpwwwpalmettogbacompalmettoprovidersnsfDocsCatProviders~Jurisdiction201120Part20B~Medical20Review~General~9NNJBX6701openampnavmenu=Medical^Review||||
Comparative Billing Report (CBR)
Developed by eGlobalTech (eGT) and Palmetto GBA
National CBR on use of modifier 25 by providers under family practice specialty code
CBR contains data-driven tables and graphs with an explanation of findings that compare providers billing patterns to those of their peers in the state and across the nation for claims filed with Modifier 25
httpwwwcbrinfonetcbr201409html
552015 26
Medical Review Strategy
ldquoThe Listrdquo ndash Part B
Drugs and Biologicals
Evaluation amp Management
Laboratory
Emergency Department Visits
New Providers
Hot-Spot Focus Category
27
Medical Review Strategy
Laboratory
82542 ndash Column ChromatographyMass Spectrometry
Drug testing for opioid heroin etc (costs)
Can not have standing orders for this(med necc must be specific)
Emergency Department Visits (non-signature)
99283 ndash Emergency Department Visit for the EampM of a Patient - Expanded
99284 ndash Emergency Department Visit for the EampM of a Patient - Detailed
99285 ndash Emergency Department Visit for the EampM of a Patient - Comprehensive
28 CPT only copyright 2012 American Medical Association
All rights reserved
Medical Review Strategy
New Providers
New Part B Medicare Providers
Hot-Spot Focus Category
17000 17004 17110 17311 amp 17312 Destruction of Lesions and Mohs Examination of Specimens
MR Tip MOHS has very specific guidelines Must follow guidance in codebook Pathologist amp Surgeon bill at the same time so be clear on who is billing what The most common mistake is usually no pathology report
29 CPT only copyright 2012 American Medical Association
All rights reserved
Hot Topics and Reminders
30
Enrollment Application Status
Interactive Voice Response (IVR) Unit
Use DCN number or PTAN associated with that provider enrollment application
Status information updated approximately 24 hours after each transaction
552015 31
ROADTO10ORG
552015 32
ICD-10 ndash Resources
October 1 2015
552015 34
bull httpwwwcmsgovMedicareCodingICD10indexhtmlredirect=icd10
ICD-10 - CMS
bull httpwwwpalmettogbacompalmettoicdnsfDocsCatHomeICD-10
ICD-10
Palmetto GBA
News to Use and Resources
35
GBD Blog and Twitter
Palmetto GBA is using the Going Beyond Diagnosis (GBD) blog and Twitter account to help facilitate communication on error rate reduction
httppalmgbacomgbd
BeyondDx
552015 36
Provider Enrollment Open House Available the First Tuesday of the Month
Palmetto GBArsquos Provider Enrollment Department holds an open house at our Palmetto GBA office located at 17 Technology Circle Columbia South Carolina 29203 the first Tuesday of each month This open house is for any of Palmetto GBArsquos J11 Part B providers who would like to stop by and receive answers to their questions concerning their Medicare provider enrollment applications
Self Service Tools
552015 39
wwwPalmettoGBAcomJ11B
OPS ndash New Features
Submission of documentation to satisfy an Additional Documentation Response (ADR)
Unlimited PDF attachments (each up to 40 MB for a maximum total of 150MB)
Select lsquoMedical Reviewrsquo then lsquoMR ADR Responsersquo form
552015 40
New OPS Feature
Get Your First-Level Appeal Letters Delivered Electronically
Palmetto GBA now offers an eDelivery option for receiving your redetermination decision letters electronically Imagine getting your Medicare
redetermination notices (MRNs) the same day that they are issued delivered directly to your computer You even can choose to get an email to let you know that the letter
is waiting for you
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Lab Claim Error Impact
bull Laboratory or performing provider is responsible for working with the ordering physician to complete and document the order or intent to order all tests
bull Ordering providerrsquos revenue is not tied to completing the laboratory order when tests performed by outside lab
bull Laboratory providers struggle to obtain the needed documentation from the ordering physician
15
Corrective Action
bull Implement processes to check for signed and dated order or records to support order or intent to order for each test before rendering lab test
bull Develop relationships with ordering providers ndash Let them know what supporting documentation is
needed when ordering
ndash Request necessary documentation when it is missing
bull Check for all necessary documentation prior to submitting
bull Self audit
bull Fix known deficiencies
16
Evaluation and Management Services
Categorized into different settings depending on where the service is furnished Examples of settings include
Office or other outpatient setting
Hospital inpatient
Emergency department (ED)
Nursing facility (NF)
17
Why are Errors Occurring
bull Insufficient documentation
bull No response to documentation request
bull Illegible
bull Documentation for wrong patient or date of service submitted
bull Documentation does not support level of EM billed
bull Documentation does not adequately describe the service defined by the CPTHPCS code or HCPCS modifier billed
Signature issues - no signature (or no legible signature) and no signature log or attestation submitted
bull Does not meet key elements - medical decision making history or physical exam for billed EM service level
18
Evaluation amp Management
19
Great teaching tool
Printing Options
EM Help Center
20
EM Weekly Tips
21
CERT Tips
Review denials
Submit missing documentation directly to CERT if denial is not a medical necessity denial
Appeal medical necessity denials
‒ CERT Redetermination Request Form
Designate a CERT ldquoPoint of Contactrdquo (POC)
httpswwwcertprovidercom
552015 22
Medical Review Spotlight
23
CERT vs Palmetto GBA Medical Reviews
bull CERT
ndash Traditionally conducts post-payment reviews ndash after the claim has finalized
ndash CERT contractor selects claim sample requests records and completes the review
ndash Failure to respond to a CERT record request may result in a contact from Palmetto GBA to assist the CERT in obtaining the records
bull Palmetto GBA
ndash Medical reviews can be pre-payment or post-payment reviews
ndash Palmetto GBA selects the claim sample sends the request for medical records and completes the reviews
ndash Based on a service specific review MR may conduct a provider-specific review
24
Active Medical Reviews
552015 25
httpwwwpalmettogbacompalmettoprovidersnsfDocsCatProviders~Jurisdiction201120Part20B~Medical20Review~General~9NNJBX6701openampnavmenu=Medical^Review||||
Comparative Billing Report (CBR)
Developed by eGlobalTech (eGT) and Palmetto GBA
National CBR on use of modifier 25 by providers under family practice specialty code
CBR contains data-driven tables and graphs with an explanation of findings that compare providers billing patterns to those of their peers in the state and across the nation for claims filed with Modifier 25
httpwwwcbrinfonetcbr201409html
552015 26
Medical Review Strategy
ldquoThe Listrdquo ndash Part B
Drugs and Biologicals
Evaluation amp Management
Laboratory
Emergency Department Visits
New Providers
Hot-Spot Focus Category
27
Medical Review Strategy
Laboratory
82542 ndash Column ChromatographyMass Spectrometry
Drug testing for opioid heroin etc (costs)
Can not have standing orders for this(med necc must be specific)
Emergency Department Visits (non-signature)
99283 ndash Emergency Department Visit for the EampM of a Patient - Expanded
99284 ndash Emergency Department Visit for the EampM of a Patient - Detailed
99285 ndash Emergency Department Visit for the EampM of a Patient - Comprehensive
28 CPT only copyright 2012 American Medical Association
All rights reserved
Medical Review Strategy
New Providers
New Part B Medicare Providers
Hot-Spot Focus Category
17000 17004 17110 17311 amp 17312 Destruction of Lesions and Mohs Examination of Specimens
MR Tip MOHS has very specific guidelines Must follow guidance in codebook Pathologist amp Surgeon bill at the same time so be clear on who is billing what The most common mistake is usually no pathology report
29 CPT only copyright 2012 American Medical Association
All rights reserved
Hot Topics and Reminders
30
Enrollment Application Status
Interactive Voice Response (IVR) Unit
Use DCN number or PTAN associated with that provider enrollment application
Status information updated approximately 24 hours after each transaction
552015 31
ROADTO10ORG
552015 32
ICD-10 ndash Resources
October 1 2015
552015 34
bull httpwwwcmsgovMedicareCodingICD10indexhtmlredirect=icd10
ICD-10 - CMS
bull httpwwwpalmettogbacompalmettoicdnsfDocsCatHomeICD-10
ICD-10
Palmetto GBA
News to Use and Resources
35
GBD Blog and Twitter
Palmetto GBA is using the Going Beyond Diagnosis (GBD) blog and Twitter account to help facilitate communication on error rate reduction
httppalmgbacomgbd
BeyondDx
552015 36
Provider Enrollment Open House Available the First Tuesday of the Month
Palmetto GBArsquos Provider Enrollment Department holds an open house at our Palmetto GBA office located at 17 Technology Circle Columbia South Carolina 29203 the first Tuesday of each month This open house is for any of Palmetto GBArsquos J11 Part B providers who would like to stop by and receive answers to their questions concerning their Medicare provider enrollment applications
Self Service Tools
552015 39
wwwPalmettoGBAcomJ11B
OPS ndash New Features
Submission of documentation to satisfy an Additional Documentation Response (ADR)
Unlimited PDF attachments (each up to 40 MB for a maximum total of 150MB)
Select lsquoMedical Reviewrsquo then lsquoMR ADR Responsersquo form
552015 40
New OPS Feature
Get Your First-Level Appeal Letters Delivered Electronically
Palmetto GBA now offers an eDelivery option for receiving your redetermination decision letters electronically Imagine getting your Medicare
redetermination notices (MRNs) the same day that they are issued delivered directly to your computer You even can choose to get an email to let you know that the letter
is waiting for you
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Corrective Action
bull Implement processes to check for signed and dated order or records to support order or intent to order for each test before rendering lab test
bull Develop relationships with ordering providers ndash Let them know what supporting documentation is
needed when ordering
ndash Request necessary documentation when it is missing
bull Check for all necessary documentation prior to submitting
bull Self audit
bull Fix known deficiencies
16
Evaluation and Management Services
Categorized into different settings depending on where the service is furnished Examples of settings include
Office or other outpatient setting
Hospital inpatient
Emergency department (ED)
Nursing facility (NF)
17
Why are Errors Occurring
bull Insufficient documentation
bull No response to documentation request
bull Illegible
bull Documentation for wrong patient or date of service submitted
bull Documentation does not support level of EM billed
bull Documentation does not adequately describe the service defined by the CPTHPCS code or HCPCS modifier billed
Signature issues - no signature (or no legible signature) and no signature log or attestation submitted
bull Does not meet key elements - medical decision making history or physical exam for billed EM service level
18
Evaluation amp Management
19
Great teaching tool
Printing Options
EM Help Center
20
EM Weekly Tips
21
CERT Tips
Review denials
Submit missing documentation directly to CERT if denial is not a medical necessity denial
Appeal medical necessity denials
‒ CERT Redetermination Request Form
Designate a CERT ldquoPoint of Contactrdquo (POC)
httpswwwcertprovidercom
552015 22
Medical Review Spotlight
23
CERT vs Palmetto GBA Medical Reviews
bull CERT
ndash Traditionally conducts post-payment reviews ndash after the claim has finalized
ndash CERT contractor selects claim sample requests records and completes the review
ndash Failure to respond to a CERT record request may result in a contact from Palmetto GBA to assist the CERT in obtaining the records
bull Palmetto GBA
ndash Medical reviews can be pre-payment or post-payment reviews
ndash Palmetto GBA selects the claim sample sends the request for medical records and completes the reviews
ndash Based on a service specific review MR may conduct a provider-specific review
24
Active Medical Reviews
552015 25
httpwwwpalmettogbacompalmettoprovidersnsfDocsCatProviders~Jurisdiction201120Part20B~Medical20Review~General~9NNJBX6701openampnavmenu=Medical^Review||||
Comparative Billing Report (CBR)
Developed by eGlobalTech (eGT) and Palmetto GBA
National CBR on use of modifier 25 by providers under family practice specialty code
CBR contains data-driven tables and graphs with an explanation of findings that compare providers billing patterns to those of their peers in the state and across the nation for claims filed with Modifier 25
httpwwwcbrinfonetcbr201409html
552015 26
Medical Review Strategy
ldquoThe Listrdquo ndash Part B
Drugs and Biologicals
Evaluation amp Management
Laboratory
Emergency Department Visits
New Providers
Hot-Spot Focus Category
27
Medical Review Strategy
Laboratory
82542 ndash Column ChromatographyMass Spectrometry
Drug testing for opioid heroin etc (costs)
Can not have standing orders for this(med necc must be specific)
Emergency Department Visits (non-signature)
99283 ndash Emergency Department Visit for the EampM of a Patient - Expanded
99284 ndash Emergency Department Visit for the EampM of a Patient - Detailed
99285 ndash Emergency Department Visit for the EampM of a Patient - Comprehensive
28 CPT only copyright 2012 American Medical Association
All rights reserved
Medical Review Strategy
New Providers
New Part B Medicare Providers
Hot-Spot Focus Category
17000 17004 17110 17311 amp 17312 Destruction of Lesions and Mohs Examination of Specimens
MR Tip MOHS has very specific guidelines Must follow guidance in codebook Pathologist amp Surgeon bill at the same time so be clear on who is billing what The most common mistake is usually no pathology report
29 CPT only copyright 2012 American Medical Association
All rights reserved
Hot Topics and Reminders
30
Enrollment Application Status
Interactive Voice Response (IVR) Unit
Use DCN number or PTAN associated with that provider enrollment application
Status information updated approximately 24 hours after each transaction
552015 31
ROADTO10ORG
552015 32
ICD-10 ndash Resources
October 1 2015
552015 34
bull httpwwwcmsgovMedicareCodingICD10indexhtmlredirect=icd10
ICD-10 - CMS
bull httpwwwpalmettogbacompalmettoicdnsfDocsCatHomeICD-10
ICD-10
Palmetto GBA
News to Use and Resources
35
GBD Blog and Twitter
Palmetto GBA is using the Going Beyond Diagnosis (GBD) blog and Twitter account to help facilitate communication on error rate reduction
httppalmgbacomgbd
BeyondDx
552015 36
Provider Enrollment Open House Available the First Tuesday of the Month
Palmetto GBArsquos Provider Enrollment Department holds an open house at our Palmetto GBA office located at 17 Technology Circle Columbia South Carolina 29203 the first Tuesday of each month This open house is for any of Palmetto GBArsquos J11 Part B providers who would like to stop by and receive answers to their questions concerning their Medicare provider enrollment applications
Self Service Tools
552015 39
wwwPalmettoGBAcomJ11B
OPS ndash New Features
Submission of documentation to satisfy an Additional Documentation Response (ADR)
Unlimited PDF attachments (each up to 40 MB for a maximum total of 150MB)
Select lsquoMedical Reviewrsquo then lsquoMR ADR Responsersquo form
552015 40
New OPS Feature
Get Your First-Level Appeal Letters Delivered Electronically
Palmetto GBA now offers an eDelivery option for receiving your redetermination decision letters electronically Imagine getting your Medicare
redetermination notices (MRNs) the same day that they are issued delivered directly to your computer You even can choose to get an email to let you know that the letter
is waiting for you
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Evaluation and Management Services
Categorized into different settings depending on where the service is furnished Examples of settings include
Office or other outpatient setting
Hospital inpatient
Emergency department (ED)
Nursing facility (NF)
17
Why are Errors Occurring
bull Insufficient documentation
bull No response to documentation request
bull Illegible
bull Documentation for wrong patient or date of service submitted
bull Documentation does not support level of EM billed
bull Documentation does not adequately describe the service defined by the CPTHPCS code or HCPCS modifier billed
Signature issues - no signature (or no legible signature) and no signature log or attestation submitted
bull Does not meet key elements - medical decision making history or physical exam for billed EM service level
18
Evaluation amp Management
19
Great teaching tool
Printing Options
EM Help Center
20
EM Weekly Tips
21
CERT Tips
Review denials
Submit missing documentation directly to CERT if denial is not a medical necessity denial
Appeal medical necessity denials
‒ CERT Redetermination Request Form
Designate a CERT ldquoPoint of Contactrdquo (POC)
httpswwwcertprovidercom
552015 22
Medical Review Spotlight
23
CERT vs Palmetto GBA Medical Reviews
bull CERT
ndash Traditionally conducts post-payment reviews ndash after the claim has finalized
ndash CERT contractor selects claim sample requests records and completes the review
ndash Failure to respond to a CERT record request may result in a contact from Palmetto GBA to assist the CERT in obtaining the records
bull Palmetto GBA
ndash Medical reviews can be pre-payment or post-payment reviews
ndash Palmetto GBA selects the claim sample sends the request for medical records and completes the reviews
ndash Based on a service specific review MR may conduct a provider-specific review
24
Active Medical Reviews
552015 25
httpwwwpalmettogbacompalmettoprovidersnsfDocsCatProviders~Jurisdiction201120Part20B~Medical20Review~General~9NNJBX6701openampnavmenu=Medical^Review||||
Comparative Billing Report (CBR)
Developed by eGlobalTech (eGT) and Palmetto GBA
National CBR on use of modifier 25 by providers under family practice specialty code
CBR contains data-driven tables and graphs with an explanation of findings that compare providers billing patterns to those of their peers in the state and across the nation for claims filed with Modifier 25
httpwwwcbrinfonetcbr201409html
552015 26
Medical Review Strategy
ldquoThe Listrdquo ndash Part B
Drugs and Biologicals
Evaluation amp Management
Laboratory
Emergency Department Visits
New Providers
Hot-Spot Focus Category
27
Medical Review Strategy
Laboratory
82542 ndash Column ChromatographyMass Spectrometry
Drug testing for opioid heroin etc (costs)
Can not have standing orders for this(med necc must be specific)
Emergency Department Visits (non-signature)
99283 ndash Emergency Department Visit for the EampM of a Patient - Expanded
99284 ndash Emergency Department Visit for the EampM of a Patient - Detailed
99285 ndash Emergency Department Visit for the EampM of a Patient - Comprehensive
28 CPT only copyright 2012 American Medical Association
All rights reserved
Medical Review Strategy
New Providers
New Part B Medicare Providers
Hot-Spot Focus Category
17000 17004 17110 17311 amp 17312 Destruction of Lesions and Mohs Examination of Specimens
MR Tip MOHS has very specific guidelines Must follow guidance in codebook Pathologist amp Surgeon bill at the same time so be clear on who is billing what The most common mistake is usually no pathology report
29 CPT only copyright 2012 American Medical Association
All rights reserved
Hot Topics and Reminders
30
Enrollment Application Status
Interactive Voice Response (IVR) Unit
Use DCN number or PTAN associated with that provider enrollment application
Status information updated approximately 24 hours after each transaction
552015 31
ROADTO10ORG
552015 32
ICD-10 ndash Resources
October 1 2015
552015 34
bull httpwwwcmsgovMedicareCodingICD10indexhtmlredirect=icd10
ICD-10 - CMS
bull httpwwwpalmettogbacompalmettoicdnsfDocsCatHomeICD-10
ICD-10
Palmetto GBA
News to Use and Resources
35
GBD Blog and Twitter
Palmetto GBA is using the Going Beyond Diagnosis (GBD) blog and Twitter account to help facilitate communication on error rate reduction
httppalmgbacomgbd
BeyondDx
552015 36
Provider Enrollment Open House Available the First Tuesday of the Month
Palmetto GBArsquos Provider Enrollment Department holds an open house at our Palmetto GBA office located at 17 Technology Circle Columbia South Carolina 29203 the first Tuesday of each month This open house is for any of Palmetto GBArsquos J11 Part B providers who would like to stop by and receive answers to their questions concerning their Medicare provider enrollment applications
Self Service Tools
552015 39
wwwPalmettoGBAcomJ11B
OPS ndash New Features
Submission of documentation to satisfy an Additional Documentation Response (ADR)
Unlimited PDF attachments (each up to 40 MB for a maximum total of 150MB)
Select lsquoMedical Reviewrsquo then lsquoMR ADR Responsersquo form
552015 40
New OPS Feature
Get Your First-Level Appeal Letters Delivered Electronically
Palmetto GBA now offers an eDelivery option for receiving your redetermination decision letters electronically Imagine getting your Medicare
redetermination notices (MRNs) the same day that they are issued delivered directly to your computer You even can choose to get an email to let you know that the letter
is waiting for you
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Why are Errors Occurring
bull Insufficient documentation
bull No response to documentation request
bull Illegible
bull Documentation for wrong patient or date of service submitted
bull Documentation does not support level of EM billed
bull Documentation does not adequately describe the service defined by the CPTHPCS code or HCPCS modifier billed
Signature issues - no signature (or no legible signature) and no signature log or attestation submitted
bull Does not meet key elements - medical decision making history or physical exam for billed EM service level
18
Evaluation amp Management
19
Great teaching tool
Printing Options
EM Help Center
20
EM Weekly Tips
21
CERT Tips
Review denials
Submit missing documentation directly to CERT if denial is not a medical necessity denial
Appeal medical necessity denials
‒ CERT Redetermination Request Form
Designate a CERT ldquoPoint of Contactrdquo (POC)
httpswwwcertprovidercom
552015 22
Medical Review Spotlight
23
CERT vs Palmetto GBA Medical Reviews
bull CERT
ndash Traditionally conducts post-payment reviews ndash after the claim has finalized
ndash CERT contractor selects claim sample requests records and completes the review
ndash Failure to respond to a CERT record request may result in a contact from Palmetto GBA to assist the CERT in obtaining the records
bull Palmetto GBA
ndash Medical reviews can be pre-payment or post-payment reviews
ndash Palmetto GBA selects the claim sample sends the request for medical records and completes the reviews
ndash Based on a service specific review MR may conduct a provider-specific review
24
Active Medical Reviews
552015 25
httpwwwpalmettogbacompalmettoprovidersnsfDocsCatProviders~Jurisdiction201120Part20B~Medical20Review~General~9NNJBX6701openampnavmenu=Medical^Review||||
Comparative Billing Report (CBR)
Developed by eGlobalTech (eGT) and Palmetto GBA
National CBR on use of modifier 25 by providers under family practice specialty code
CBR contains data-driven tables and graphs with an explanation of findings that compare providers billing patterns to those of their peers in the state and across the nation for claims filed with Modifier 25
httpwwwcbrinfonetcbr201409html
552015 26
Medical Review Strategy
ldquoThe Listrdquo ndash Part B
Drugs and Biologicals
Evaluation amp Management
Laboratory
Emergency Department Visits
New Providers
Hot-Spot Focus Category
27
Medical Review Strategy
Laboratory
82542 ndash Column ChromatographyMass Spectrometry
Drug testing for opioid heroin etc (costs)
Can not have standing orders for this(med necc must be specific)
Emergency Department Visits (non-signature)
99283 ndash Emergency Department Visit for the EampM of a Patient - Expanded
99284 ndash Emergency Department Visit for the EampM of a Patient - Detailed
99285 ndash Emergency Department Visit for the EampM of a Patient - Comprehensive
28 CPT only copyright 2012 American Medical Association
All rights reserved
Medical Review Strategy
New Providers
New Part B Medicare Providers
Hot-Spot Focus Category
17000 17004 17110 17311 amp 17312 Destruction of Lesions and Mohs Examination of Specimens
MR Tip MOHS has very specific guidelines Must follow guidance in codebook Pathologist amp Surgeon bill at the same time so be clear on who is billing what The most common mistake is usually no pathology report
29 CPT only copyright 2012 American Medical Association
All rights reserved
Hot Topics and Reminders
30
Enrollment Application Status
Interactive Voice Response (IVR) Unit
Use DCN number or PTAN associated with that provider enrollment application
Status information updated approximately 24 hours after each transaction
552015 31
ROADTO10ORG
552015 32
ICD-10 ndash Resources
October 1 2015
552015 34
bull httpwwwcmsgovMedicareCodingICD10indexhtmlredirect=icd10
ICD-10 - CMS
bull httpwwwpalmettogbacompalmettoicdnsfDocsCatHomeICD-10
ICD-10
Palmetto GBA
News to Use and Resources
35
GBD Blog and Twitter
Palmetto GBA is using the Going Beyond Diagnosis (GBD) blog and Twitter account to help facilitate communication on error rate reduction
httppalmgbacomgbd
BeyondDx
552015 36
Provider Enrollment Open House Available the First Tuesday of the Month
Palmetto GBArsquos Provider Enrollment Department holds an open house at our Palmetto GBA office located at 17 Technology Circle Columbia South Carolina 29203 the first Tuesday of each month This open house is for any of Palmetto GBArsquos J11 Part B providers who would like to stop by and receive answers to their questions concerning their Medicare provider enrollment applications
Self Service Tools
552015 39
wwwPalmettoGBAcomJ11B
OPS ndash New Features
Submission of documentation to satisfy an Additional Documentation Response (ADR)
Unlimited PDF attachments (each up to 40 MB for a maximum total of 150MB)
Select lsquoMedical Reviewrsquo then lsquoMR ADR Responsersquo form
552015 40
New OPS Feature
Get Your First-Level Appeal Letters Delivered Electronically
Palmetto GBA now offers an eDelivery option for receiving your redetermination decision letters electronically Imagine getting your Medicare
redetermination notices (MRNs) the same day that they are issued delivered directly to your computer You even can choose to get an email to let you know that the letter
is waiting for you
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Evaluation amp Management
19
Great teaching tool
Printing Options
EM Help Center
20
EM Weekly Tips
21
CERT Tips
Review denials
Submit missing documentation directly to CERT if denial is not a medical necessity denial
Appeal medical necessity denials
‒ CERT Redetermination Request Form
Designate a CERT ldquoPoint of Contactrdquo (POC)
httpswwwcertprovidercom
552015 22
Medical Review Spotlight
23
CERT vs Palmetto GBA Medical Reviews
bull CERT
ndash Traditionally conducts post-payment reviews ndash after the claim has finalized
ndash CERT contractor selects claim sample requests records and completes the review
ndash Failure to respond to a CERT record request may result in a contact from Palmetto GBA to assist the CERT in obtaining the records
bull Palmetto GBA
ndash Medical reviews can be pre-payment or post-payment reviews
ndash Palmetto GBA selects the claim sample sends the request for medical records and completes the reviews
ndash Based on a service specific review MR may conduct a provider-specific review
24
Active Medical Reviews
552015 25
httpwwwpalmettogbacompalmettoprovidersnsfDocsCatProviders~Jurisdiction201120Part20B~Medical20Review~General~9NNJBX6701openampnavmenu=Medical^Review||||
Comparative Billing Report (CBR)
Developed by eGlobalTech (eGT) and Palmetto GBA
National CBR on use of modifier 25 by providers under family practice specialty code
CBR contains data-driven tables and graphs with an explanation of findings that compare providers billing patterns to those of their peers in the state and across the nation for claims filed with Modifier 25
httpwwwcbrinfonetcbr201409html
552015 26
Medical Review Strategy
ldquoThe Listrdquo ndash Part B
Drugs and Biologicals
Evaluation amp Management
Laboratory
Emergency Department Visits
New Providers
Hot-Spot Focus Category
27
Medical Review Strategy
Laboratory
82542 ndash Column ChromatographyMass Spectrometry
Drug testing for opioid heroin etc (costs)
Can not have standing orders for this(med necc must be specific)
Emergency Department Visits (non-signature)
99283 ndash Emergency Department Visit for the EampM of a Patient - Expanded
99284 ndash Emergency Department Visit for the EampM of a Patient - Detailed
99285 ndash Emergency Department Visit for the EampM of a Patient - Comprehensive
28 CPT only copyright 2012 American Medical Association
All rights reserved
Medical Review Strategy
New Providers
New Part B Medicare Providers
Hot-Spot Focus Category
17000 17004 17110 17311 amp 17312 Destruction of Lesions and Mohs Examination of Specimens
MR Tip MOHS has very specific guidelines Must follow guidance in codebook Pathologist amp Surgeon bill at the same time so be clear on who is billing what The most common mistake is usually no pathology report
29 CPT only copyright 2012 American Medical Association
All rights reserved
Hot Topics and Reminders
30
Enrollment Application Status
Interactive Voice Response (IVR) Unit
Use DCN number or PTAN associated with that provider enrollment application
Status information updated approximately 24 hours after each transaction
552015 31
ROADTO10ORG
552015 32
ICD-10 ndash Resources
October 1 2015
552015 34
bull httpwwwcmsgovMedicareCodingICD10indexhtmlredirect=icd10
ICD-10 - CMS
bull httpwwwpalmettogbacompalmettoicdnsfDocsCatHomeICD-10
ICD-10
Palmetto GBA
News to Use and Resources
35
GBD Blog and Twitter
Palmetto GBA is using the Going Beyond Diagnosis (GBD) blog and Twitter account to help facilitate communication on error rate reduction
httppalmgbacomgbd
BeyondDx
552015 36
Provider Enrollment Open House Available the First Tuesday of the Month
Palmetto GBArsquos Provider Enrollment Department holds an open house at our Palmetto GBA office located at 17 Technology Circle Columbia South Carolina 29203 the first Tuesday of each month This open house is for any of Palmetto GBArsquos J11 Part B providers who would like to stop by and receive answers to their questions concerning their Medicare provider enrollment applications
Self Service Tools
552015 39
wwwPalmettoGBAcomJ11B
OPS ndash New Features
Submission of documentation to satisfy an Additional Documentation Response (ADR)
Unlimited PDF attachments (each up to 40 MB for a maximum total of 150MB)
Select lsquoMedical Reviewrsquo then lsquoMR ADR Responsersquo form
552015 40
New OPS Feature
Get Your First-Level Appeal Letters Delivered Electronically
Palmetto GBA now offers an eDelivery option for receiving your redetermination decision letters electronically Imagine getting your Medicare
redetermination notices (MRNs) the same day that they are issued delivered directly to your computer You even can choose to get an email to let you know that the letter
is waiting for you
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
EM Help Center
20
EM Weekly Tips
21
CERT Tips
Review denials
Submit missing documentation directly to CERT if denial is not a medical necessity denial
Appeal medical necessity denials
‒ CERT Redetermination Request Form
Designate a CERT ldquoPoint of Contactrdquo (POC)
httpswwwcertprovidercom
552015 22
Medical Review Spotlight
23
CERT vs Palmetto GBA Medical Reviews
bull CERT
ndash Traditionally conducts post-payment reviews ndash after the claim has finalized
ndash CERT contractor selects claim sample requests records and completes the review
ndash Failure to respond to a CERT record request may result in a contact from Palmetto GBA to assist the CERT in obtaining the records
bull Palmetto GBA
ndash Medical reviews can be pre-payment or post-payment reviews
ndash Palmetto GBA selects the claim sample sends the request for medical records and completes the reviews
ndash Based on a service specific review MR may conduct a provider-specific review
24
Active Medical Reviews
552015 25
httpwwwpalmettogbacompalmettoprovidersnsfDocsCatProviders~Jurisdiction201120Part20B~Medical20Review~General~9NNJBX6701openampnavmenu=Medical^Review||||
Comparative Billing Report (CBR)
Developed by eGlobalTech (eGT) and Palmetto GBA
National CBR on use of modifier 25 by providers under family practice specialty code
CBR contains data-driven tables and graphs with an explanation of findings that compare providers billing patterns to those of their peers in the state and across the nation for claims filed with Modifier 25
httpwwwcbrinfonetcbr201409html
552015 26
Medical Review Strategy
ldquoThe Listrdquo ndash Part B
Drugs and Biologicals
Evaluation amp Management
Laboratory
Emergency Department Visits
New Providers
Hot-Spot Focus Category
27
Medical Review Strategy
Laboratory
82542 ndash Column ChromatographyMass Spectrometry
Drug testing for opioid heroin etc (costs)
Can not have standing orders for this(med necc must be specific)
Emergency Department Visits (non-signature)
99283 ndash Emergency Department Visit for the EampM of a Patient - Expanded
99284 ndash Emergency Department Visit for the EampM of a Patient - Detailed
99285 ndash Emergency Department Visit for the EampM of a Patient - Comprehensive
28 CPT only copyright 2012 American Medical Association
All rights reserved
Medical Review Strategy
New Providers
New Part B Medicare Providers
Hot-Spot Focus Category
17000 17004 17110 17311 amp 17312 Destruction of Lesions and Mohs Examination of Specimens
MR Tip MOHS has very specific guidelines Must follow guidance in codebook Pathologist amp Surgeon bill at the same time so be clear on who is billing what The most common mistake is usually no pathology report
29 CPT only copyright 2012 American Medical Association
All rights reserved
Hot Topics and Reminders
30
Enrollment Application Status
Interactive Voice Response (IVR) Unit
Use DCN number or PTAN associated with that provider enrollment application
Status information updated approximately 24 hours after each transaction
552015 31
ROADTO10ORG
552015 32
ICD-10 ndash Resources
October 1 2015
552015 34
bull httpwwwcmsgovMedicareCodingICD10indexhtmlredirect=icd10
ICD-10 - CMS
bull httpwwwpalmettogbacompalmettoicdnsfDocsCatHomeICD-10
ICD-10
Palmetto GBA
News to Use and Resources
35
GBD Blog and Twitter
Palmetto GBA is using the Going Beyond Diagnosis (GBD) blog and Twitter account to help facilitate communication on error rate reduction
httppalmgbacomgbd
BeyondDx
552015 36
Provider Enrollment Open House Available the First Tuesday of the Month
Palmetto GBArsquos Provider Enrollment Department holds an open house at our Palmetto GBA office located at 17 Technology Circle Columbia South Carolina 29203 the first Tuesday of each month This open house is for any of Palmetto GBArsquos J11 Part B providers who would like to stop by and receive answers to their questions concerning their Medicare provider enrollment applications
Self Service Tools
552015 39
wwwPalmettoGBAcomJ11B
OPS ndash New Features
Submission of documentation to satisfy an Additional Documentation Response (ADR)
Unlimited PDF attachments (each up to 40 MB for a maximum total of 150MB)
Select lsquoMedical Reviewrsquo then lsquoMR ADR Responsersquo form
552015 40
New OPS Feature
Get Your First-Level Appeal Letters Delivered Electronically
Palmetto GBA now offers an eDelivery option for receiving your redetermination decision letters electronically Imagine getting your Medicare
redetermination notices (MRNs) the same day that they are issued delivered directly to your computer You even can choose to get an email to let you know that the letter
is waiting for you
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
EM Weekly Tips
21
CERT Tips
Review denials
Submit missing documentation directly to CERT if denial is not a medical necessity denial
Appeal medical necessity denials
‒ CERT Redetermination Request Form
Designate a CERT ldquoPoint of Contactrdquo (POC)
httpswwwcertprovidercom
552015 22
Medical Review Spotlight
23
CERT vs Palmetto GBA Medical Reviews
bull CERT
ndash Traditionally conducts post-payment reviews ndash after the claim has finalized
ndash CERT contractor selects claim sample requests records and completes the review
ndash Failure to respond to a CERT record request may result in a contact from Palmetto GBA to assist the CERT in obtaining the records
bull Palmetto GBA
ndash Medical reviews can be pre-payment or post-payment reviews
ndash Palmetto GBA selects the claim sample sends the request for medical records and completes the reviews
ndash Based on a service specific review MR may conduct a provider-specific review
24
Active Medical Reviews
552015 25
httpwwwpalmettogbacompalmettoprovidersnsfDocsCatProviders~Jurisdiction201120Part20B~Medical20Review~General~9NNJBX6701openampnavmenu=Medical^Review||||
Comparative Billing Report (CBR)
Developed by eGlobalTech (eGT) and Palmetto GBA
National CBR on use of modifier 25 by providers under family practice specialty code
CBR contains data-driven tables and graphs with an explanation of findings that compare providers billing patterns to those of their peers in the state and across the nation for claims filed with Modifier 25
httpwwwcbrinfonetcbr201409html
552015 26
Medical Review Strategy
ldquoThe Listrdquo ndash Part B
Drugs and Biologicals
Evaluation amp Management
Laboratory
Emergency Department Visits
New Providers
Hot-Spot Focus Category
27
Medical Review Strategy
Laboratory
82542 ndash Column ChromatographyMass Spectrometry
Drug testing for opioid heroin etc (costs)
Can not have standing orders for this(med necc must be specific)
Emergency Department Visits (non-signature)
99283 ndash Emergency Department Visit for the EampM of a Patient - Expanded
99284 ndash Emergency Department Visit for the EampM of a Patient - Detailed
99285 ndash Emergency Department Visit for the EampM of a Patient - Comprehensive
28 CPT only copyright 2012 American Medical Association
All rights reserved
Medical Review Strategy
New Providers
New Part B Medicare Providers
Hot-Spot Focus Category
17000 17004 17110 17311 amp 17312 Destruction of Lesions and Mohs Examination of Specimens
MR Tip MOHS has very specific guidelines Must follow guidance in codebook Pathologist amp Surgeon bill at the same time so be clear on who is billing what The most common mistake is usually no pathology report
29 CPT only copyright 2012 American Medical Association
All rights reserved
Hot Topics and Reminders
30
Enrollment Application Status
Interactive Voice Response (IVR) Unit
Use DCN number or PTAN associated with that provider enrollment application
Status information updated approximately 24 hours after each transaction
552015 31
ROADTO10ORG
552015 32
ICD-10 ndash Resources
October 1 2015
552015 34
bull httpwwwcmsgovMedicareCodingICD10indexhtmlredirect=icd10
ICD-10 - CMS
bull httpwwwpalmettogbacompalmettoicdnsfDocsCatHomeICD-10
ICD-10
Palmetto GBA
News to Use and Resources
35
GBD Blog and Twitter
Palmetto GBA is using the Going Beyond Diagnosis (GBD) blog and Twitter account to help facilitate communication on error rate reduction
httppalmgbacomgbd
BeyondDx
552015 36
Provider Enrollment Open House Available the First Tuesday of the Month
Palmetto GBArsquos Provider Enrollment Department holds an open house at our Palmetto GBA office located at 17 Technology Circle Columbia South Carolina 29203 the first Tuesday of each month This open house is for any of Palmetto GBArsquos J11 Part B providers who would like to stop by and receive answers to their questions concerning their Medicare provider enrollment applications
Self Service Tools
552015 39
wwwPalmettoGBAcomJ11B
OPS ndash New Features
Submission of documentation to satisfy an Additional Documentation Response (ADR)
Unlimited PDF attachments (each up to 40 MB for a maximum total of 150MB)
Select lsquoMedical Reviewrsquo then lsquoMR ADR Responsersquo form
552015 40
New OPS Feature
Get Your First-Level Appeal Letters Delivered Electronically
Palmetto GBA now offers an eDelivery option for receiving your redetermination decision letters electronically Imagine getting your Medicare
redetermination notices (MRNs) the same day that they are issued delivered directly to your computer You even can choose to get an email to let you know that the letter
is waiting for you
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
CERT Tips
Review denials
Submit missing documentation directly to CERT if denial is not a medical necessity denial
Appeal medical necessity denials
‒ CERT Redetermination Request Form
Designate a CERT ldquoPoint of Contactrdquo (POC)
httpswwwcertprovidercom
552015 22
Medical Review Spotlight
23
CERT vs Palmetto GBA Medical Reviews
bull CERT
ndash Traditionally conducts post-payment reviews ndash after the claim has finalized
ndash CERT contractor selects claim sample requests records and completes the review
ndash Failure to respond to a CERT record request may result in a contact from Palmetto GBA to assist the CERT in obtaining the records
bull Palmetto GBA
ndash Medical reviews can be pre-payment or post-payment reviews
ndash Palmetto GBA selects the claim sample sends the request for medical records and completes the reviews
ndash Based on a service specific review MR may conduct a provider-specific review
24
Active Medical Reviews
552015 25
httpwwwpalmettogbacompalmettoprovidersnsfDocsCatProviders~Jurisdiction201120Part20B~Medical20Review~General~9NNJBX6701openampnavmenu=Medical^Review||||
Comparative Billing Report (CBR)
Developed by eGlobalTech (eGT) and Palmetto GBA
National CBR on use of modifier 25 by providers under family practice specialty code
CBR contains data-driven tables and graphs with an explanation of findings that compare providers billing patterns to those of their peers in the state and across the nation for claims filed with Modifier 25
httpwwwcbrinfonetcbr201409html
552015 26
Medical Review Strategy
ldquoThe Listrdquo ndash Part B
Drugs and Biologicals
Evaluation amp Management
Laboratory
Emergency Department Visits
New Providers
Hot-Spot Focus Category
27
Medical Review Strategy
Laboratory
82542 ndash Column ChromatographyMass Spectrometry
Drug testing for opioid heroin etc (costs)
Can not have standing orders for this(med necc must be specific)
Emergency Department Visits (non-signature)
99283 ndash Emergency Department Visit for the EampM of a Patient - Expanded
99284 ndash Emergency Department Visit for the EampM of a Patient - Detailed
99285 ndash Emergency Department Visit for the EampM of a Patient - Comprehensive
28 CPT only copyright 2012 American Medical Association
All rights reserved
Medical Review Strategy
New Providers
New Part B Medicare Providers
Hot-Spot Focus Category
17000 17004 17110 17311 amp 17312 Destruction of Lesions and Mohs Examination of Specimens
MR Tip MOHS has very specific guidelines Must follow guidance in codebook Pathologist amp Surgeon bill at the same time so be clear on who is billing what The most common mistake is usually no pathology report
29 CPT only copyright 2012 American Medical Association
All rights reserved
Hot Topics and Reminders
30
Enrollment Application Status
Interactive Voice Response (IVR) Unit
Use DCN number or PTAN associated with that provider enrollment application
Status information updated approximately 24 hours after each transaction
552015 31
ROADTO10ORG
552015 32
ICD-10 ndash Resources
October 1 2015
552015 34
bull httpwwwcmsgovMedicareCodingICD10indexhtmlredirect=icd10
ICD-10 - CMS
bull httpwwwpalmettogbacompalmettoicdnsfDocsCatHomeICD-10
ICD-10
Palmetto GBA
News to Use and Resources
35
GBD Blog and Twitter
Palmetto GBA is using the Going Beyond Diagnosis (GBD) blog and Twitter account to help facilitate communication on error rate reduction
httppalmgbacomgbd
BeyondDx
552015 36
Provider Enrollment Open House Available the First Tuesday of the Month
Palmetto GBArsquos Provider Enrollment Department holds an open house at our Palmetto GBA office located at 17 Technology Circle Columbia South Carolina 29203 the first Tuesday of each month This open house is for any of Palmetto GBArsquos J11 Part B providers who would like to stop by and receive answers to their questions concerning their Medicare provider enrollment applications
Self Service Tools
552015 39
wwwPalmettoGBAcomJ11B
OPS ndash New Features
Submission of documentation to satisfy an Additional Documentation Response (ADR)
Unlimited PDF attachments (each up to 40 MB for a maximum total of 150MB)
Select lsquoMedical Reviewrsquo then lsquoMR ADR Responsersquo form
552015 40
New OPS Feature
Get Your First-Level Appeal Letters Delivered Electronically
Palmetto GBA now offers an eDelivery option for receiving your redetermination decision letters electronically Imagine getting your Medicare
redetermination notices (MRNs) the same day that they are issued delivered directly to your computer You even can choose to get an email to let you know that the letter
is waiting for you
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Medical Review Spotlight
23
CERT vs Palmetto GBA Medical Reviews
bull CERT
ndash Traditionally conducts post-payment reviews ndash after the claim has finalized
ndash CERT contractor selects claim sample requests records and completes the review
ndash Failure to respond to a CERT record request may result in a contact from Palmetto GBA to assist the CERT in obtaining the records
bull Palmetto GBA
ndash Medical reviews can be pre-payment or post-payment reviews
ndash Palmetto GBA selects the claim sample sends the request for medical records and completes the reviews
ndash Based on a service specific review MR may conduct a provider-specific review
24
Active Medical Reviews
552015 25
httpwwwpalmettogbacompalmettoprovidersnsfDocsCatProviders~Jurisdiction201120Part20B~Medical20Review~General~9NNJBX6701openampnavmenu=Medical^Review||||
Comparative Billing Report (CBR)
Developed by eGlobalTech (eGT) and Palmetto GBA
National CBR on use of modifier 25 by providers under family practice specialty code
CBR contains data-driven tables and graphs with an explanation of findings that compare providers billing patterns to those of their peers in the state and across the nation for claims filed with Modifier 25
httpwwwcbrinfonetcbr201409html
552015 26
Medical Review Strategy
ldquoThe Listrdquo ndash Part B
Drugs and Biologicals
Evaluation amp Management
Laboratory
Emergency Department Visits
New Providers
Hot-Spot Focus Category
27
Medical Review Strategy
Laboratory
82542 ndash Column ChromatographyMass Spectrometry
Drug testing for opioid heroin etc (costs)
Can not have standing orders for this(med necc must be specific)
Emergency Department Visits (non-signature)
99283 ndash Emergency Department Visit for the EampM of a Patient - Expanded
99284 ndash Emergency Department Visit for the EampM of a Patient - Detailed
99285 ndash Emergency Department Visit for the EampM of a Patient - Comprehensive
28 CPT only copyright 2012 American Medical Association
All rights reserved
Medical Review Strategy
New Providers
New Part B Medicare Providers
Hot-Spot Focus Category
17000 17004 17110 17311 amp 17312 Destruction of Lesions and Mohs Examination of Specimens
MR Tip MOHS has very specific guidelines Must follow guidance in codebook Pathologist amp Surgeon bill at the same time so be clear on who is billing what The most common mistake is usually no pathology report
29 CPT only copyright 2012 American Medical Association
All rights reserved
Hot Topics and Reminders
30
Enrollment Application Status
Interactive Voice Response (IVR) Unit
Use DCN number or PTAN associated with that provider enrollment application
Status information updated approximately 24 hours after each transaction
552015 31
ROADTO10ORG
552015 32
ICD-10 ndash Resources
October 1 2015
552015 34
bull httpwwwcmsgovMedicareCodingICD10indexhtmlredirect=icd10
ICD-10 - CMS
bull httpwwwpalmettogbacompalmettoicdnsfDocsCatHomeICD-10
ICD-10
Palmetto GBA
News to Use and Resources
35
GBD Blog and Twitter
Palmetto GBA is using the Going Beyond Diagnosis (GBD) blog and Twitter account to help facilitate communication on error rate reduction
httppalmgbacomgbd
BeyondDx
552015 36
Provider Enrollment Open House Available the First Tuesday of the Month
Palmetto GBArsquos Provider Enrollment Department holds an open house at our Palmetto GBA office located at 17 Technology Circle Columbia South Carolina 29203 the first Tuesday of each month This open house is for any of Palmetto GBArsquos J11 Part B providers who would like to stop by and receive answers to their questions concerning their Medicare provider enrollment applications
Self Service Tools
552015 39
wwwPalmettoGBAcomJ11B
OPS ndash New Features
Submission of documentation to satisfy an Additional Documentation Response (ADR)
Unlimited PDF attachments (each up to 40 MB for a maximum total of 150MB)
Select lsquoMedical Reviewrsquo then lsquoMR ADR Responsersquo form
552015 40
New OPS Feature
Get Your First-Level Appeal Letters Delivered Electronically
Palmetto GBA now offers an eDelivery option for receiving your redetermination decision letters electronically Imagine getting your Medicare
redetermination notices (MRNs) the same day that they are issued delivered directly to your computer You even can choose to get an email to let you know that the letter
is waiting for you
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
CERT vs Palmetto GBA Medical Reviews
bull CERT
ndash Traditionally conducts post-payment reviews ndash after the claim has finalized
ndash CERT contractor selects claim sample requests records and completes the review
ndash Failure to respond to a CERT record request may result in a contact from Palmetto GBA to assist the CERT in obtaining the records
bull Palmetto GBA
ndash Medical reviews can be pre-payment or post-payment reviews
ndash Palmetto GBA selects the claim sample sends the request for medical records and completes the reviews
ndash Based on a service specific review MR may conduct a provider-specific review
24
Active Medical Reviews
552015 25
httpwwwpalmettogbacompalmettoprovidersnsfDocsCatProviders~Jurisdiction201120Part20B~Medical20Review~General~9NNJBX6701openampnavmenu=Medical^Review||||
Comparative Billing Report (CBR)
Developed by eGlobalTech (eGT) and Palmetto GBA
National CBR on use of modifier 25 by providers under family practice specialty code
CBR contains data-driven tables and graphs with an explanation of findings that compare providers billing patterns to those of their peers in the state and across the nation for claims filed with Modifier 25
httpwwwcbrinfonetcbr201409html
552015 26
Medical Review Strategy
ldquoThe Listrdquo ndash Part B
Drugs and Biologicals
Evaluation amp Management
Laboratory
Emergency Department Visits
New Providers
Hot-Spot Focus Category
27
Medical Review Strategy
Laboratory
82542 ndash Column ChromatographyMass Spectrometry
Drug testing for opioid heroin etc (costs)
Can not have standing orders for this(med necc must be specific)
Emergency Department Visits (non-signature)
99283 ndash Emergency Department Visit for the EampM of a Patient - Expanded
99284 ndash Emergency Department Visit for the EampM of a Patient - Detailed
99285 ndash Emergency Department Visit for the EampM of a Patient - Comprehensive
28 CPT only copyright 2012 American Medical Association
All rights reserved
Medical Review Strategy
New Providers
New Part B Medicare Providers
Hot-Spot Focus Category
17000 17004 17110 17311 amp 17312 Destruction of Lesions and Mohs Examination of Specimens
MR Tip MOHS has very specific guidelines Must follow guidance in codebook Pathologist amp Surgeon bill at the same time so be clear on who is billing what The most common mistake is usually no pathology report
29 CPT only copyright 2012 American Medical Association
All rights reserved
Hot Topics and Reminders
30
Enrollment Application Status
Interactive Voice Response (IVR) Unit
Use DCN number or PTAN associated with that provider enrollment application
Status information updated approximately 24 hours after each transaction
552015 31
ROADTO10ORG
552015 32
ICD-10 ndash Resources
October 1 2015
552015 34
bull httpwwwcmsgovMedicareCodingICD10indexhtmlredirect=icd10
ICD-10 - CMS
bull httpwwwpalmettogbacompalmettoicdnsfDocsCatHomeICD-10
ICD-10
Palmetto GBA
News to Use and Resources
35
GBD Blog and Twitter
Palmetto GBA is using the Going Beyond Diagnosis (GBD) blog and Twitter account to help facilitate communication on error rate reduction
httppalmgbacomgbd
BeyondDx
552015 36
Provider Enrollment Open House Available the First Tuesday of the Month
Palmetto GBArsquos Provider Enrollment Department holds an open house at our Palmetto GBA office located at 17 Technology Circle Columbia South Carolina 29203 the first Tuesday of each month This open house is for any of Palmetto GBArsquos J11 Part B providers who would like to stop by and receive answers to their questions concerning their Medicare provider enrollment applications
Self Service Tools
552015 39
wwwPalmettoGBAcomJ11B
OPS ndash New Features
Submission of documentation to satisfy an Additional Documentation Response (ADR)
Unlimited PDF attachments (each up to 40 MB for a maximum total of 150MB)
Select lsquoMedical Reviewrsquo then lsquoMR ADR Responsersquo form
552015 40
New OPS Feature
Get Your First-Level Appeal Letters Delivered Electronically
Palmetto GBA now offers an eDelivery option for receiving your redetermination decision letters electronically Imagine getting your Medicare
redetermination notices (MRNs) the same day that they are issued delivered directly to your computer You even can choose to get an email to let you know that the letter
is waiting for you
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Active Medical Reviews
552015 25
httpwwwpalmettogbacompalmettoprovidersnsfDocsCatProviders~Jurisdiction201120Part20B~Medical20Review~General~9NNJBX6701openampnavmenu=Medical^Review||||
Comparative Billing Report (CBR)
Developed by eGlobalTech (eGT) and Palmetto GBA
National CBR on use of modifier 25 by providers under family practice specialty code
CBR contains data-driven tables and graphs with an explanation of findings that compare providers billing patterns to those of their peers in the state and across the nation for claims filed with Modifier 25
httpwwwcbrinfonetcbr201409html
552015 26
Medical Review Strategy
ldquoThe Listrdquo ndash Part B
Drugs and Biologicals
Evaluation amp Management
Laboratory
Emergency Department Visits
New Providers
Hot-Spot Focus Category
27
Medical Review Strategy
Laboratory
82542 ndash Column ChromatographyMass Spectrometry
Drug testing for opioid heroin etc (costs)
Can not have standing orders for this(med necc must be specific)
Emergency Department Visits (non-signature)
99283 ndash Emergency Department Visit for the EampM of a Patient - Expanded
99284 ndash Emergency Department Visit for the EampM of a Patient - Detailed
99285 ndash Emergency Department Visit for the EampM of a Patient - Comprehensive
28 CPT only copyright 2012 American Medical Association
All rights reserved
Medical Review Strategy
New Providers
New Part B Medicare Providers
Hot-Spot Focus Category
17000 17004 17110 17311 amp 17312 Destruction of Lesions and Mohs Examination of Specimens
MR Tip MOHS has very specific guidelines Must follow guidance in codebook Pathologist amp Surgeon bill at the same time so be clear on who is billing what The most common mistake is usually no pathology report
29 CPT only copyright 2012 American Medical Association
All rights reserved
Hot Topics and Reminders
30
Enrollment Application Status
Interactive Voice Response (IVR) Unit
Use DCN number or PTAN associated with that provider enrollment application
Status information updated approximately 24 hours after each transaction
552015 31
ROADTO10ORG
552015 32
ICD-10 ndash Resources
October 1 2015
552015 34
bull httpwwwcmsgovMedicareCodingICD10indexhtmlredirect=icd10
ICD-10 - CMS
bull httpwwwpalmettogbacompalmettoicdnsfDocsCatHomeICD-10
ICD-10
Palmetto GBA
News to Use and Resources
35
GBD Blog and Twitter
Palmetto GBA is using the Going Beyond Diagnosis (GBD) blog and Twitter account to help facilitate communication on error rate reduction
httppalmgbacomgbd
BeyondDx
552015 36
Provider Enrollment Open House Available the First Tuesday of the Month
Palmetto GBArsquos Provider Enrollment Department holds an open house at our Palmetto GBA office located at 17 Technology Circle Columbia South Carolina 29203 the first Tuesday of each month This open house is for any of Palmetto GBArsquos J11 Part B providers who would like to stop by and receive answers to their questions concerning their Medicare provider enrollment applications
Self Service Tools
552015 39
wwwPalmettoGBAcomJ11B
OPS ndash New Features
Submission of documentation to satisfy an Additional Documentation Response (ADR)
Unlimited PDF attachments (each up to 40 MB for a maximum total of 150MB)
Select lsquoMedical Reviewrsquo then lsquoMR ADR Responsersquo form
552015 40
New OPS Feature
Get Your First-Level Appeal Letters Delivered Electronically
Palmetto GBA now offers an eDelivery option for receiving your redetermination decision letters electronically Imagine getting your Medicare
redetermination notices (MRNs) the same day that they are issued delivered directly to your computer You even can choose to get an email to let you know that the letter
is waiting for you
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Comparative Billing Report (CBR)
Developed by eGlobalTech (eGT) and Palmetto GBA
National CBR on use of modifier 25 by providers under family practice specialty code
CBR contains data-driven tables and graphs with an explanation of findings that compare providers billing patterns to those of their peers in the state and across the nation for claims filed with Modifier 25
httpwwwcbrinfonetcbr201409html
552015 26
Medical Review Strategy
ldquoThe Listrdquo ndash Part B
Drugs and Biologicals
Evaluation amp Management
Laboratory
Emergency Department Visits
New Providers
Hot-Spot Focus Category
27
Medical Review Strategy
Laboratory
82542 ndash Column ChromatographyMass Spectrometry
Drug testing for opioid heroin etc (costs)
Can not have standing orders for this(med necc must be specific)
Emergency Department Visits (non-signature)
99283 ndash Emergency Department Visit for the EampM of a Patient - Expanded
99284 ndash Emergency Department Visit for the EampM of a Patient - Detailed
99285 ndash Emergency Department Visit for the EampM of a Patient - Comprehensive
28 CPT only copyright 2012 American Medical Association
All rights reserved
Medical Review Strategy
New Providers
New Part B Medicare Providers
Hot-Spot Focus Category
17000 17004 17110 17311 amp 17312 Destruction of Lesions and Mohs Examination of Specimens
MR Tip MOHS has very specific guidelines Must follow guidance in codebook Pathologist amp Surgeon bill at the same time so be clear on who is billing what The most common mistake is usually no pathology report
29 CPT only copyright 2012 American Medical Association
All rights reserved
Hot Topics and Reminders
30
Enrollment Application Status
Interactive Voice Response (IVR) Unit
Use DCN number or PTAN associated with that provider enrollment application
Status information updated approximately 24 hours after each transaction
552015 31
ROADTO10ORG
552015 32
ICD-10 ndash Resources
October 1 2015
552015 34
bull httpwwwcmsgovMedicareCodingICD10indexhtmlredirect=icd10
ICD-10 - CMS
bull httpwwwpalmettogbacompalmettoicdnsfDocsCatHomeICD-10
ICD-10
Palmetto GBA
News to Use and Resources
35
GBD Blog and Twitter
Palmetto GBA is using the Going Beyond Diagnosis (GBD) blog and Twitter account to help facilitate communication on error rate reduction
httppalmgbacomgbd
BeyondDx
552015 36
Provider Enrollment Open House Available the First Tuesday of the Month
Palmetto GBArsquos Provider Enrollment Department holds an open house at our Palmetto GBA office located at 17 Technology Circle Columbia South Carolina 29203 the first Tuesday of each month This open house is for any of Palmetto GBArsquos J11 Part B providers who would like to stop by and receive answers to their questions concerning their Medicare provider enrollment applications
Self Service Tools
552015 39
wwwPalmettoGBAcomJ11B
OPS ndash New Features
Submission of documentation to satisfy an Additional Documentation Response (ADR)
Unlimited PDF attachments (each up to 40 MB for a maximum total of 150MB)
Select lsquoMedical Reviewrsquo then lsquoMR ADR Responsersquo form
552015 40
New OPS Feature
Get Your First-Level Appeal Letters Delivered Electronically
Palmetto GBA now offers an eDelivery option for receiving your redetermination decision letters electronically Imagine getting your Medicare
redetermination notices (MRNs) the same day that they are issued delivered directly to your computer You even can choose to get an email to let you know that the letter
is waiting for you
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Medical Review Strategy
ldquoThe Listrdquo ndash Part B
Drugs and Biologicals
Evaluation amp Management
Laboratory
Emergency Department Visits
New Providers
Hot-Spot Focus Category
27
Medical Review Strategy
Laboratory
82542 ndash Column ChromatographyMass Spectrometry
Drug testing for opioid heroin etc (costs)
Can not have standing orders for this(med necc must be specific)
Emergency Department Visits (non-signature)
99283 ndash Emergency Department Visit for the EampM of a Patient - Expanded
99284 ndash Emergency Department Visit for the EampM of a Patient - Detailed
99285 ndash Emergency Department Visit for the EampM of a Patient - Comprehensive
28 CPT only copyright 2012 American Medical Association
All rights reserved
Medical Review Strategy
New Providers
New Part B Medicare Providers
Hot-Spot Focus Category
17000 17004 17110 17311 amp 17312 Destruction of Lesions and Mohs Examination of Specimens
MR Tip MOHS has very specific guidelines Must follow guidance in codebook Pathologist amp Surgeon bill at the same time so be clear on who is billing what The most common mistake is usually no pathology report
29 CPT only copyright 2012 American Medical Association
All rights reserved
Hot Topics and Reminders
30
Enrollment Application Status
Interactive Voice Response (IVR) Unit
Use DCN number or PTAN associated with that provider enrollment application
Status information updated approximately 24 hours after each transaction
552015 31
ROADTO10ORG
552015 32
ICD-10 ndash Resources
October 1 2015
552015 34
bull httpwwwcmsgovMedicareCodingICD10indexhtmlredirect=icd10
ICD-10 - CMS
bull httpwwwpalmettogbacompalmettoicdnsfDocsCatHomeICD-10
ICD-10
Palmetto GBA
News to Use and Resources
35
GBD Blog and Twitter
Palmetto GBA is using the Going Beyond Diagnosis (GBD) blog and Twitter account to help facilitate communication on error rate reduction
httppalmgbacomgbd
BeyondDx
552015 36
Provider Enrollment Open House Available the First Tuesday of the Month
Palmetto GBArsquos Provider Enrollment Department holds an open house at our Palmetto GBA office located at 17 Technology Circle Columbia South Carolina 29203 the first Tuesday of each month This open house is for any of Palmetto GBArsquos J11 Part B providers who would like to stop by and receive answers to their questions concerning their Medicare provider enrollment applications
Self Service Tools
552015 39
wwwPalmettoGBAcomJ11B
OPS ndash New Features
Submission of documentation to satisfy an Additional Documentation Response (ADR)
Unlimited PDF attachments (each up to 40 MB for a maximum total of 150MB)
Select lsquoMedical Reviewrsquo then lsquoMR ADR Responsersquo form
552015 40
New OPS Feature
Get Your First-Level Appeal Letters Delivered Electronically
Palmetto GBA now offers an eDelivery option for receiving your redetermination decision letters electronically Imagine getting your Medicare
redetermination notices (MRNs) the same day that they are issued delivered directly to your computer You even can choose to get an email to let you know that the letter
is waiting for you
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Medical Review Strategy
Laboratory
82542 ndash Column ChromatographyMass Spectrometry
Drug testing for opioid heroin etc (costs)
Can not have standing orders for this(med necc must be specific)
Emergency Department Visits (non-signature)
99283 ndash Emergency Department Visit for the EampM of a Patient - Expanded
99284 ndash Emergency Department Visit for the EampM of a Patient - Detailed
99285 ndash Emergency Department Visit for the EampM of a Patient - Comprehensive
28 CPT only copyright 2012 American Medical Association
All rights reserved
Medical Review Strategy
New Providers
New Part B Medicare Providers
Hot-Spot Focus Category
17000 17004 17110 17311 amp 17312 Destruction of Lesions and Mohs Examination of Specimens
MR Tip MOHS has very specific guidelines Must follow guidance in codebook Pathologist amp Surgeon bill at the same time so be clear on who is billing what The most common mistake is usually no pathology report
29 CPT only copyright 2012 American Medical Association
All rights reserved
Hot Topics and Reminders
30
Enrollment Application Status
Interactive Voice Response (IVR) Unit
Use DCN number or PTAN associated with that provider enrollment application
Status information updated approximately 24 hours after each transaction
552015 31
ROADTO10ORG
552015 32
ICD-10 ndash Resources
October 1 2015
552015 34
bull httpwwwcmsgovMedicareCodingICD10indexhtmlredirect=icd10
ICD-10 - CMS
bull httpwwwpalmettogbacompalmettoicdnsfDocsCatHomeICD-10
ICD-10
Palmetto GBA
News to Use and Resources
35
GBD Blog and Twitter
Palmetto GBA is using the Going Beyond Diagnosis (GBD) blog and Twitter account to help facilitate communication on error rate reduction
httppalmgbacomgbd
BeyondDx
552015 36
Provider Enrollment Open House Available the First Tuesday of the Month
Palmetto GBArsquos Provider Enrollment Department holds an open house at our Palmetto GBA office located at 17 Technology Circle Columbia South Carolina 29203 the first Tuesday of each month This open house is for any of Palmetto GBArsquos J11 Part B providers who would like to stop by and receive answers to their questions concerning their Medicare provider enrollment applications
Self Service Tools
552015 39
wwwPalmettoGBAcomJ11B
OPS ndash New Features
Submission of documentation to satisfy an Additional Documentation Response (ADR)
Unlimited PDF attachments (each up to 40 MB for a maximum total of 150MB)
Select lsquoMedical Reviewrsquo then lsquoMR ADR Responsersquo form
552015 40
New OPS Feature
Get Your First-Level Appeal Letters Delivered Electronically
Palmetto GBA now offers an eDelivery option for receiving your redetermination decision letters electronically Imagine getting your Medicare
redetermination notices (MRNs) the same day that they are issued delivered directly to your computer You even can choose to get an email to let you know that the letter
is waiting for you
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Medical Review Strategy
New Providers
New Part B Medicare Providers
Hot-Spot Focus Category
17000 17004 17110 17311 amp 17312 Destruction of Lesions and Mohs Examination of Specimens
MR Tip MOHS has very specific guidelines Must follow guidance in codebook Pathologist amp Surgeon bill at the same time so be clear on who is billing what The most common mistake is usually no pathology report
29 CPT only copyright 2012 American Medical Association
All rights reserved
Hot Topics and Reminders
30
Enrollment Application Status
Interactive Voice Response (IVR) Unit
Use DCN number or PTAN associated with that provider enrollment application
Status information updated approximately 24 hours after each transaction
552015 31
ROADTO10ORG
552015 32
ICD-10 ndash Resources
October 1 2015
552015 34
bull httpwwwcmsgovMedicareCodingICD10indexhtmlredirect=icd10
ICD-10 - CMS
bull httpwwwpalmettogbacompalmettoicdnsfDocsCatHomeICD-10
ICD-10
Palmetto GBA
News to Use and Resources
35
GBD Blog and Twitter
Palmetto GBA is using the Going Beyond Diagnosis (GBD) blog and Twitter account to help facilitate communication on error rate reduction
httppalmgbacomgbd
BeyondDx
552015 36
Provider Enrollment Open House Available the First Tuesday of the Month
Palmetto GBArsquos Provider Enrollment Department holds an open house at our Palmetto GBA office located at 17 Technology Circle Columbia South Carolina 29203 the first Tuesday of each month This open house is for any of Palmetto GBArsquos J11 Part B providers who would like to stop by and receive answers to their questions concerning their Medicare provider enrollment applications
Self Service Tools
552015 39
wwwPalmettoGBAcomJ11B
OPS ndash New Features
Submission of documentation to satisfy an Additional Documentation Response (ADR)
Unlimited PDF attachments (each up to 40 MB for a maximum total of 150MB)
Select lsquoMedical Reviewrsquo then lsquoMR ADR Responsersquo form
552015 40
New OPS Feature
Get Your First-Level Appeal Letters Delivered Electronically
Palmetto GBA now offers an eDelivery option for receiving your redetermination decision letters electronically Imagine getting your Medicare
redetermination notices (MRNs) the same day that they are issued delivered directly to your computer You even can choose to get an email to let you know that the letter
is waiting for you
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Hot Topics and Reminders
30
Enrollment Application Status
Interactive Voice Response (IVR) Unit
Use DCN number or PTAN associated with that provider enrollment application
Status information updated approximately 24 hours after each transaction
552015 31
ROADTO10ORG
552015 32
ICD-10 ndash Resources
October 1 2015
552015 34
bull httpwwwcmsgovMedicareCodingICD10indexhtmlredirect=icd10
ICD-10 - CMS
bull httpwwwpalmettogbacompalmettoicdnsfDocsCatHomeICD-10
ICD-10
Palmetto GBA
News to Use and Resources
35
GBD Blog and Twitter
Palmetto GBA is using the Going Beyond Diagnosis (GBD) blog and Twitter account to help facilitate communication on error rate reduction
httppalmgbacomgbd
BeyondDx
552015 36
Provider Enrollment Open House Available the First Tuesday of the Month
Palmetto GBArsquos Provider Enrollment Department holds an open house at our Palmetto GBA office located at 17 Technology Circle Columbia South Carolina 29203 the first Tuesday of each month This open house is for any of Palmetto GBArsquos J11 Part B providers who would like to stop by and receive answers to their questions concerning their Medicare provider enrollment applications
Self Service Tools
552015 39
wwwPalmettoGBAcomJ11B
OPS ndash New Features
Submission of documentation to satisfy an Additional Documentation Response (ADR)
Unlimited PDF attachments (each up to 40 MB for a maximum total of 150MB)
Select lsquoMedical Reviewrsquo then lsquoMR ADR Responsersquo form
552015 40
New OPS Feature
Get Your First-Level Appeal Letters Delivered Electronically
Palmetto GBA now offers an eDelivery option for receiving your redetermination decision letters electronically Imagine getting your Medicare
redetermination notices (MRNs) the same day that they are issued delivered directly to your computer You even can choose to get an email to let you know that the letter
is waiting for you
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Enrollment Application Status
Interactive Voice Response (IVR) Unit
Use DCN number or PTAN associated with that provider enrollment application
Status information updated approximately 24 hours after each transaction
552015 31
ROADTO10ORG
552015 32
ICD-10 ndash Resources
October 1 2015
552015 34
bull httpwwwcmsgovMedicareCodingICD10indexhtmlredirect=icd10
ICD-10 - CMS
bull httpwwwpalmettogbacompalmettoicdnsfDocsCatHomeICD-10
ICD-10
Palmetto GBA
News to Use and Resources
35
GBD Blog and Twitter
Palmetto GBA is using the Going Beyond Diagnosis (GBD) blog and Twitter account to help facilitate communication on error rate reduction
httppalmgbacomgbd
BeyondDx
552015 36
Provider Enrollment Open House Available the First Tuesday of the Month
Palmetto GBArsquos Provider Enrollment Department holds an open house at our Palmetto GBA office located at 17 Technology Circle Columbia South Carolina 29203 the first Tuesday of each month This open house is for any of Palmetto GBArsquos J11 Part B providers who would like to stop by and receive answers to their questions concerning their Medicare provider enrollment applications
Self Service Tools
552015 39
wwwPalmettoGBAcomJ11B
OPS ndash New Features
Submission of documentation to satisfy an Additional Documentation Response (ADR)
Unlimited PDF attachments (each up to 40 MB for a maximum total of 150MB)
Select lsquoMedical Reviewrsquo then lsquoMR ADR Responsersquo form
552015 40
New OPS Feature
Get Your First-Level Appeal Letters Delivered Electronically
Palmetto GBA now offers an eDelivery option for receiving your redetermination decision letters electronically Imagine getting your Medicare
redetermination notices (MRNs) the same day that they are issued delivered directly to your computer You even can choose to get an email to let you know that the letter
is waiting for you
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
ROADTO10ORG
552015 32
ICD-10 ndash Resources
October 1 2015
552015 34
bull httpwwwcmsgovMedicareCodingICD10indexhtmlredirect=icd10
ICD-10 - CMS
bull httpwwwpalmettogbacompalmettoicdnsfDocsCatHomeICD-10
ICD-10
Palmetto GBA
News to Use and Resources
35
GBD Blog and Twitter
Palmetto GBA is using the Going Beyond Diagnosis (GBD) blog and Twitter account to help facilitate communication on error rate reduction
httppalmgbacomgbd
BeyondDx
552015 36
Provider Enrollment Open House Available the First Tuesday of the Month
Palmetto GBArsquos Provider Enrollment Department holds an open house at our Palmetto GBA office located at 17 Technology Circle Columbia South Carolina 29203 the first Tuesday of each month This open house is for any of Palmetto GBArsquos J11 Part B providers who would like to stop by and receive answers to their questions concerning their Medicare provider enrollment applications
Self Service Tools
552015 39
wwwPalmettoGBAcomJ11B
OPS ndash New Features
Submission of documentation to satisfy an Additional Documentation Response (ADR)
Unlimited PDF attachments (each up to 40 MB for a maximum total of 150MB)
Select lsquoMedical Reviewrsquo then lsquoMR ADR Responsersquo form
552015 40
New OPS Feature
Get Your First-Level Appeal Letters Delivered Electronically
Palmetto GBA now offers an eDelivery option for receiving your redetermination decision letters electronically Imagine getting your Medicare
redetermination notices (MRNs) the same day that they are issued delivered directly to your computer You even can choose to get an email to let you know that the letter
is waiting for you
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
ICD-10 ndash Resources
October 1 2015
552015 34
bull httpwwwcmsgovMedicareCodingICD10indexhtmlredirect=icd10
ICD-10 - CMS
bull httpwwwpalmettogbacompalmettoicdnsfDocsCatHomeICD-10
ICD-10
Palmetto GBA
News to Use and Resources
35
GBD Blog and Twitter
Palmetto GBA is using the Going Beyond Diagnosis (GBD) blog and Twitter account to help facilitate communication on error rate reduction
httppalmgbacomgbd
BeyondDx
552015 36
Provider Enrollment Open House Available the First Tuesday of the Month
Palmetto GBArsquos Provider Enrollment Department holds an open house at our Palmetto GBA office located at 17 Technology Circle Columbia South Carolina 29203 the first Tuesday of each month This open house is for any of Palmetto GBArsquos J11 Part B providers who would like to stop by and receive answers to their questions concerning their Medicare provider enrollment applications
Self Service Tools
552015 39
wwwPalmettoGBAcomJ11B
OPS ndash New Features
Submission of documentation to satisfy an Additional Documentation Response (ADR)
Unlimited PDF attachments (each up to 40 MB for a maximum total of 150MB)
Select lsquoMedical Reviewrsquo then lsquoMR ADR Responsersquo form
552015 40
New OPS Feature
Get Your First-Level Appeal Letters Delivered Electronically
Palmetto GBA now offers an eDelivery option for receiving your redetermination decision letters electronically Imagine getting your Medicare
redetermination notices (MRNs) the same day that they are issued delivered directly to your computer You even can choose to get an email to let you know that the letter
is waiting for you
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
News to Use and Resources
35
GBD Blog and Twitter
Palmetto GBA is using the Going Beyond Diagnosis (GBD) blog and Twitter account to help facilitate communication on error rate reduction
httppalmgbacomgbd
BeyondDx
552015 36
Provider Enrollment Open House Available the First Tuesday of the Month
Palmetto GBArsquos Provider Enrollment Department holds an open house at our Palmetto GBA office located at 17 Technology Circle Columbia South Carolina 29203 the first Tuesday of each month This open house is for any of Palmetto GBArsquos J11 Part B providers who would like to stop by and receive answers to their questions concerning their Medicare provider enrollment applications
Self Service Tools
552015 39
wwwPalmettoGBAcomJ11B
OPS ndash New Features
Submission of documentation to satisfy an Additional Documentation Response (ADR)
Unlimited PDF attachments (each up to 40 MB for a maximum total of 150MB)
Select lsquoMedical Reviewrsquo then lsquoMR ADR Responsersquo form
552015 40
New OPS Feature
Get Your First-Level Appeal Letters Delivered Electronically
Palmetto GBA now offers an eDelivery option for receiving your redetermination decision letters electronically Imagine getting your Medicare
redetermination notices (MRNs) the same day that they are issued delivered directly to your computer You even can choose to get an email to let you know that the letter
is waiting for you
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
GBD Blog and Twitter
Palmetto GBA is using the Going Beyond Diagnosis (GBD) blog and Twitter account to help facilitate communication on error rate reduction
httppalmgbacomgbd
BeyondDx
552015 36
Provider Enrollment Open House Available the First Tuesday of the Month
Palmetto GBArsquos Provider Enrollment Department holds an open house at our Palmetto GBA office located at 17 Technology Circle Columbia South Carolina 29203 the first Tuesday of each month This open house is for any of Palmetto GBArsquos J11 Part B providers who would like to stop by and receive answers to their questions concerning their Medicare provider enrollment applications
Self Service Tools
552015 39
wwwPalmettoGBAcomJ11B
OPS ndash New Features
Submission of documentation to satisfy an Additional Documentation Response (ADR)
Unlimited PDF attachments (each up to 40 MB for a maximum total of 150MB)
Select lsquoMedical Reviewrsquo then lsquoMR ADR Responsersquo form
552015 40
New OPS Feature
Get Your First-Level Appeal Letters Delivered Electronically
Palmetto GBA now offers an eDelivery option for receiving your redetermination decision letters electronically Imagine getting your Medicare
redetermination notices (MRNs) the same day that they are issued delivered directly to your computer You even can choose to get an email to let you know that the letter
is waiting for you
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Provider Enrollment Open House Available the First Tuesday of the Month
Palmetto GBArsquos Provider Enrollment Department holds an open house at our Palmetto GBA office located at 17 Technology Circle Columbia South Carolina 29203 the first Tuesday of each month This open house is for any of Palmetto GBArsquos J11 Part B providers who would like to stop by and receive answers to their questions concerning their Medicare provider enrollment applications
Self Service Tools
552015 39
wwwPalmettoGBAcomJ11B
OPS ndash New Features
Submission of documentation to satisfy an Additional Documentation Response (ADR)
Unlimited PDF attachments (each up to 40 MB for a maximum total of 150MB)
Select lsquoMedical Reviewrsquo then lsquoMR ADR Responsersquo form
552015 40
New OPS Feature
Get Your First-Level Appeal Letters Delivered Electronically
Palmetto GBA now offers an eDelivery option for receiving your redetermination decision letters electronically Imagine getting your Medicare
redetermination notices (MRNs) the same day that they are issued delivered directly to your computer You even can choose to get an email to let you know that the letter
is waiting for you
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Self Service Tools
552015 39
wwwPalmettoGBAcomJ11B
OPS ndash New Features
Submission of documentation to satisfy an Additional Documentation Response (ADR)
Unlimited PDF attachments (each up to 40 MB for a maximum total of 150MB)
Select lsquoMedical Reviewrsquo then lsquoMR ADR Responsersquo form
552015 40
New OPS Feature
Get Your First-Level Appeal Letters Delivered Electronically
Palmetto GBA now offers an eDelivery option for receiving your redetermination decision letters electronically Imagine getting your Medicare
redetermination notices (MRNs) the same day that they are issued delivered directly to your computer You even can choose to get an email to let you know that the letter
is waiting for you
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
OPS ndash New Features
Submission of documentation to satisfy an Additional Documentation Response (ADR)
Unlimited PDF attachments (each up to 40 MB for a maximum total of 150MB)
Select lsquoMedical Reviewrsquo then lsquoMR ADR Responsersquo form
552015 40
New OPS Feature
Get Your First-Level Appeal Letters Delivered Electronically
Palmetto GBA now offers an eDelivery option for receiving your redetermination decision letters electronically Imagine getting your Medicare
redetermination notices (MRNs) the same day that they are issued delivered directly to your computer You even can choose to get an email to let you know that the letter
is waiting for you
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
New OPS Feature
Get Your First-Level Appeal Letters Delivered Electronically
Palmetto GBA now offers an eDelivery option for receiving your redetermination decision letters electronically Imagine getting your Medicare
redetermination notices (MRNs) the same day that they are issued delivered directly to your computer You even can choose to get an email to let you know that the letter
is waiting for you
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
New OPS Feature
bull To start receiving your Medicare redetermination letters electronically you must be signed up for our Online Provider Services (OPS) tool
bull Once you have signed into OPS and selected Admin a drop-down box will provide you with your eDelivery options Just choose eDelivery to start receiving your letters through OPS You can also select User Email Notification to start receiving emails when your MRN letters are available for you Every choice is so easy and user-friendly
bull Once you have chosen the eDelivery option all of your MRNs will come to you electronically even if you sent in your appeal request via fax or mail
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Additional OPS Features
The OPS application provides information access over the Web for the following online
services bull Eligibility bull Claims Status bull eClaim Submissions bull Remittances Online bull Financial Information - payment floor last three checks
paid eOffset requests and eCheck payments bull Appeals bull Medical Review ADR Response Form bull eDelivery - Receive Paperless Additional Documentation
Requests via your OPS Message Inbox
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Additional OPS Features
All forms currently have a file size limitation of 5 MB per attachment Users may attach up to five files depending on the form Form MR ADR Response forms OPS users may submit attachments up to 40 MB in size While there is no longer a limit to the number of files that can be attached to the form the combined size of all attachments cannot exceed 150 MB in size
Note All attachments must be in PDF format
OPS is our free Internet-based provider self-service portal
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Palmetto GBA Advanced Clinical Editing (P-ACE)
Available at no cost to all direct submitters and those transmitting claims through a clearinghousebilling service
lsquoSmart editsrsquo will appear on claim rejection reports (277CA)
Claims failing the pre-adjudication editing afford providers an opportunity to review the claim for correctness and resubmission or if appropriate modifications can be made to the claim and then resubmitted
There is no software to download
552015 45
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Physician Fee Schedule
Tool
46
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
CMS National and Open Door Calls and E-News National Provider Calls and Events
httpwwwcmsgovOutreach-and-EducationOutreachNPCNational-Provider-Calls-and-Eventshtml
Open Door Forums httpwwwcmsgovOutreach-and-
EducationOutreachOpenDoorForumsindexhtml
bull CMS E-News ‒ httpwwwcmsgovOutreach-and-
EducationOutreachFFSProvPartProgProvider-Partnership-Email-Archivehtml
47
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Claim Processing Issue Log (CPIL)
552015 48
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
49
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Progressive Corrective Action is simply a way of targeting and directing medical review efforts on claims for services where there exists the greatest risk of inappropriate program payments
50
Progressive Corrective Action(PCA)
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
To maximize program protection against inappropriate payments
To decrease the receipt of claims for non-covered or unnecessary services
To educate providers on appropriate practices
Goals of the PCA process
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
To help improve quality of care for beneficiaries
To avoid inconvenience to providers who adhere to program requirements
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Analyze your Remittance Advice to improve future reimbursement
Palmetto GBA encourages all providers to review the top denials when filing claims to prevent denials
Utilize the information to develop a checklist
The checklist can then be used to review documentation and codes prior to filing
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Medical Review Top Denials Rank Denial
Code Denial Description
1 F12
Documentation received contains incorrectincompleteinvalid patient identification or date of service
2 F10 Documentation requested for this date of service was not received or was incomplete
3 630 Payer deems the information submitted does not support Medical Necessity of services billed
4 F26 Claim billed in error per provider
5 F41 Information submitted contains an invalidillegible provider signature
6 F06 Documentation lacks the necessary provider signature
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Medical Review Top Denials Rank Denial
Code Denial Description
7 015 Documentation requested for this date of service was not received or was incomplete
8 093 Information submitted deemed illegible
9 529 Payer deems the information submitted does not support medical necessity of services billed
10 023 Original medical record has been altered
11 022 Documentation requested for this date of service was not received or was incomplete
12 F46 Information submitted contains an invalidillegible provider signature
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
99213 - Office or Other Outpatient Visit for the EampM of an Established Patient Expanded Requires at least 2 out of 3 key components
An expanded problem focused history
An expanded problem focused examination
Medical decision making of low complexity
E amp M Office Visits ndash Established
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Currently under Post ndashpay review
99214 - Office or Other Outpatient Visit for the EampM of an Established Patient Detailed
o Requires at least 2 out of 3 key components
A detailed history
A detailed examination
Medical decision making of moderate complexity
E amp M Office Visits ndash Established
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Office visits continuedhellip
99215 - Office or Other Outpatient Visit for the EampM of an Established Patient
Comprehensive
Requires at least 2 out of 3 key components
o A comprehensive history
o A comprehensive examination
o Medical decision making of high complexity
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Palmetto GBA performed service-specific prepayment targeted medical review on claims for EM code 99233 Subsequent Hospital Inpatient Care (Typically 35 Minutes Per Day)
At the end of the probe North Carolina as a region continued on the probe
Subsequent Hospital Inpatient Care (99233)
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
CPT code 99233 (Subsequent Hospital Care) is used (per day) for the Evaluation and Management (EM) of an established patient Two of these three key components are necessary in order to bill this code
A detailed interval history
A detailed examination
Medical decision making of high complexity
The Components of Subsequent Hospital Care
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
296-NODOC-During education calls it was noted that addresses had not been updated per the 855B form
F12-WRONG-The wrong documentation was submitted
620-Downcode-Level of services billed were not documented therefore services were down-coded
Common Errors included
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Letrsquos look at possible Root Causes of Denialshellip
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
The submitted documentation supports a code that does not support 99233 ie 99231 or 99232
Education calls revealed that most of the check list used during the Emergency Room Visits donrsquot capture the documentation components necessary to bill for 99233
Another discovery was that third party billing companies did not have a process in place to receive medical documentation timely resulting in 296 denials(NODOC)
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Simple Equals Significant Remember that a few simple interventions can
drastically effect the charge denial rate
Make sure you are signed up for the Palmetto GBA listserv to be updated on upcoming probes to be conducted
Assess the chain of communication between billing and documentation submission
Is there someone who reviews the documentation prior to submitting
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
This family of CPT codes are used to report evaluation and management services provided in the emergency department
Palmetto GBA began the probe edits for emergency department for 9928399284 and 99285 in November 2014
Edit effectiveness has been completed for approximately one-half and some expected provider specific complex reviews based on their individual results
Emergency Department Services
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Due the high cost of biologicals and the increasing utilization trends several drugs were identified for review during the upcoming option year All of the drugs selected are categorized as Major Risk per the Part B Prioritization Report
They are the top drugs based on dollars at risk and CERT error rates Some of the top drugs have been excluded due to MAU edits already in place
Drugs ampBiologicals
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
J2778 ndash Ranizumab (Lucentis) Injection 1 mg
J0178 ndash Aflibercept (Eylea) Injection 1 mg
J0897 ndash Denosumab (Prolia) Injection 1 mg
J9041 ndash Bortezomib (Velcade) Injection 1 mg
Edits will be set for the following Medications
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Is the documentation submitted for the correct beneficiary
Is the documentation present for the dates of service billed
Is there documentation of Physician order or intent to administer drug
If the order is present does the order include the dosage of the drug to be administered
The ldquoRight Documentation Prescriptionrdquo for Drugs and Biologicals
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Does the order include the frequency of the drug to be administered
Does the order include the route of the drug to be administered
Is there a physician certified diagnosis submitted in the medical record to substantiate the medical need for the drug
Is the recommended dosing schedule for the covered diagnosis documented in the record
Is documentation present for the administration of drug
Continuedhellip
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Do the units billed correspond with the vials used in documentation submitted for review
Is there a corrected UB indicating all or part of the claim was billed in error
Drugs amp Biological Billing
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Diagnostic Test
A diagnostic test includes all diagnostic x-ray tests all diagnostic laboratory tests and other diagnostic tests furnished to a beneficiary
Letrsquos take a ldquostabrdquo at Labs
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
A treating physician is a physician as defined in sect1861(r) of the Social Security Act (the Act) who furnishes a consultation or treats a beneficiary for a specific medical problem and who uses the results of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Physician
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
A treating practitioner is a nurse practitioner clinical nurse specialist or physician assistant as defined in sect1861(s)(2)(K) of the Act who furnishes pursuant to State law a consultation or treats a beneficiary for a specific medical problem and who uses the result of a diagnostic test in the management of the beneficiarys specific medical problem
Treating Practitioner
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
A testing facility is a Medicare provider or supplier that furnishes diagnostic tests A testing facility may include a physician or a group of physicians (eg radiologist pathologist) a laboratory or an independent diagnostic testing facility (IDTF)
Testing Facility
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
An order is a communication from the treating physicianpractitioner requesting that a diagnostic test be performed for a beneficiary The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physicianpractitioner (eg if test X is negative then perform test Y)
Orders-the missing link
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
An order may be delivered via the following forms of communication
A written document signed by the treating physicianpractitioner which is hand-delivered mailed or faxed to the testing facility
Orders continuedhellip
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
A telephone call by the treating physicianpractitioner or hisher office to the testing facility
An electronic mail by the treating physicianpractitioner or hisher office to the testing facility
If the order is communicated via telephone both the treating physicianpractitioner or hisher office and the testing facility must document the telephone call in their respective copies of the beneficiarys medical records
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
The order or the intent to order is vital and must be included in the medical record
CERT denials related to the billing of the Professional Component due to missing orders or intent to order remains at the top of the list for denials
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
CERT Errors-
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Missing the physician order or clinical documentation of intent of ordering lab
Missing signed and dated clinical documentation to support medical necessity for the lab
Common Errors-
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Medicare contractors do two things when conducting medical reviews or audits of claims submitted by independent labs
Obtain corroborating test results which show the billed services were rendered
Verify that the tests were medically necessary based upon documentation sent to the laboratory by the orderingreferring provider
Medicare Part B Claim Reviews
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Verifying the ordering-treating providerrsquos intent and involvement with requesting the patientrsquos tests is a crucial aspect of establishing medical necessity
The presence of a signed (electronic or otherwise) order by the authorizing provider is often the simplest means by which to validate the tests performed and billed by an independent clinical laboratory however it is not the only means
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
In accordance with the CMS Program Integrity Manual (CMS Pub 100-08) Chapter 3 3412 and 42 CFR sect41032 review contractors must first ask the billing laboratory for relevant records to establish medical necessity
If the laboratory provides a signed order for the test(s) then it is considered confirmation of the physicianrsquosNPPrsquos intent and medical necessity can be determined at this point
Independent Labs
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
If the ordering physicianNPP fails to respond with the necessary documentation the lab services will be denied and the independent clinical laboratory assumes financial responsibility for the overpayment
Therefore it is imperative that lab clients such as ordering physicians NPPs and staff understand their responsibility in documenting and establishing coverage for tests submitted to Medicare contractors
The Lab ldquoglitchrdquohellip
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Develop an action plan to decrease lab denials by-
o Using a tracking system to determine your ldquolabrdquo flowhelliphow is the order transmitted to the lab
o Who reviews the documentation prior to submission for the ldquo 5 Lab rightsrdquo
Lab Partners
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
The right patient
The right date of service
The right documentation
The right order(or intent to order)
The right lab test
The 5 Lab Rights
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
ICD-10
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
ICD-10 Page
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Testing Information
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Related Sites
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
ICD-10 Acknowledgement Testing
National Testing week scheduled
June 1 - 5 2015
Last chance before implementation on 10012015
Unlimited testing
Will receive normal reports 999 277CA
Claims will NOT be processed
Remittances will NOT be created
MLN Matter Article MM8858 provides details
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
End-to-End Testing
National Testing Week Scheduled
July 20 - 24
Limited provider and claims testing
Will receive 999 and 277CA reports
Claims will be processed
Remittances will be created where applicable
Unprocessable Claims(RTP) will be returned
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
ICD-10 Update Successful weeks of provider testing Next End to End testing in late July 20 - 24 PRO32 software is HIPAA compliant and ICD-10
tested Communicate with your clearinghousebilling
service to ensure they are testing and going to be ready to submit your ICD-10 claims in October
Use available resources on CMS website to get the complete list of ICD-10 codes under the downloads section httpwwwcmsgovMedicarecodingICD102015-ICD-10-CM-and-GEMShtml
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
ICD-10 Testing Test a good sampling of all the types of claims that
you currently submit for production including Medicare Secondary Payer(MSP) and Coordination of Benefits(COB)
Consider sending claims that you know should reject ndash negative testing
Submit claims with multiple lines of service
Test specific LCDs and complicated scenarios
Review the 999 and 277CA Response Report Results to ensure your claims accepted or rejected as they should
Report any software issues to your vendor
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Testing Requirements Test claims must be sent to the same contractor as production claims
Test files must use the Submitter ID (Trading Partner ID) used during volunteer registration
Maximum of five NPIs and ten HICNS for each testing week
Claim files must be marked as ldquoTestrdquo in the ISA15 field with a ldquoTrdquo
Test claims with ICD-10 diagnosis codes must be submitted with dates of service on or after October 1 2015 Claims with ICD-9 diagnosis codes should be submitted with dates of service before October 1 2015
Test claim volume is limited to a total of 50 claims for the entire testing week submitted in no more than 3 test files If more than 50 claims are submitted over the course of the testing week they may not be processed
You should receive Electronic Remittance Advice (ERA) files for claims that are processed
ERA files will be marked as ldquotestrdquo files in the ISA15 field with a ldquoTrdquo
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Common Errors to Avoid Only use Submitter Ids NPIs PTANs and HICNs that
you provided for set up
The name and spelling on the claim should match the HICN
Avoid submitting claims for the HICN for the same date of service and procedure
Ensure that your claims have complete information so not to reject for anything not related to ICD-10
Claims with DOS onafter 100115 must have indicator of 0 and claims with DOS onprior to 93015 must have indicator of 9
All claims must have physician and NPIs as required
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Contact Information
EDI Helpdesk hours 800 ndash 500 ET
Telephone number 1-855-696-0705 please listen carefully to the options and have your PTAN NPI and Submitter ID available
Email address for basic questions MedicareediPalmettogbacom
EDI Fax Numbers begin with 803
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Contacts
552015 98
855-696-0705
Provider Contact Center
Resources
Palmetto GBA J11 Part B Home Page
wwwpalmettogbacomj11b
Palmetto GBA E-Mail Updates
wwwpalmettogbacomj11b Select E-MAIL UPDATES
Provider Enrollment Resources
wwwpalmettogbacomj11b Click on lsquoBrowse By Topicrsquo then
lsquoProvider Enrollmentrsquo
Contact Us By Email
J11PartBPalmettoGBAcom
Self Service Tools
wwwpalmettogbacomJ11B (center of home page)
Social Networking
552015 99
Social Networking
552015 99