PARA HealthCare Analytics Weekly eJournal December 23, 2020

D ecember 23, 2020

PARA

WeeklyeJOURNAL NEWS FOR HEALTHCARE DECISION MAKERS

The COVID-19 Vaccine Is Finally Here.

And just in time, our experts provide guidance on: - Coding - Billing - Pricing

PARA Sim plif ies Com plex Issu es

Page 11 - New COVID-19 Treatement Add-On Payment - UPDATED: M edi-Cal Paym en t Rat es For COVID-19 Test in g - Medicare Premiums And Deductible Update

FAST LINKS

Days Un t il Pr ice Tr an spar en cy Deadlin e Page 31

- " M ost Favor ed Nat ion" For Dr u g Paym en t s In 2021 - New Add-On HCPCS For Professional E/M Services - Except ion s To RHC Pr odu ct ivit y

- Administration: Pages 1-46 - HIM /Coding Staff: Pages 1-46 - Providers: Pages 2,5,7,15,18,21,23 - California Providers: Page 5 - M edicare Enrollees: Pages 6,21 1 - Pharmacy: Pages 7,11

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Finance: Pages 11,15 Rural Health Care: Page 18 Cardiology: Page 23 Price Transparency: Page 31 Therapy Services: Page 26 Compliance: Page 31 Hospice Care: Page 35

© PARA Healt h Car e An alyt ics an HFRI Company 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 eJournal: December 23, 2020

NEW COVID-19 TREATMENT ADD-ON PAYMENT (NCTAP)

Medicare recently announced a New COVID-19 Treatment Add-On Payment (NCTAP) program for hospitals paid under its Inpatient Prospective Payment System effective November 2, 2020 through the end of the of the Public Health Emergency (PHE).The NCTAP offers enhanced ?add-on? payments for inpatient care reimbursed under Medicare?s Inpatient Prospective Payment System (IPPS) when certain new products with FDA Administrative approval or emergency use authorization for COVID-19 are provided during an inpatient stay.(The new program is not available to Critical Access Hospitals, which are paid on a cost-reimbursement basis for inpatient care.)

However, add-on payments are triggered only if the cost of the case (as measured by the hospital?s established Medicare cost to charge ratios) exceeds the amount of the DRG payment under IPPS. CMS provides a webpage for NCTAP information at the following link: https://www.cms.gov/medicare/covid-19/covid-19-treatments-add-payment-nctap

The NCTAP add-on payment will be equal to the lesser of: - 65% of the operating outlier claim threshold OR - 65% of the costs that exceed the standard DRG payment (including those cases adjusted to the relative weight under section 3710 of the CARES Act.) For high-cost cases, the NCTAP payments could increase IPPS reimbursement in addition to the 20% bump in the operating portion of IPPS DRG payments for COVID patients previously made available under the CARES Act, announced in September 11, 2020 in MLN Matters SE20015: https://www.cms.gov/files/document/se20015.pdf

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PARA Weekly eJournal: December 23, 2020

NEW COVID-19 TREATMENT ADD-ON PAYMENT (NCTAP)

CMS determines NCTAP eligibility based on claims eligible for the 20% add-on payment under section 3710 of the CARES Act based on the presence of specific ICD-10 codes: - ICD-10-CM Diagnosis Code of U07.1 -COVID-19 AND - An ICD-10-PCS code for Remdesivir (Veklury), COVID-19 convalescent plasma, or Remdesivir administered with Baricitinib (Olumiant)

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PARA Weekly eJournal: December 23, 2020

NEW COVID-19 TREATMENT ADD-ON PAYMENT (NCTAP)

*The Emergency Use Authorization (EUA) requires the administration of Baricitinib with Remdesivir ICD-10-PCS code(s) XW033E5 Introduction of Remdesivir Anti-infective into Peripheral Vein, Percutaneous Approach, New Technology Group 5 or XW043E5 Introduction of Remdesivir Anti-infective into Central Vein, Percutaneous Approach, New Technology Group 5.

While CMS reminds us that, per Chapter 32 of the Claims Processing Manual ? Billing Requirements for Special Services a hospital should not seek additional payment for drugs or biologicals that a governmental entity provided at no cost to to diagnose or treat patients with known or suspected COVID-19, a hospital should report all ICD-10-PCS code(s) associated with the product(s).

Additional billing and reporting information may be obtained from CMS through the following link: https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/clm104c32.pdf#

Because Medicare is currently providing monoclonal antibody therapy products at no cost to providers, those products are not included in the NCTAP.Medicare does, however, cover the administration/infusion of the monoclonal products.

The ?COVID-19 Frequently Asked Questions (FAQs) on Medicare Fee-For-Service (FFS) Billing? document includes questions on NCTAPs beginning with question number 13 of F. Hospital Inpatient Prospective Payment Systems (IPPS) Payments: https://www.cms.gov/files/document/03092020-covid-19-faqs-508.pdf

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PARA Weekly eJournal: December 23, 2020

MEDI-CAL UPDATED PAYMENT RATES FOR COVID-19 TESTING

Medi-Cal has announced it will cover COVID-19 Detection CPT® Code 87428 effective for dates of service on or after November 10th, 2020. https://files.medi-cal.ca.gov/pubsdoco/newsroom/newsroom_30717_09.aspx?_cldee= bW1jbWlsbGFuQHBhcmEtaGNmcy5jb20%3d&recipientid=contact-9212cfb6eaf 5ea11a815000d3a5bf119-fa09c2e2c2274e6d8b77e43822f7e81c&esid=39193d1f -763e-eb11-a813-000d3a310f17

The full description of the new code is: 87428 -- Infectious agent antigen detection by immunoassay technique, (eg, enzyme immunoassay [EIA], enzyme-linked immunosorbent assay [ELISA], fluorescence immunoassay [FIA], immunochemiluminometric assay [IMCA]) qualitative or semiquantitative; severe acute respiratory syndrome coronavirus (eg, SARS-CoV, SARS-CoV-2 [COVID-19]) and influenza virus types A and B The frequency limitation for CPT® Code 87428 is once per day for any provider type. There is no established payment rate for this CPT® Code yet; it will be released in future Medi-Cal publications.

Medi-Cal will implement an Erroneous Payment Correction (EPC) plan to reprocess affected claims retroactive to November 10th.

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PARA Weekly eJournal: December 23, 2020

CY2021 MEDICARE PREMIUMS AND DEDUCTIBLE UPDATES

CMS has announced the new updates for the CY2021 premiums and deductibles for Part A and Part B fee for service providers.

Medicare Part B covers physician services, outpatient hospital services, certain home health services, durable medical equipment, and certain other medical and health services not covered under Part A. The standard monthly premium for Medicare Part B enrollees will be $148.50 for CY 2021. This is a slight increase over CY2020, which was $144.60.

The annual deducible for Part B enrollees for CY2021 is $203.00. As with the increase in premiums, this is also a slight increase over CY2020, which was $198.00.

Medicare Part A covers inpatient hospital, skilled nursing facility, and some home health care services.

Currently, CMS records show about 99% (percent) of Medicare beneficiaries do not have a Part A premium since they have at least 40 quarters of Medicare-covered employment.

For CY2021, the Medicare Part A inpatient deductible is $1,484.00. This is an increase of $76.00 from the CY2020 deductible amount of $1,408.00.

CY2021 Co-insurance rates: $371.00 ? 61st ? 90th day $742.00 ? 91st ? 150th day for Lifetime reserve days $ 185.50? 21st ? 100th day for SNF days Medicare Advantage Premiums: In CY2021 Medicare Advantage premiums will decline while plan choices and new benefits increase. On average, Medicare Advantage premiums are estimated to decrease by 23% from CY2020.

Article reference: https://www.cms.gov/newsroom/fact-sheets/2021-medicare-parts-b-premiums-and-deductibles

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PARA Weekly eJournal: December 23, 2020

CMS TO START "MOST FAVORED NATION" DRUG PAYMENTS IN 2021

On November 27 2020, Medicare published a new final rule to implement one of President Trump?s executive orders to reduce the cost of prescription drugs. The surprising new rule did not follow the usual regulatory process. There was no proposed rule, the regulation went straight to ?final rule with a comment period?, citing the Medicare beneficiary?s need for less expensive drugs during the pandemic as the basis of this exercise of regulatory authority.

Under the ?Most Favored Nation? Innovation Model, CMS selected 50 of its highest expenditure drugs to be reimbursed to OPPS hospitals and physicians nationwide at the ?MFN? price. The lowest price paid for that drug among certain other developed nations, such as Australia, Canada, Germany, France, the United Kingdom, Italy, Spain, and Japan (among others.) PARA clients may identify which of the 50 MFN drug HCPCS are contained within their chargemaster using the PARA Data Editor ?Advisor? tab.Enter ?MFN? in the ?Summary? field, then click on ?CDM?:

When providers claim reimbursement for one of the 50 MFN drugs by reporting the usual HCPCS code and appropriate units, they must also claim an ?add-on? payment of $148.73 ?per dose? by reporting a new add-on HCPCS, M1145 ? ?Most Favored Nation (MFN) model drug add-on amount, per dose (do not report with line items that have the JW modifier)?:

Although the reimbursement for M1145 is set at $148.73, some hospitals intend to report it at a charge of $0.01 in order to ensure that claims to Medicare do not report a materially higher rate of charges for the same drug.Under OPPS, the reimbursement should process at $148.73 even for a nominal charge.

The new reimbursement method applies only to outpatient claims and professional fee claims, but does not apply to Critical Access Hospitals, Cancer centers, children?s hospitals, hospitals paid on the basis of reasonable costs, and a few other excepted provider types.

CMS projects that in general, physician practices will be better off under the per-dose add-on payment approach than hospital outpatient departments, and single specialty practices will be better off than multi-specialty practices.

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PARA Weekly eJournal: December 23, 2020

CMS TO START "MOST FAVORED NATION" DRUG PAYMENTS IN 2021

Since the rule takes effect 1/1/2021, providers have very little time to develop a workflow to capture the add-on HCPCS code M4511, or to have that HCPCS code added to the EHR system dictionary.It also remains unclear whether the new MFN rule was coordinated among other CMS entities responsible for implementing this new payment methodology on January 1, 2021.

Considering the rush to adopt this final rule, it is reasonable to expect some kind of a delay or a more significant intervention may come into play as a result of either stakeholder comments received on the Final Rule, legal challenges, the new Biden administration, and/or the Congressional appropriations process. However, for now, providers should make every effort to prepare. Reimbursement is at stake, and no particular relief is certain.

Medicare offers a Most Favored Nation Fact Sheet at the link below. An excerpt is provided: FACT SHEET: Most Favored Nation Model for Medicare Part B Drugs and Biologicals Interim Final Rule with Comment Period | CMS

A link and an excerpt from the CMS Innovation Center webpage is provided below: Most Favored Nation Model | CMS Innovation Center

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PARA Weekly eJournal: December 23, 2020

CMS TO START "MOST FAVORED NATION" DRUG PAYMENTS IN 2021

The ?Per dose? add-on HCPCS M4511 is described in the following excerpt from the Final Rule: https://www.federalregister.gov/documents/2020/11/27/2020-26037/most-favored-nation-mfn-model ?? MFN participants will be required to submit a separate claim line using a new model-specific HCPCS code (M1145, MFN drug add-on, per dose) to bill for and receive the alternative add-on payment amount for each dose of an MFN Model drug that is billed on the claim. The MFN participant will indicate in the units field of the claim line with HCPCS code M1145 the number of doses of a separately payable MFN Model drugthat are billed on the claim. To do so, the MFN participant will count the number of claim lines with a HCPCS code that is included on the applicable MFN Model Drug HCPCS Codes List (based on the date of service),including all claim lines when the number of billing units necessary to indicate the dosage given exceeds the character size of the units field and the claim has more than one claim line for such MFN Model drug (we note that this is expected to be a rare situation), and excluding the number of claim lines billed with the JW modifier. This approach will allow the Medicare claims processing system to apply the alternative add-on payment amount for each dose, and not apply beneficiary cost-sharing to the alternative add-on payment amount. MFN participants will still bill for wastage as they otherwise would, using a separate claim line and the JW modifier, and the payment for such claim lines will be based on the MFN Drug Payment Amount (the alternative add-on payment amount is not applicable to such claim lines).

The specific rates that CMS will reimburse per drug are not yet published, although we found international price data is listed in the Issue Brief prepared by the Assistant Secretary for Planning and Evaluation at HHS. Here?s a link and an excerpt demonstrating the vast difference in prices for Infliximab (Remicade), HCPCS J1745: https://aspe.hhs.gov/system/files/pdf/264421/Part-B%20Drugs-International-Issue-Brief.pdf

The MFN website says ?Technical documents, including the MFN Drug Payment Amount and the alternative add-on payment amount, will be posted on this website and updated on a quarterly basis.?

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PARA Weekly eJournal: December 23, 2020

CMS TO START "MOST FAVORED NATION" DRUG PAYMENTS IN 2021

Although this program is referred to by CMS as a ?Model?, participation in the reimbursement scheme is mandatory for many Part B providers, including physicians, suppliers, and outpatient hospitals which are paid under OPPS.The rule does not apply to drugs administered during an inpatient stay (specifically, Part B-only inpatient claims are excluded), DME claims,and ESRD PPS claims.There is also a limitation on the MFN Drug Payment Amount that will apply to certain claims submitted by 340B covered entities.

In the first year of the MFN model, 2021, CMS will blend the lowest price paid for the same drug among economically similar countries (the MFN price) into its reimbursement rates ? the final rate paid will consist of 25% MFN Price and 75% of the Average Sales Price.Over four years, the reimbursement will culminate in 100% of the MFN Price, unless the model is stopped or altered earlier at Medicare?s discretion or by outside influencing factors.

The full text of the Interim Final Rule (RIN 0938-AT91) is available at the link below. We have included a few excerpts: https://innovation.cms.gov/media/document/mfn-ifc-rule ?Drug acquisition costs in the U.S. exceed those in Europe, Canada, and Japan, according to an October 2018 ASPE analysis of Medicare Part B physician administered drugs. This finding was generally consistent with the existing evidence base as described in the HHS analysis?s background section, which found peer-reviewed literature on this topic to be relatively limited and dated, but with similar findings of higher drug prices in the U.S. compared to other countries. The HHS analysis compared U.S. drug acquisition costs for a set of Medicare Part B physician-administered drugs to acquisition costs in 16 other developed economies? Austria, Belgium, Canada, Czechia, Finland, France, Germany, Greece, Ireland, Italy, Japan, Portugal, Slovakia, Spain, Sweden, and the United Kingdom (UK). The main analysis in the HHS report focused on 27 drugs accounting for 64 percent of total Medicare Part B drug spending in 2016.Among the 27 drugs included in the analysis, acquisition costs in the U.S. were 1.8 times higher than in comparator countries.? ?

Comments on the Final Rule will be accepted until January 26, 2021, at the following electronic address: http://www.regulations.gov (Follow the "Submit a comment" instructions.) Commenters may also submit comments via regular mail and express or overnight mail; the addresses are found on pages 2 and 3 of the final rule.

PARA will publish updates on the MFN rule as more information comes to light.

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PARA Weekly eJournal: December 23, 2020

BILLING AND CODING FOR COVID-19 VACCINES

On Fri day, December 18, 2020 the FDA approved the M oderna COVID-19 vacci ne for use under an Emergency Use Authori zati on (EUA).Thi s vacci ne joi ns the Pfi zer product whi ch was provi ded EUA on December 11, 2020.

Under the CARES Act, Medicare will provide beneficiaries COVID-19 vaccine administration with no cost-sharing to beneficiaries under Part B coverage.

Initially, providers will not incur a cost for the drug product as they will be distributed through government agencies.Providers should not bill for the drug when they receive it at no cost.CMS states it will establish COVID-19 drug product allowances, which will be based on reasonable costs (or, for physician offices, 95% of Average Wholesale Prices), later. Effective immediately after the FDA approves vaccinations for EUA, providers may report the COVID-19 administration code based on the type of vaccine and the which dose is provided.

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PARA Weekly eJournal: December 23, 2020

BILLING AND CODING FOR COVID-19 VACCINES

*Per the The Medicare Claims Processing Manual Chapter 32 - Billing Requirements for Special Services section 67.2 providers should not bill for drugs when they receive it at no cost. https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/clm104c32.pdf#

In anticipation of the EUA approval of the COVID-19 vaccine that is currently in development by AstraZeneca and the University of Oxford, the AMA CPTÂŽ code set for the vaccine product and administration.Like both the Pfizer and Moderna vaccines, administration code will be reported based whether it is the first or the second dose.

The effective date for these codes will follow the EUA approval.The codes are provided on the following page.

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PARA Weekly eJournal: December 23, 2020

BILLING AND CODING FOR COVID-19 VACCINES

*Per the The Medicare Claims Processing Manual Chapter 32 - Billing Requirements for Special Services section 67.2 providers should not bill for drugs when they receive it at no cost.

The AMA provides instructions for coding the administration of the COVID-19 vaccines through the following document: https://www.ama-assn.org/system/files/2020-11/covid-vaccine-long-descriptors.pdf

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PARA Weekly eJournal: December 23, 2020

BILLING AND CODING FOR COVID-19 VACCINES

CMS created a resource page to provide COVID-19 vaccine policies and guidance for providers, state programs and beneficiaries: https://www.cms.gov/covidvax

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PARA Weekly eJournal: December 23, 2020

NEW ADD-ON HCPCS FOR PROFESSIONAL E/M SERVICES

In t h e 2021 M edicar e Ph ysician Fee Sch edu le Fin al Ru le, CM S cr eat ed t w o n ew add-on HCPCS codes t o r epor t visit com plexit y or pr olon ged t im e in per f or m in g an E/ M ser vice.

The new codes are: G2211: Visit complexity inherent to evaluation and management associated with medical care services that serve as the continuing focal point for all needed health care services and/or with medical care services that are part of ongoing care related to a patient?s single, serious condition or a complex condition. (Add-on code, list separately in addition to office/outpatient evaluation and management visit, new or established).

G2212: Prolonged office or other outpatient evaluation and management service(s) beyond the maximum required time of the primary procedure which has been selected using total time on the date of the primary service; each additional 15 minutes by the physician or qualified healthcare professional, with or without direct patient contact (List separately in addition to CPT ÂŽ codes 99205, 99215 for office or other outpatient evaluation and management services) (Do not report G2212 on the same date of service as 99354, 99355, 99358, 99359, 99415, 99416). (Do not report G2212 for any time unit less than 15 minutes).

To read the full discussion of the new codes, refer to the CMS Medicare Physician Fee Schedule Final Rule, which is temporarily published at https://public-inspection.federalregister.gov/2020-26815.pdf. That document is scheduled to be published in the Federal Register on 12/28/2020 and available online at federalregister.gov/d/2020-26815, and on govinfo.gov.

Here are key points regarding new code G2211: - Reimbursement of G2211 for professional fees will be paid at the same rate for both facility and non-facility settings:.49 RVU x $32.41 = $15.88 (national unadjusted rate) - Under OPPS, facilities may report G2211, but the OPPS Status Indicator is N, payment packaged to any other payable service on the same claim (e.g., G0463, Hospital outpatient clinic visit for assessment and management of a patient).Reimbursement is limited to professional fee reporting; PARA does not recommend reporting G2211 as a facility fee - G2211 code is expected to be reported with 100% of office/outpatient E/M visits by specialties that rely on office/outpatient E/M visits to report the majority of their services. Medicare did not restrict billing G0211 based on specialty, but it assumed that certain specialties furnish these types of visits more than others

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PARA Weekly eJournal: December 23, 2020

NEW ADD-ON HCPCS FOR PROFESSIONAL E/M SERVICES

- G2211 reflects the time, intensity, and practice expense when practitioners furnish services that enable them to build ?longitudinal relationships with all patients (that is, not only those patients who have a chronic condition or single-high risk disease) and to address the majority of patients? health care needs with consistency and continuity over longer periods of time" - CMS did not specify what documentation will specifically support G2211.In the context of primary care, HCPCS add-on code G2211 could ?recognize the resources inherent in holistic, patient-centered care that integrates the treatment of illness or injury, management of acute and chronic health conditions, and coordination of specialty care in a collaborative relationship with the clinical care team.?Such collaborative care includes patient education, expectations and responsibilities, shared decision-making around therapeutic goals, and shared commitments to achieve those goals - In both primary and specialty care, HCPCS add-on code G2211 reflects the time, intensity, and practice expense associated with providing services that result in care that is ?personalized to the patient?

- CMS seeks to encourage practitioners in rural communities, including NPPs, to deliver the comprehensive and longitudinal care that HCPCS add-on code G2211 describes - Example of appropriate reporting: In the context of primary care, a clinical example for the use of HCPCS add-on code G2211 could be: a 68 year-old woman with progressive congestive heart failure (CHF), diabetes, and gout, on multiple medications, who presents to her physician for an established patient visit. The clinician discusses the patient?s current health issues, which includes confirmation that her CHF symptoms have remained stable over the past 3 months. She also denies symptoms to suggest hyper- or hypoglycemia, but does note ongoing pain in her right wrist and knee. The clinician adjusts the dosage of some of the patient?s medications, instructs the patient to take acetaminophen for her joint pain, and orders laboratory tests to assess glycemic control, metabolic status, and kidney function.

The practitioner also discusses age appropriate prevention with the patient and orders a pneumonia vaccination and screening colonoscopy. In this clinical example, the practitioner is serving as a focal point for the patient?s care, addressing the broad scope of the patient?s health care needs, by furnishing care for some or all of the patient?s conditions across a spectrum of diagnoses and organ systems with consistency and continuity over time - Example of inappropriate reporting of G2211: when the care furnished during the office/outpatient E/M visit is provided by a professional whose relationship with the patient is of a discrete, routine, or time-limited nature, such as a mole removal or referral to a physician for removal of a mole; for treatment of a simple virus; for counseling related to seasonal allergies, initial onset gastroesophageal reflux disease; treatment for a fracture; and where comorbidities are either not present or not addressed, and/or and when the billing practitioner has not taken responsibility for ongoing medical care for that particular patient with consistency and continuity over time, or does not plan to take responsibility for subsequent, ongoing medical care for that particular patient with consistency and continuity over time.

Reporting the add-on code with these types of visits would be inconsistent with the code descriptor, which describes care that is a continuing focal point and/or part of ongoing care

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PARA Weekly eJournal: December 23, 2020

NEW ADD-ON HCPCS FOR PROFESSIONAL E/M SERVICES

- Medicare does not expect that HCPCS addon code G2211 would be reported when the office/outpatient E/M is reported with a payment modifier, such as modifier -25.While reporting G2211 with an E/M that has modifier 25 appended is not prohibited at this time, CMS might prohibit it in future rule-making - G2211 can be reported for both new and established patients Here are the key points in reporting new code G2212: - G2212 is intended to be used in lieu of 99417.The CPTÂŽ explanation of time required for 99417 was too vague for CMS; the new HCPCS G2212 clarifies the time required to ensure that the 15-minute increment is above the maximum time threshold for each E/M code - Reimbursement per unit of G2212 will be slightly different in the facility vs. non-facility setting:Non-facility @ .97 x $32.41 = $31.37; Facility @ .93 x $32.41 = $30.14 - The documented time required to report units G2212 must be the full 15-minute increment.Do not report G2212 for a partial period, even if that partial period is more than half the 15 minutes

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PARA Weekly eJournal: December 23, 2020

NEW EXCEPTIONS TO RHC PRODUCTIVITY DUE TO COVID-19

M edicar e an n ou n ced a n ew oppor t u n it y f or Ru r al Healt h Clin ics (RHCs) t o apply f or an except ion t o RHC pr ovider pr odu ct ivit y st an dar ds du e t o t h e ef f ect s of t h e COVID-19 Nat ion al Healt h Em er gen cy.

Productivity standards are vital to the life of the RHC because they are used to determine the average cost per patient for Medicare reimbursement. Practitioners in the RHC (physicians, nurse practitioners, physician assistants and certified midwives) are held to a minimum number of visits per FTE, and are expected to furnish services within the RHC. If statistics reflect failure to meet this minimum, it could indicate the RHC is operating at an excessive staffing level, which results in excessive cost.

At the end of the RHC's cost reporting year, the A/B MAC, calculates the RHC?s all inclusive rate (AIR) by dividing the total allowable costs across all of the reported patient types by the number of visits for all patient types. Patient visits are defined as Medicare, Medicaid, Medicare Advantage, private payers, etc.

These patient visit types are included in the determining calculation for the RHCs productivity. If the final results reflect a fewer number of expected visits have been furnished, the A/B MAC substitutes the expected number of visits for the denominator and will instead use the actual number of visits. The total allowable costs would be divided by the higher, expected number of visits. In the case of low productivity, the calculation could result in lowering the AIR per-visit rate.

Due to the COVID-19, RHCs were faced with fewer face-to-face visits, as remote services (i.e. telehealth and virtual check-ins) became the choice of care delivery whenever possible. As a result, some RHCs may have difficulty meeting the established productivity standards. In light of this PHE, CMS will allow MACs to use discretion to make an exception to the productivity standards for a one-year (1) period based on individual circumstances.

RHCs that seek an exception must submit a written request after the provider?s fiscal year end, with justification for failure to meet the productivity requirements. The RHC is expected to provide the following information in the prepared request: - A summary of the facility?s hours of operation - A summary of the physician and mid-level practitioner hours and FTE calculations. Any non-RHC hours must be excluded from the calculation of the FTEs, including any contracted hours, administrative hours, hours of service spent in the hospital, etc.

- A summary of the year-end total RHC visit for each practitioner position (physician, physician assistant and/or nurse practitioner - The exception percentage and/or standard being requested per practitioner position - Any additional documentation or narrative that provides support for the exception request 18

PARA Weekly eJournal: December 23, 2020

NEW EXCEPTIONS TO RHC PRODUCTIVITY DUE TO COVID-19

Links and contacts for the various Medicare Administrative Contractor contacts for submitting exception requests are provided here.

National Government Services (NGS) providers should direct exception requests to the email address ngsprovbaseddeterminations@anthem.com

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PARA Weekly eJournal: December 23, 2020

NEW EXCEPTIONS TO RHC PRODUCTIVITY DUE TO COVID-19

First Coast Service Options Medicare Providers should direct exception requests as instructed at this link: https://medicare.fcso.com/PARD_provider_reimbursement/0462066.asp

Novitas JH (AR, CO, LA, MS, NM, OK, TX, Indian Health Services and Veterans Medicare Providers) should direct exception requests to: https://www.novitas-solutions.com/webcenter/portal/MedicareJH/pagebyid?contentId=00228302

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PARA Weekly eJournal: December 23, 2020

MEDICARE BENEFICIARIES AND ACCESS TO COVID-19 ANTIBODY TREATMENT

Th e Cen t er s f or M edicar e & M edicaid Ser vices an n ou n ced t h at st ar t in g Novem ber 10, 2020, M edicar e ben ef iciar ies can r eceive cover age of m on oclon al an t ibodies t o t r eat cor on avir u s disease 2019 (COVID-19) w it h n o cost -sh ar in g du r in g t h e pu blic h ealt h em er gen cy (PHE).

CMS?coverage of monoclonal antibody infusions applies to bamlanivimab, which received an emergency use authorization (EUA) from the U.S. Food and Drug Administration yesterday. ?Today, CMS is announcing a historic, first-of-its kind policy that drastically expands access to COVID-19 monoclonal antibodies to beneficiaries without cost sharing,? said CMS Administrator Seema Verma. ?Our timely approach means beneficiaries can receive these potentially life-saving therapies in a range of settings ? such as in a doctor?s office, nursing home, infusion centers, as long as safety precautions can be met. This aggressive action and innovative approach will undoubtedly save lives.?

CMS anticipates that this monoclonal antibody product will initially be given to health care providers at no charge. Medicare will not pay for the monoclonal antibody products that providers receive for free but today?s action provides for reimbursement for the infusion of the product. When health care providers begin to purchase monoclonal antibody products, Medicare anticipates setting the payment rate in the same way it set the payment rates for COVID-19 vaccines, such as based on 95% of the average wholesale price for COVID-19 vaccines in many provider settings. CMS will issue billing and coding instructions for health care providers in the coming days.

CMS anticipates the announcement today will allow for a broad range of providers and suppliers, including freestanding and hospital-based infusion centers, home health agencies, nursing homes, and entities with whom nursing homes contract, to administer this treatment in accordance with the EUA, and bill Medicare to administer these infusions.

Under section 6008 of the Families First Coronavirus Response Act (FFCRA), state and territorial Medicaid programs may receive a temporary 6.2 percentage point increase in the Federal Medical Assistance Percentage (FMAP), through the end of the quarter in which the COVID-19 PHE ends.

A condition for receipt of this enhanced federal match is that a state or territory must cover COVID-19 testing services and treatments, including vaccines and their administration, specialized equipment, and therapies for Medicaid enrollees without cost sharing.

This means that this monoclonal antibody infusion is expected to be covered when furnished to Medicaid beneficiaries, in accordance with the EUA, during this period, with limited exceptions.To view the Monoclonal Antibody COVID-19 Infusion Program Instruction, visit: https://www.cms.gov/files/document/covid-medicare-monoclonal-antibody -infusion-program-instruction.pdf

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PARA Weekly eJournal: December 23, 2020

NEW CONDITION CODES 90 AND 91 EFFECTIVE FEBRUARY 1, 2021

On October 29, 2020, the National Uniform Billing Committee (NUBC) created condition codes 90 and 91 for services and treatment provided under Expanded Access Approved Services (EA) or Emergency Use Authorization (EUA.) https://www.nubc.org/nubc-announces-new-condition-codes-effective-february-1-2021

For claims received (not based on date of service, admission date, or discharge date) on or after February 1, 2021 Medicare instructs providers to append Condition Code 90 to claims with Expanded Access Approved (EA) services. The EA program, sometimes referred to as ?compassionate use,? authorizes investigational drugs, biologicals, or medical devices for treatments outside of clinical trials when no other therapy or treatment is available for patients with diseases or conditions that are serious or life-threatening. The treatment offered under an EA have not been approved by the FDA and may or may not be effective in treatment.

For claims received (not based on date of service, admission date, or discharge date) on or after February 1, 2021 Medicare instructs providers to append Condition Code 91 to claims with treatment provided as part of an Emergency Use Authorization (EUA). EUA therapy or treatments are approved by the FDA during the Public Health Emergency when no alternative treatments are available. These treatments haven?t been granted full FDA approval. Examples of recent therapies approved by the FDA under EUA are monoclonal antibody drugs Regeneron, combo Casirivimab and Imdevimab, Bamlanivimab, Remdesivir and convalescent plasma.

On November 20, 2020. CMS released MLN Matters MM12049: https://www.cms.gov/files/document/mm12049.pdf

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PARA Weekly eJournal: December 23, 2020

RACS TO AUDIT INPATIENT DEFIBRILLATOR IMPLANT CLAIMS

On October 6, 2020, CMS approved a new nationwide Recovery Audit Contractor issue to examine whether medical necessity documentation requirements were met for inpatient implantable defibrillator claims.Since many providers remain unaware of the special restrictions placed on coverage of ICD implant procedures, hospitals may be blindsided by the impending audits and resulting recoupments.

RAC auditors will focus on inpatient defibrillator cases performed after a new National Coverage Determination became effective on February 15, 2019.The NCD requires a formal ?shared decision making visit? between the patient and the physician prior to the procedure.If that visit was not conducted, reimbursement will be recouped in full.Since inpatient ICD cases are typically reimbursed at between $30,000 and $90,000, the threat is significant.

A link and an excerpt from the approved issue announcement on the CMS website: https://www.cms.gov/node/1439781 Issue Name: 0195-Implantable Automatic Defibrillator- Inpatient Procedure: Medical Necessity and Documentation Requirements Date: 2020-10-06 Review Type: Complex Provider Type: Inpatient Hospital MAC Jurisdiction: All A/B MACs Description: The implantable automatic defibrillator is an electronic device designed to detect and treat life-threatening tachyarrhythmias. The device consists of a pulse generator and electrodes for sensing and defibrillating. Medical documentation will be reviewed for medical necessity to validate that implantable automatic cardiac defibrillators are used only for covered indications.

PARA clients can identify the number of inpatient cases at risk of audit by using the CMS Claims Database on the PARA Data Editor. Search inpatient claims for DRGs 222, 223, 224, 225, 226, and 227:

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PARA Weekly eJournal: December 23, 2020

RACS TO AUDIT INPATIENT DEFIBRILLATOR IMPLANT CLAIMS

The National Coverage Determination for Implantable Automatic Defibrillators (NCD 20.4) became effective February 15, 2019.The NCD is available on the CMS Coverage Database at the link below: https://www.cms.gov/medicare-coverage-database/details/ncd-details.aspx?NCDId=110&ncdver= 4&DocID=20.4&bc=gAAAAAIAAAAA&

The NCD requires that most patients receiving an initial ICD placement must first attend a ?formal shared decision making visit? with their doctor prior to the ICD placement procedure.If the ICD is placed without the required prerequisite visit, Medicare will not cover the procedure.Since payment is not predicated upon submitting the visit documentation in advance, many hospitals have been billing ICD cases and receiving substantial payments while unaware that the cases did not meet medical necessity.

Although the documentation of the shared decision making visit may not normally be found in the hospital medical record, hospitals remain fully at risk.Here?s an excerpt from the Medicare Program Integrity Manual, Chapter 3 - Verifying Potential Errors and Taking Corrective Actions: https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/pim83c03.pdf 3.2.3.3 - Third-party Additional Documentation Request (Rev. 10228; Issued: 07-27-20; Effective: 08-27-20; Implementation: 08-27-20) ?

Unless otherwise specified, the MAC, RAC and UPIC shall request information from the billing provider/supplier. The treating physician, another clinician, provider, or supplier should submit the requested documentation. However, because the provider selected for review is the one whose payment is at risk, it is this provider who is ultimately responsible for submitting, within the established timelines, the documentation requested by the MAC, CERT, RAC and UPIC. In addition to other coverage requirements, the shared decision-making visit applies to the following categories of patients who may be considering an implantable ICD procedure: -

Patients with a prior MI and a measured Left Ventricular Ejection Fraction (LVEF) < 0.30

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Patients who have severe, ischemic, dilated cardiomyopathy but no personal history of sustained VT or cardiac arrest due to VF, and have NYHA Class II or III heart failure, LVEF < 35%

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Patients who have severe, non-ischemic, dilated cardiomyopathy but no personal history of cardiac arrest or sustained VT, NYHA Class II or III heart failure, LVEF < 35%, been on optimal medical therapy for at least three months

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Patients with documented, familial or genetic disorders with a high risk of life-threatending tachyarrhythmias (sustained VT or VF, to include, but not limited to, long QT syndrome or hypertrophic cardiomyopathy 24

PARA Weekly eJournal: December 23, 2020

RACS TO AUDIT INPATIENT DEFIBRILLATOR IMPLANT CLAIMS

However, the shared decision-making visit is not required for patients with a personal history of sustained Ventricular Tachyarrhythmia (VT) or cardiac arrest due to Ventricular Fibrillation (VF), or patients that have had an ICD previously and require an ICD replacement procedure.

The formal shared decision-making encounter must occur between the patient and a physician or qualified non-physician practitioner using an evidence-based decision tool on ICDs prior to initial ICD implantation. The Colorado Program for Patient Centered Decisions offers such a tool at the following website: https://patientdecisionaid.org/icd/

https://patientdecisionaid.org/wp-content/uploads/2016/06/ICDInfographic-4.8.19.pdf

Hospitals would be well served to require evidence of the shared decision-making visit prior to performing an implantable defibrillator procedure for a Medicare beneficiary for both inpatient and outpatient cases.The procedure is costly due to the expensive purchased implants ? lost revenue for these procedures is more than benign because the significant cost of the implanted defibrillator device itself is at risk.

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PARA Weekly eJournal: December 23, 2020

CHANGE IN STORE FOR NEW NCCI EDIT: PT/OT EVALS WITH 9928X

In response to frustration expressed by several clients regarding the NCCI edits that prevent reporting a physical therapy or occupational therapy evaluation with an emergency department visit, PARA registered an objection with the CMS National Correct Coding Initiative contractor, Capitol Bridge, LLC, on November 25, 2020.

Capitol Bridge replied on the next business day, 11/30/2020, that the edits will be changed ? however, it did not indicate what the change will be or on what date the change will be effective. Here is their email:

PARA?s objection was conveyed by email dated 11/25/2020; the reply from Capitol Bridge was received the next business day.It appears that the decision to ?change? the edits was made prior to our objection.The full text of our objection is provided below.

I represent a revenue cycle consulting firm; I am writing on behalf of several client hospitals regarding the new NCCI edits added effective October 1, 2020 which disallow payment for a physical or occupational therapy evaluation (CPTÂŽ s 97161-97169) with an emergency department visit code (CPTÂŽ?s 99281-99285). Here is an excerpt from the NCCI PTP Edits V263r0 effective 10/1/2020:

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PARA Weekly eJournal: December 23, 2020

CHANGE IN STORE FOR NEW NCCI EDIT: PT/OT EVALS WITH 9928X

We find the edits are ill-informed and unjust for the following reasons: - The abrupt reduction in reimbursement for these PT and OT evaluations is causing unexpected material financial and operational harm to hospitals. Shouldn?t there be some ?due process?notice and comment period prior to imposing an edit that financially damages hospitals rather than an unexplained fiat?

- These new CCI edits reduce Medicare OPPS reimbursement in a manner that is inconsistent with program policy.

These edits hold the same financial impact as ?packaging?payment for PT and OT evaluations to an ED visit code, while suppressing reporting revenue which represents a distinct cost from a separate, non-ED cost center. Under OPPS, the APC rate-setting process for APCs 5021, 5022, 5023, 5024, and 5025 (applicable to CPTÂŽ s 99281-99285) could not have included packaging the expense of PT or OT evaluations into the ED visit charge because this CCI edit was not in place at the time rates were calculated. Additionally, PT and OT evaluations are status A, not paid under OPPS but paid under the MPFS - The new edits prohibiting a PT or OT evaluation to be billed with ED visits are limited to only ED visit HCPCS 9928x and not all OPPS status J2 codes, such as G0379, G0380-G0384, and G0463. This belies a well-informed process.

What input was sought or obtained in considering the addition of these new edits?

- PT and OT evaluations provided in the emergency department setting are medically necessary services that represent a specific cost to facilities, as these services are performed by facility-employed PTs and OTs, not the ED physician. Hospitals should be permitted to report the services performed by therapists in the Emergency Department setting without contending with an NCCI edit or line item denial, as the cost of rendering those services is valid, measurable, and not included in the Emergency Department revenue center nor in the APC reimbursement for the ED visit codes - CMS should want hospitals to report HCPCS codes for PT and OT evaluations when performed in the ED, as it may prove useful to researchers in determining whether an evaluation has positive outcomes on emergency department patients discharged from outpatient status with various diagnoses

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PARA Weekly eJournal: December 23, 2020

CHANGE IN STORE FOR NEW NCCI EDIT: PT/OT EVALS WITH 9928X

- CMS should want hospitals to report HCPCS codes for PT and OT evaluations when performed in the ED, as it may prove useful to researchers in determining whether an evaluation has positive outcomes on emergency department patients discharged from outpatient status with various diagnoses - The imposition of these entirely inexplicable edits damages hospital reimbursement at a time when hospitals are stressed financially due to the COVID-19 PHE. We are confident that Medicare did not intend to simply cut emergency department services reimbursement ? all other actions by CMS during the PHE have been on the whole incredibly supportive of community hospitals and healthcare providers in general. Surely the addition of these NCCI edits were poorly timed, to say the least One final piece of information ? here is a link and an excerpt from ?Physical Therapist Practice in the Emergency Department Observation Unit: Descriptive Study?which might illuminate the value of services rendered by therapists in the ED setting: https://academic.oup.com/ptj/article/95/2/249/2684151

?? The first priority of the physical therapist in the EDOU in determining discharge disposition is to determine the patient?s ability to mobilize safely with available social supports and environmental constraints. If the patient is not independent or there is not support at home, recommendations are made regarding appropriate level of rehabilitation care. Physical therapy EDOU management also focuses on care coordination with the medical team to provide symptom management (pain medication, antiemetics) to maximize function and promote self-management of the patients?conditions. Finally, physical therapist services in the EDOU provide for referral to appropriate level and timing of follow-up services such outpatient physical therapy. ? ?

We hope you find this to be a cogent argument for removing the new NCCI edits between the ED visit codes (9928x) and the Physical or Occupational Therapy evaluation codes, 97161-97169.

Please respond at your earliest opportunity, our clients are deeply concerned and frustrated. Thank you in advance for your time in considering these points.

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PARA Weekly eJournal: December 23, 2020

HIGH THROUGHPUT COVID-19 TEST CODING UPDATE

Medicare will change how it reimburses high-throughput COVID-19 testing on 1/1/2021. High-throughput laboratory equipment is capable of automated processing of more than 200 specimens a day. Operators must have specialized technical training to operate the equipment properly.In April, 2020, Medicare created two HCPCS which represent high-throughput testing, which CMS will reimburse at $100 per test through December 31, 2020:

Report U0003 in place of tests that were reported as 87635 (infectious agent detection by nucleic acid (DNA or RNA); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), amplified probe technique) when high-throughput technology is used.

HCPCS U0004 should be reported in place of U0002 (2019-ncov Coronavirus, sars-cov-2/2019-ncov (covid-19), any technique, multiple types or subtypes (includes all targets), non-cdc.) when high-throughput technology is used.

Effective January 1, 2021 and throughout the Public Health Emergency, Medicare will reduce payment for U0003 and U0004 to $75, but Medicare will pay an additional $25 for new add-on HCPCS code U0005:

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PARA Weekly eJournal: December 23, 2020

HIGH THROUGHPUT COVID-19 TEST CODING UPDATE

U0005 may be reported if the COVID-19 lab test is completed within two calendar days of the specimen collection AND the laboratory completed 51% of high throughput testing for all patients (not only Medicare beneficiaries) in the previous month within two calendar days. The laboratory must maintain records of its monthly assessments of timely results reporting.CMS instructs MACs to conduct claim reviews and audits to ensure providers are compliant with the Ruling.

This change in reimbursement is addressed in Medicare?s Frequently Asked Questions publication regarding Medicare FFS Billing, under D. High Throughput COVID-19 Testing: https://www.cms.gov/files/document/03092020-covid-19-faqs-508.pdf

?

CMS provides a partial list of accepted technology high-throughput machines In Ruling 2020-1-R dated April 14, 2020: https://www.cms.gov/files/document/cms-2020-01-r.pdf Medicare re-evaluated testing resources in Ruling 2020-1-R2 dated January 1, 2021: https://www.cms.gov/files/document/cms-ruling-2020-1-r2.pdf HCPCS U0003 and U0004 should not be used when testing for COVID-19 antibodies.

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PARA Weekly eJournal: December 23, 2020

PARA'S PRICE TRANSPARENCY TOOL

TENREASONS Why Hospitals Choose The Price Transparency Tool From PARA HealthCare Analytics and HFRI. 1.

Ensure compliance with the January 1, 2019 and January 1, 2021 CMS mandates for Price Transparency: a. Post a listing of all services and prices available at the facility in a machine-readable format b. Include payer specific reimbursement information for all services available at the facility

2.

Provide customized and meaningful information for patients. Take the guess work out of obtaining an estimate.

3.

Improve collections. Patients will know their liability before the service is provided.

They can even prepay!

4.

Web based solution. Simple implementation. No software to install.

5.

Comprehensive tool that pulls a. Top services at a facility b. User?s insurance information via eligibility checking c. Registration information to return usage statistics readily available to the facility 31

PARA Weekly eJournal: December 23, 2020

PARA'S PRICE TRANSPARENCY TOOL

TENREASONS, cont.

6.

Highly customizable a. The style and functionality of the tool to be directly embedded on the facility website b. The services available on the Decision Tree and how they are presented (i.e. descriptions, categories) c. The Prices that are presented (e.g., Average Line Charge, Average Package Charge, Average CDM Charge, etc.) d. The programming to meet all expectations and functionality

7.

8.

9.

Always up to date with the latest information for all users. With no additional work on behalf of the hospital once implemented. Fully serviced and managed on PARA?s servers with all data and functionality accessible by the facility through the PARA Data Editor.

Ongoing feature upgrades and improvements that reflect changes in practice, technology, and services.

Reporting capabilities to review all activity on hospital website and what services are being shopped.

10. Most cost-effective solution in the industry. PARA?s

cost to deploy its solution is market competitive and in line with what CMS is saying healthcare organizations should pay for to implement a patient price estimator.

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PARA Weekly eJournal: December 23, 2020

COVID-19 UPDATED 12/7/2020

7, r e b m De c e 0 2 0 2

PARA Healt h Car e An alyt ics con t in u es t o u pdat e COVID-19 codin g an d billin g in f or m at ion based on f r equ en t ly ch an gin g gu idelin es r egu lat ion s f r om CM S an d payer s. All codin g m u st be su ppor t ed by m edical docu m en t at ion .

Updat es f r om t h e pr eviou s ver sion of t h is COVID-19 paper ar e in dicat ed in r ed, an d t est t ables ar e u pdat ed.

ICD-10-CM Of f icial Codin g an d Repor t in g Gu idelin es f or Cor on avir u s, ef f ect ive Apr il 1, 2020 t h r ou gh Sept em ber 30, 2020, m ay be dow n loaded f r om t h e lin k below : https://apps.para-hcfs.com/para/Documents /COVID-19%20(Updated%2012-07-2020).pdf

Download the full 24-page update dated December 7, 2020, by clicking the link above or the document to the right.

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PARA Weekly eJournal: December 23, 2020

PALLIATIVE CARE AND COVID-19

Wh at is t h e COVID-19 Hospice Respit e Car e Relief Act of CY2020? Th is Act w as in t r odu ced t o Con gr ess by Sen at or s Br ow n an d Capit o t o alleviat e dif f icu lt ies f or h ospice or gan izat ion s pr ovidin g r espit e car e in sit u at ion s w h er e f am ily car egiver s ar en?t available t o car e f or h ospice pat ien t s f or t h e cu r r en t f ive-day lim it . For exam ple, w h en f am ily car egiver s h ave been diagn osed w it h COVID-19 an d m u st isolat e f r om h igh r isk h ospice pat ien t s.

In addition, there may be patients unwilling to enter a facility due to the potential risk of contracting COVID-19 or there may be no respite beds available. https://www.congress.gov/bill/116th-congress/senate-bill/4423

Medicare?s Hospice Respite Care Benefit enables Medicare beneficiaries receiving hospice services and their caregiver(s) to be eligible for short-term, inpatient, respite care services.

Medicare will cover respite care if the hospice beneficiary?s primary caregiver is ill, needs rest, or is otherwise unable to care for the hospice patient.

However, there are limitations under the current law which restricts Medicare beneficiaries to access the hospice respite care benefit in an inpatient facility setting only. Examples of facilities could be a hospital, inpatient hospice center or nursing home. The current restrictions are limited to a five-day stay.

With the adoption of this amendment, it will provide the Secretary of Health and Human Services (HHS) with the authority to make the hospice respite care benefit flexible during ANY current public health emergency (PHE), including the current COVID-19 crisis.

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PARA Weekly eJournal: December 23, 2020

PALLIATIVE CARE AND COVID-19

This expanded benefit will open up access for hospice beneficiaries in two (2) ways: 1.Authority to waive the five-day maximum benefit when the caregiver(s) is unable to provide care due to illness or isolation, for up to 15 days.

2.Authority to waive the requirement that respite care only be provided in the inpatient setting, expanding the hospice respite benefit available to hospice patients in their place of residence, protecting and reducing the patient from COVID-19 exposure risks.

This bill is currently still in legislation and the progress can be tracked at the link below: https://www.govtrack.us/congress/bills/116/hr8322

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PARA Weekly eJournal: December 23, 2020

MLN CONNECTS PARA invites you to check out the mlnconnects page available from the Centers For Medicare and Medicaid (CMS). It's chock full of news and information, training opportunities, events and more! Each week PARA will bring you the latest news and links to available resources. Click each link for the PDF!

Th u r sday, Decem ber 17, 2020 New s

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MLN Web-Based Training: Complete Training & Save Certificates by January 31 IRF Quality Reporting Program: December Refresh LTCH Quality Reporting Program: December Refresh COVID-19: Stress & Resilience, Crisis Standards of Care COVID-19: Designated Hospitals Lessons Learned and Patient Surge Management Strategies

Com plian ce -

Ambulance Fee Schedule and Medicare Transports

M LN M at t er sÂŽ Ar t icles -

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2021 Annual Update of Per-Beneficiary Threshold Amounts CY 2021 Update for Durable Medical Equipment, Prosthetics, Orthotics and Supplies (DMEPOS) Fee Schedule Summary of Policies in the Calendar Year (CY) 2021 Medicare Physician Fee Schedule (MPFS) Final Rule, Telehealth Originating Site Facility Fee Payment Amount and Telehealth Services List, CT Modifier Reduction List, and Preventive Services List International Classification of Diseases, 10th Revision (ICD-10) and Other Coding Revisions to National Coverage Determination (NCDs)--April 2021 ? Revised

Pu blicat ion s -

Opioid Treatment Programs (OTPs) Medicare Enrollment ?

Revised Opioid Treatment Programs (OTPs) Medicare Billing and Payment ? Revised

View this edition as a PDF (PDF)

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PARA Weekly eJournal: December 23, 2020

There was ONE new or revised MedLearns released this week.

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

1

FIND ALL THESE MEDLEARNS IN THE ADVISOR TAB OF THE PDE

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PARA Weekly eJournal: December 23, 2020

The link to this MedLearn MM12080

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PARA Weekly eJournal: December 23, 2020

There were SIX new or revised Transmittals released this week.

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

6

FIND ALL THESE TRANSMITTALS IN THE ADVISOR TAB OF THE PDE

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PARA Weekly eJournal: December 23, 2020

The link to this Transmittal R10523CP

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PARA Weekly eJournal: December 23, 2020

The link to this Transmittal R10524PI

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PARA Weekly eJournal: December 23, 2020

The link to this Transmittal R10525OTN

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PARA Weekly eJournal: December 23, 2020

The link to this Transmittal R10521FM

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PARA Weekly eJournal: December 23, 2020

The link to this Transmittal R10520OTN

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PARA Weekly eJournal: December 23, 2020

The link to this Transmittal R10519COM

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Randi Brant ner Vice President of Analytics 719.308.0883 rbrantner@hfri.net