Question: Has there been any mention about a delay in ICD-10? What would happen if we submitted ICD-9 codes for dates of service on or after October 1, 2015?
Answer: ICD-10 is set to go into effect on October 1, 2015 with no discussion of delay at this point. If claims are submitted on or after October 1, 2015 without a valid ICD-10 code, they will be rejected. The Medicare claims processing systems do not have the capability to accept ICD-9 codes for dates of service after September 30, 2015, or accept claims that contain both ICD-9 and ICD-10 codes for any dates of service.
Proposed physician fee schedule 2016: PQRS requirements will stay the same but expect measures to change
As published by DecisionHealth, August 1, 2015 by Julia Kyles, CPC-A
Providers who were caught off guard by this year’s tougher quality reporting standards should start thinking about their 2016 action plan now. Medicare will not add to the requirements for such methods as individual claims-based or registry reporting, but it does intend to revise the list of individual measures and measures groups that will be available next year, according to the 2016 proposed physician fee schedule (p. 397). Page numbers throughout this article refer to the public inspection version of the proposed rule. A pdf is available in the Guidelines & Changes section of the Anesthesia & Pain Coder’s Pink Sheet website. See Proposed rule tightens incident-to rule, creates opportunities for CRNAs.
The physician quality reporting system (PQRS) will end in 2018, and the merit-based incentive payment system (MIPS) will begin. But until that time, Medicare will focus on aligning the program’s requirements with other quality reporting programs, such as meaningful use. And for 2016, every eligible professional who reports individual measures via claims or registry will still need to hit nine measures including one cross-cutting measure across three national quality strategy (NQS) domains.
Understand who is eligible
In the proposed rule, Medicare notes that the first PQRS pay cut triggered “many questions surrounding who must participate in the PQRS to avoid the PQRS payment adjustment.” Essentially, if a provider bills Medicare for Part B services, he or she is an eligible professional. “There are no hardship or low volume exemptions for the PQRS payment adjustment,” CMS notes and clarifies that health care professionals who bill under method II in critical access hospitals must participate in PQRS.
The only providers who are not able to participate in PQRS are those who practice in rural health clinics and federally qualified health centers and professionals who are employed by or reassign their payments to independent diagnostic testing facilities and independent laboratories (p. 399-400).
Revisions could change your PQRS plan
Selecting measures should be the first step of your annual quality reporting plan because the measures change each year. Medicare intends to make changes to available measures in 2016 that fall into six categories:
- New cross-cutting measures. Medicare will add four cross-cutting measures including falls risk assessment and falls plan of care (APCPS 7/15). And one new measure: unhealthy alcohol use, screening and brief counseling — which would replace the current measure that screens for only unhealthy alcohol use (p. 441).
- New individual and group measures. You will have 45 new measures in 2016, but only 23 of those measures will be available for claims-based reporting (p. 443). CMS no longer accepts measures that can be reported only on claims.
- NQS domain changes. Watch out for changes at the NQS level as you need to report measures that cover at least three of the domains. This year, CMS proposes to make changes to five measures, such as #131 (Pain assessment and follow-up) switching from community/population health to communication and care coordination (p. 474).
- Deleted measures. A total of 12 measures will come off the measures list, according to the proposed rule. The reasons for deletion include the measure does not add clinical value, for example #193 (Perioperative temperature management), or an improved measure is available, such as the new alcohol screening and counseling measure (p. 475).
- Changes to reporting methods for existing measures. This is another area where providers who report via claims should take note (p. 482). Medicare proposes to remove the claims-reporting option for five of the 18 measures on the list, including #44 (Coronary artery bypass graft [CABG]: preoperative beta-blocker in patients with isolated CABG surgery).
- New and revised measures groups. Medicare will add two new measures groups — multiple chronic conditions and diabetic retinopathy — and bring back cardiovascular prevention, which the agency removed in 2015 (p. 488). The agency also plans to revise the measures included in five measures groups: CABG, dementia, diabetes, preventive care and rheumatoid arthritis. Registry reporting will remain the only option for measures groups.
Proposed physician fee schedule 2016: PQRS would whittle claims-based reporting for anesthesia, pain practices
As published by DecisionHealth, August 1, 2015 by Julia Kyles, CPC-A
Anesthesia providers will be down to one anesthesia measure that they can report via claims, and pain management practices will not be able to report the new opioid management measures, if Medicare goes through with its quality reporting plans (Proposed physician fee schedule 2016: PQRS requirements will stay the same but expect measures to change).
The annual shuffle of physician quality reporting system (PQRS) measures would introduce five new anesthesia measures created by the American Society of Anesthesiology, including a replacement for #193 (Perioperative temperature management):
- Smoking abstinence.
- Perioperative temperature management.
- Prevention of post-operative nausea and vomiting.
- Procedure room to a post-anesthesia care unit transfer.
- Use of checklist or protocol for direct transfer of care of procedure room to intensive care unit.
The American Academy of Neurology introduced four measures aimed at chronic opioid treatment and one for patients with primary headache disorders.
- Chronic opioid therapy (COT) follow-up evaluation.
- Documentation of signed opioid treatment agreement.
- Evaluation or interview for risk of opioid misuse.
- Quality-of-life assessment for patients with primary headache disorders.
But there’s a catch: Only the primary headache measure is offered with a claims-based option. The other eight new measures will be registry-only if Medicare sticks to its proposed rule.
Anesthesia providers hit hardest
The proposed changes would reduce the number of measures associated with anesthesia services to one: #76 (Prevention of central venous catheter [CVC] — related bloodstream infections) and this measure isn’t that popular with anesthesia providers. According to the latest data from Medicare, it was reported only 241,017 times. By way of comparison, 4250F — the main code associated with #193 — was reported more than 5 million times in 2013.
Medicare also intends to move #44 (Coronary artery bypass graft [CABG]: preoperative beta-blocker in patients with isolated CABG surgery) to registry only, either by individual reporting or as part of the CABG measures group. But that doesn’t mean hospital-based anesthesia providers who report via claims will be able to report one measure and avoid the 2% pay cut to their 2016 payments. Medicare will look at all of the provider’s claims to determine whether he should have reported more measures.
Take 2 steps to ease the claims-based burden
If your providers are reluctant to take on the cost of registry reporting, they’re not alone. Here are two things they can do to make claims reporting easier in 2016:
- Think about PQRS measures before Jan. 1. Look at the measures your providers reported this year and consider how the proposed changes will impact them next year. For example, if a provider has been reporting unhealthy alcohol use, he’ll need to find another measure as the replacement measure will be registry-only.
- Comment on the rule. Members of the public have until 5 p.m. Eastern time, Sept. 8, to submit a comment on the proposed rule and may do so online at regulations.gov.
Follow These 4 Rules to Stay on Track With Locum Tenens Claims
Published by AAPC, July 7, 2015
Remember: You can’t bill locum tenens for ‘extra help.’
Summertime means vacations, and possibly extended holidays or sabbaticals for some of your providers. If one of your anesthesiologists takes an extended leave, your group might hire a locum tenens physician to fill in during his or her absence.
Reminder: When you hire a locum tenens physician, you can bill for her services under the absent physician’s name and Medicare identification number, still bringing money in to your practice even though your physician is away. But if you aren’t careful, you could land your practice in hot water with denials and increased payer scrutiny.
“Medicare has certain parameters that need to be met in order to bill locum tenens, and many other insurance companies adopt similar policies,” explains Laureen Jandroep, CPC, COC, CPC-I, CPPM, founder/CEO Certification Coaching Organization, LLC in Oceanville, N.J.
Dodge some of the speed bumps that might pop up when a physician takes leave by following these locum tenens tenets.
Rule 1: Locum Must Be Subbing For Another Physician
When you are billing for the locum, she must be filling in for another physician who has taken leave for some reason. You cannot hire temporary physicians as extra help and bill locum tenens, confirms Catherine Brink, BS, CMM, CPC, CMSCS, CPOM, president of Healthcare Resource Management Inc. in Spring Lake, N.J.
“The locum tenens physician must be substituting for a physician within the practice, and cannot [be] a contractual employee of the practice,” she adds.
So if Dr. A goes on vacation and you hire Dr. B to take over her case load, you might bill locum tenens for Dr. B’s services. If you hire Dr. B for two months to help out with pre-op exams, you cannot bill locum tenens.
Rule 2: Bill Locum’s Services Under Absent Physician’s ID
When billing for the locum tenens’s services, you must be sure to bill under the name and Medicare ID of the absent physician, advises Jandroep. Further, you should append modifier Q6 (Service furnished by a locum tenens physician) to any code you are billing for the locum tenens’s services.
A locum tenens claim must also include the practice group’s National Provider Identifier (NPI), and the NPI of the physician the locum is subbing for.
Example: Dr. A is on leave, and Dr. B is the locum. Dr. B sees one of Dr. A’s patients in the office and administers a total of four trigger point injections to the patient’s trapezius muscle and levator scapulae. On the claim, you should report 20552 (Injection[s]; single or multiple trigger point[s], 1 or 2 muscle[s]) for the service with modifier Q6 appended to show that you are billing for a locum. File the claim under Dr. A’s name and NPI.
Rule 3: Observe 60-Day Limit for Locums
Locums can’t fill in forever. Medicare stipulates that a locum tenens physician can substitute for the same physician for 60 continuous days, starting with his first day of service, says Jandroep. Other payers that follow locum rules might have different time constraints, she continues.
“If coverage is needed for longer than 60 days, then the covering physician should be added to the group and their NPI number [should] be used instead of the regular physician’s,” explains Jandroep.
Rule 4: Keep Detailed Locum Records
When you are employing a locum tenens physician, you should “absolutely” keep a record of all the services the locum provides, Brink recommends.
Keeping this record is good practice “in case of an audit, and for compliance with Medicare billing and coding guidelines,” she explains.