PARA Weekly Update For Users May 9 2018

Date

PARA WEEKLY

UPDATE For Users

Improving T he Businessof HealthCare Since 1985 May 9, 2018 NEWS FOR HEALTHCARE DECISION MAKERS

IN THIS ISSUE

6

QUESTIONS & ANSWERS - G0444 Depression Screening - Holter Monitoring Coding - Chemotherapy Infusions - Flow Cytometry - Billing For J9203 Gemtuzumab Oncology Drug CMS PROPOSES TO RELAX INPATIENT ORDER REQUIREMENTS USING PARA'S SHARE OF COST WIDGET CMS PROPOSES FOUR RULES FOR FY19 RURAL HOSPITAL PROGRAM GRANTS AVAILABLE: - Community Facilities Technical Assistance and Training - NURSE Corps Scholarships

PARA COMPANY NEWS

SERVICES

ABOUT PARA

CONTACT US

FAST LINKS

-

The number of new or revised Med Learn (MLN Matters) articles released this week. All new and previous Med Learn articles can be viewed under the type "Med Learn", in the Advisor tab of the PARA Dat a Edit or . Click here.

-------------------------------------------------------

The number of new or revised Transmittals released this week. All new and previous Transmittals can be viewed under the type "Transmittals" in the Advisor tab of the PARA Dat a Edit or . Click here.

Administration: Pages 1-33 HIM /Coding Staff: Pages 1-33 Providers: Pages: 2-7 Cardiology: Page 3 Oncology: Pages 5,7 Biotechnology: Page 6 Acute Care Facilities Pages 8-10

10

- Finance Departments: Pages 10,16,21,23-32 - Rural Healthcare: Page 13 - Hospice Services: Pages 12,19 - Telehealth: Page 10 - DM E Services: Pages 17,21 - Inpatient Rehab: Page 12

© PARA Healt h Car e An alyt ics CPT® is a r egist er ed t r adem ar k of t h e Am er ican M edical Associat ion

PARA Weekly Update: May 9, 2018

G0444 DEPRESSION SCREENING

We have two questions regarding our documentation when a depression screening was performed with an E&M code. Please advise on the appropriate CPTÂŽ and modifier coding based on this information.

PARA reviewed your medical records and here are our responses and coding recommendations.

Patient 1: The correct coding for this encounter would be 99395. The documentation shows that a PHQ9 was completed however the documentation does not include the time spent discussing the depression screening with the patient.

G0444 is a time based code for up to 15 minutes. For all timed codes, such as the G-codes you are evaluating, the documentation must report the time spent by the provider to support billing that code.

More than half of the time (e.g. 8 minutes on a 15-minute code) must be documented in order to report the code.

The time can be documented by a statement, e.g., ?I spent 9 minutes discussing the patient?s responses to the Depression Screening Questionnaire." It need not record an actual start and stop time. Attached is the Medicare Compliance Newsletter for January 2018 that discusses another timed code for Advance Care Planning. It indicates that Medicare requires time to be reported by providers, although that article refers to another HCPCS.

Patient 2: The correct coding for this encounter would be G0438 (provided the patient has not had an annual wellness visit within the last 12 months). G0444 cannot be reported for this encounter since the documentation does not include the time spent discussing the PHQ9 with the patient. The assessment and plan documents a neoplasm identified on the patient?s chest wall, however the documentation does not support billing a problem visit in addition to the G0438 since there is no physical exam documented nor is there any information in the HPI in regards to the neoplasm.

Here is a CMS link to a transmittal addressing depression screening for adults.

2

PARA Weekly Update: May 9, 2018

HOLTER MONITORING CODING

Can you explain the proper way to split codes for professional fee and outpatient facility codes for holter monitoring?

While many HCPCS codes can be used for both professional fee and outpatient facility fee reporting, some HCPCS are specifically defined for exclusive use in professional fee reporting only and may not be reported in a facility fee revenue code. Alternately, some HCPCS are used exclusively for technical component reporting, and may be reported by either professionals or facilities performing that component of service.

The code set for external electrocardiographic monitoring (aka holter monitoring) services is an example of a split code set. Two of the codes are for professional fees only, and two are for the technical component only, although the technical component can be reported by either facilities or professionals. This arrangement offers physicians a choice in reporting the separate components of testing, or to report one comprehensive code if the physician provides the entire service. Facilities, however, may report only the technical component HCPCS within a facility fee revenue code.

The codes to report holter monitoring up to 48 hours are as follows:

The PARA Data Editor Calculator HCPCS report displays the OPPS Status Indicator for the comprehensive professional fee CPTÂŽ code 93224 and the component pro fee code 93227 as M ? Not paid under OPPS:

3

PARA Weekly Update: May 9, 2018

HOLTER MONITORING CODING

The codes which offer technical component reimbursement, 93225 and 93226, display status indicator Q1 ? these HCPCS are paid under APC 5734, or payment is ?packaged? to another line on the facility claim:

Since facility charges may report only the technical component of these tests, the comprehensive code cannot be used in a facility fee revenue code ? the comprehensive code includes professional services.

The code set for tests which exceed 48 hours is as follows:

4

PARA Weekly Update: May 9, 2018

CHEMOTHERAPY INFUSIONS

Is it possible for you to republish the charge process for Hydration, IV Infusions, Injections and Vaccine Charges? We need a refresher on how to bill for the nursing service to perform drug therapy in the Oncology Department.

We offer this as an aid to the oncology department, as it appears from 2017 Medicare claims that they may not be using the chemotherapy administration code 96413 for certain eligible infusions, such as Remicade.

5

PARA Weekly Update: May 9, 2018

FLOW CYTOMETRY

Medicare is giving a code denial of not recognizing 88187, 88188, 88189, 88184. Can you tell us what we should be using? The 2018 CPTÂŽ manual still lists all of these.

The CPTÂŽ book lists all codes payable as professional fees; many are also payable on a facility fee claim, but not 88187-88189.

Please double check whether you meant to include 88184 on that list ? we show it as the payable HCPCS which represents the technical component of flow cytometry; the add-on code 88185 is status N ? it is reportable, but will not generate additional reimbursement.

The codes 88187-88189 have not been reimbursed under OPPS since 1/1/2015. These codes represent physician interpretation services and may be reported only by physicians as a professional fee, they are not reportable to Medicare by a hospital paid under OPPS. If the hospital incurs costs when preparing the specimen for the professional review, we recommend increasing the price of 88184 and/or 88185 to offset the lost revenue for the interpretation codes.(that is if we are understanding that the hospital would always report 88184/88185 when it would have reported 88187-88189.)

In biotechnology, flow cytometry is a laser- or impedance-based, biophysical technology employed in cell counting, cell sorting, biomarker detection and protein engineering, by suspending cells in a stream of fluid and passing them through an electronic detection apparatus.

6

PARA Weekly Update: May 9, 2018

BILLING FOR J9203 GEMTUZUMAB ONCOLOGY DRUG

We are wondering if the drug Gemtuzumab can be administered at our Cancer Center?

Yes. A physician-operated chemotherapy clinic can bill for J9203, Gemtuzumab.

Here?s an excerpt which specifically names this drug in publication 100-04, Medicare Claims Processing Manual, Chapter 12 ?Chapter 12 - Physicians/Nonphysician Practitioners?: https://www.cms.gov/Regulations-and-Guidance/Guidance /Manuals/Downloads/clm104c12.pdf Section 30.5 - Payment for Codes for Chemotherapy Administration and Nonchemotherapy Injections and Infusions D. Chemotherapy Administration Chemotherapy administration codes apply to parenteral administration of nonradionuclide anti-neoplastic drugs; and also to anti-neoplastic agents provided for treatment of noncancer diagnoses (e.g., cyclophosphamide for auto-immune conditions) or to substances such as monoclonal antibody agents, and other biologic response modifiers. The following drugs are commonly considered to fall under the category of monoclonal antibodies: infliximab, rituximab, alemtuzumb, gemtuzumab, and trastuzumab.

Drugs commonly considered to fall under the category of hormonal antineoplastics include leuprolide acetate and goserelin acetate. The drugs cited are not intended to be a complete list of drugs that may be administered using the chemotherapy administration codes. Local carriers may provide additional guidance as to which drugs may be considered to be chemotherapy drugs under Medicare.

The administration of anti-anemia drugs and anti-emetic drugs by injection or infusion for cancer patients is not considered chemotherapy administration.

If performed to facilitate the chemotherapy infusion or injection, the following services and items are included and are not separately billable: - Use of local anesthesia; - IV access; - Access to indwelling IV, subcutaneous catheter or port; - Flush at conclusion of infusion; - Standard tubing, syringes and supplies; and - Preparation of chemotherapy agent(s).

Payment for the above is included in the payment for the chemotherapy administration service.

If a significant separately identifiable evaluation and management service is performed, the appropriate E & M code should be reported utilizing modifier 25 in addition to the chemotherapy code. For an evaluation and management service provided on the same day, a different diagnosis is not required.

7

PARA Weekly Update: May 9, 2018

CMS PROPOSES TO RELAX INPATIENT ORDER REQUIREMENTS

n an unexpected move, Medicare has proposed to relax requirements around a written physician order for inpatient status in its 2019 Inpatient Prospective Payment System proposed rule.

This change may offer relief to hospitals which have struggled with occasional problems relating to a technically complete written physician order to admit a patient when care that was delivered at an inpatient level of service. The proposed change is not final and would take effect on October 1, 2018.

For Critical Access Hospitals (CAHs), this change is particularly welcome. Some CAHs have been caught with large outpatient claim write-offs because a surgery which was planned as an outpatient procedure converts, during the operating room session, to a procedure on the ?inpatient only? list. Since the surgeon typically does not dictate a change in patient status during the surgical procedure, CAHs are unable to report the procedure on an inpatient claim. (CAHs bill outpatient care and inpatient care separately.)

A fact sheet regarding the proposed rule was published on April 24, 2018 at the following link: https://www.cms.gov/Newsroom/MediaReleaseDatabase/Fact-sheets/ 2018-Fact-sheets-items/2018-04-24.html A link and the pertinent excerpt from the text of the proposed rule is provided below: https://s3.amazonaws.com/public-inspection.federalregister.gov/2018-08705.pdf ?Despite the discretion granted to medical reviewers to determine that admission order information derived from the medical record constructively satisfies the requirement that a written hospital inpatient admission order is present in the medical record, as we have gained experience with the policy, it has come to our attention that some otherwise medically necessary inpatient admissions are being denied payment due to technical discrepancies with the documentation of inpatient admission orders. Common technical discrepancies consist of missing practitioner admission signatures, missing co-signatures or authentication signatures, and signatures occurring after discharge.

We have become aware that, particularly during the case review process, these discrepancies have occasionally been the primary reason for denying Medicare payment of an individual claim. In looking to reduce unnecessary administrative burden on physicians and providers and having gained experience with the policy since it was implemented, we have concluded that if the hospital is operating in accordance with the CMS-1694-P 1057 hospital CoPs, medical reviews should primarily focus on whether the inpatient admission was medically reasonable and necessary rather than occasional inadvertent signature documentation issues unrelated to the medical necessity of the inpatient stay.

8

PARA Weekly Update: May 9, 2018

CMS PROPOSES TO RELAX INPATIENT ORDER REQUIREMENTS

?Therefore, we are proposing to revise the admission order documentation requirements by removing the requirement that written inpatient admission orders are a specific requirement for Medicare Part A payment. Specifically, we are proposing to revise the inpatient admission order policy to no longer require a written inpatient admission order to be present in the medical record as a specific condition of Medicare Part A payment. Hospitals and physicians are already required to document relevant orders in the medical record to substantiate medical necessity requirements. If other available documentation, such as the physician certification statement when required, This proposal does not change the requirement progress notes, or the medical record as a that an individual is considered an inpatient if whole, supports that formally admitted as an inpatient under an all the coverage criteria (including order for inpatient admission. medical necessity) are met, and the hospital is operating in accordance with the hospital conditions of participation (CoPs), we believe it is no longer necessary to also require specific documentation requirements of inpatient admission orders as a condition of Medicare Part A payment.

This proposal does not change the requirement that an individual is considered an inpatient if formally admitted as an inpatient under an order for inpatient admission. While this continues to be a requirement, as indicated earlier, technical discrepancies with the documentation of inpatient admission orders have led to the denial of otherwise medically necessary inpatient admission.

To reduce this unnecessary administrative burden on physicians and providers, we are no longer requiring that the specific documentation requirements of inpatient admission orders be present in the medical record as a condition of Medicare Part A payment.

Therefore, we are proposing to revise the regulations at 42 CFR 412.3(a) to remove the language stating that a physician order must be present in the medical record and be supported by the physician admission and progress notes, in order for the hospital to be paid for hospital inpatient services under Medicare Part A. We note that we are not proposing any changes with respect to the ?2 midnight? payment policy. ?

9

PARA Weekly Update: May 9, 2018

USING PARA'S SHARE OF COST WIDGET

The issue of price transparency has gained increasing importance in the healthcare industry due to the proliferation of medical options and the rise of consumerism. Under current law, hospitals are required to make public a list of their standard charges. CMS plans to increase the accessibility to this information by specifically requiring hospitals to publicly post their standard charges online.

That's where PARA can help.

PARA?s Patient Share of Cost Widget provides a solution that enables patients and consumers the ability to generate quotes on the hospitals top procedures. It is a web-based system that allows the patient to determine their share of cost for healthcare services.

-

Promote pricing transparency Provide accurate estimates prior to service Reduce patient dissatisfaction directed at the provider Increase self-pay collections while decreasing bad debt

For Inf or M or e mat io n Cont PARA act your A Exec ccount ut ive

10

PARA Weekly Update: May 9, 2018

CMS PROPOSES FOUR RULES AFFECTING FY19 PAYMENTS

The Centers For Medicare And Medicaid Services has proposed four new rules that will affect Fiscal Year 2019 Medicare payment policies and rates for a variety of programs. PARA brings you important links and information about each of these proposed rules.

Inpatient Psychiatric Facility: FY 2019 Payment & Quality Reporting Updates Comments accepted until June 26, 2018 CMS Fact Sheet (Click Here)

Skilled Nursing Facility: FY 2019 Payment & Quality Reporting Updates Comments accepted until June 26, 2018 CMS Fact Sheet (Click Here)

11

PARA Weekly Update: May 9, 2018

CMS PROPOSES FOUR RULES AFFECTING FY19 PAYMENTS

Inpatient Rehabilitation Facility: FY 2019 Payment & Quality Reporting Updates Comments accepted until June 26, 2018 CMS Fact Sheet (Click Here)

Hospice: Proposed Updates To The Wage Index And Payment Rates for FY 2019 Comments accepted until June 26, 2018 CMS Fact Sheet (Click Here)

12

PARA Weekly Update: May 9, 2018

RURAL HOSPITAL PROGRAM GRANTS AVAILABLE

Rural hospitals and clinics face their own set of unique and burdensome challenges when it comes to program development, cash management and maintaining volume. That's why it's great when they can get some assistance from external funding sources.

At PARA, we've found an excellent source of funding opportunities for rural healthcare facilities. Here are some examples.

Community Facilities Technical Assistance And Training - Provides up to $150,000 in funding intermediary organizations to provide technical assistance and training for rural organizations and agencies to identify and plan for community facility needs that exist in their area.

- Application Deadline: July 2, 2018 Here's the link:

NURSE Corps Scholarship Program - In exchange for at least 2 years service at a healthcare facility with a critical shortage of nurses, the Nursing Scholarship Program pays: -Tuition and other required fees -Other reasonable costs including required books, clinical supplies, and laboratory expenses -Monthly stipend for living expenses

- Application Deadline: June 14, 2018 Here's the link

13

PARA Weekly Update: May 9, 2018

LOG IN TO THE PDE USING GOOGLE CHROME

The PARA Data Editor is now compatible with multiple web browsers so that everyone can have options when it comes to which browser to use, depending on resources or preferences.

Our PARA Data Editor Multiple Web Browser (Beta) Version to available to everyone with a proper PARA Data Editor Login.

The Web Browsers available include a version in both Internet Explorer and Google Chrome.

To all users who wish to use the Multiple Web Browser (Beta) Version, please be aware that this is a PRELIMINARY version meant to work out any errors and issues that it might exhibit.

It is in the process of being updated to mirror the current production version of the PARA Data Editor.

With your help, we will be able to narrow in on fixes throughout the PARA Data Editor Multiple Web Browser (Beta) Version to then ensure full functionality and to further expand to more Web Browsers.

The PARA Data Editor Multiple Web Browser (Beta) Version can be accessed via the following link and using the appropriate login when prompted by the browser: https://www.para-hcfs.com/projects/ pde_upgrade/pde_MultBrowser Once logged in, we would like for you to please be aware of a few key features to help us improve the PDE Multiple Browser (Beta) Version.

First, please be aware of the change in look for the Multiple Browser (Beta) Version. We are attempting to update the look and feel of the PDE to be cleaner and user-friendly.

Second, if you may have any questions, need help, would like to report an error or issue with the PDE Multiple Web Browser (Beta) Version, or anything else you may think of, click on the ?Contact Support? Link in the upper-right hand corner of the PDE.

14

PARA Weekly Update: May 9, 2018

There were SIX new or revised Med Learn (MLN Matters) article released this week.

To go to the full Med Learn document simply click on the screen shot or the link.

FIND ALL THESE MED LEARNS IN THE ADVISOR TAB OF THE PDE

15

PARA Weekly Update: May 9, 2018

The link to this Med Learn: MM10611

16

PARA Weekly Update: May 9, 2018

The link to this Med Learn: MM10422

17

PARA Weekly Update: May 9, 2018

The link to this Med Learn: MM10314

18

PARA Weekly Update: May 9, 2018

The link to this Med Learn: MM10573

19

PARA Weekly Update: May 9, 2018

The link to this Med Learn: MM10604

20

PARA Weekly Update: May 9, 2018

The link to this Med Learn: MM10611

21

PARA Weekly Update: May 9, 2018

There were TEN new or revised Transmittals released this week.

To go to the full Transmittal document simply click on the screen shot or the link.

FIND ALL THESE TRANSMITTALS IN THE ADVISOR TAB OF THE PDE

22

PARA Weekly Update: May 9, 2018

The link to this Transmittal R2075OTN

23

PARA Weekly Update: May 9, 2018

The link to this Transmittal R2086OTN

24

PARA Weekly Update: May 9, 2018

The link to this Transmittal R2085OTN

25

PARA Weekly Update: May 9, 2018

The link to this Transmittal R2082OTN

26

PARA Weekly Update: May 9, 2018

The link to this Transmittal R2080OTN

27

PARA Weekly Update: May 9, 2018

The link to this Transmittal R2079OTN

28

PARA Weekly Update: May 9, 2018

The link to this Transmittal R2077OTN

29

PARA Weekly Update: May 9, 2018

The link to this Transmittal R2076OTN

30

PARA Weekly Update: May 9, 2018

The link to this Transmittal R2084OTN

31

PARA Weekly Update: May 9, 2018

The link to this Transmittal R2083OTN

32

PARA Weekly Update: May 9, 2018

33