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January 2014 Jean C. Russell, MS, RHIT Richard Cooley, BA, CCS

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Presentation on theme: "January 2014 Jean C. Russell, MS, RHIT Richard Cooley, BA, CCS"— Presentation transcript:

1 January 2014 Jean C. Russell, MS, RHIT Richard Cooley, BA, CCS Matthew H. Lawney MSPT, MBA, CHC, 518-430-1144

2 2 Agenda Visit Codes (E/M Services) ED E/M Changes Clinic E/M Changes Professional/Technical Implications Pricing Implications Observation Changes Proposed changes for Provider- Based Reporting Incident to Guideline Changes

3 3 Visit Codes (E/M Services)

4 4 Proposed Changes CMS proposed to replace the current five ED E/M visits for type A and type B ED with a single one for each type 99281-99285 G0380-G0384 This proposal was NOT accepted in the final rule CMS also proposed to replace the current ten technical clinic E/M visits with a single code This proposal WAS adopted

5 5 ED E/M Proposal CMS did not adopt a single G code for reporting ED E/M Commenters felt the range of services provided in the ED varies too significantly to reduce all visits to the single level CMS decided to not make any changes They are continuing to investigate No change to the codes No change to split billing No change to requirements for technical E/M guidelines for the ED

6 6 Clinic Visit E/M Codes New Clinic E/M 99201 – New Pt Lvl 1 99202 – New Pt Lvl 2 99203 – New Pt Lvl 3 99204 – New Pt Lvl 4 99205 – New Pt Lvl 5 Established Clinic E/M 99211 – Est Pt Lvl 1 99212 – Est Pt Lvl 2 99213 – Est Pt Lvl 3 99214 – Est Pt Lvl 4 99215 – Est Pt Lvl 5 Primary service performed and reported in a clinic is a medical visit

7 7 Split Billing Professional Bill Technical Bill

8 8 E/M Clinic Visit Split Billing Medicare expects visits to a hospital based clinic with a hospital based physician to be split billed Prior to January 1, 2013, hospitals would report an E/M professionally based on CMS/CPT guidelines (either 1995 or 1997) And an E/M technically based on hospital developed technical clinic E/M guidelines Professional Bill (POS 22) 99214 Technical Bill 99212

9 9 Clinic E/M Change Effective January 1, 2014 there is only one code reported technically for clinic visits to a hospital- based clinic: G0463 - Hospital outpatient clinic visit for assessment and management of a patient This code replaces all of the clinic E/M codes reported technically (99201-99205 and 99211- 99215) No change to the professional reporting rules and codes

10 10 Final Clinic Changes – Impact on Beneficiary Co-Pay

11 11 Summary of the Clinic Change All clinic visits billed technically to Medicare will be reported with the same code (G0463) regardless of the complexity / duration of the visit Beneficiary co-payment for technical component alone is close to $40 (national unadjusted); 40% of the total There is no longer a differentiation technically between new and established patient reported codes The professional clinic E/Ms have not changed

12 12 Impact of the Clinic Change CMS has acknowledged the challenges faced by hospital for developing guidelines for determining the appropriate visit level No longer necessary to develop Medicare technical clinic E/M guidelines ED guidelines are still required Other payers (e.g., Medicaid DOH and OMH) that are billed technically will expect the 99201-99215 codes until we are notified otherwise

13 13 Charging Suggestions Suggest hospitals keep the usual ten clinic E/M levels with their charges varying by clinic E/M (i.e., 99201-99205 and 99211-99215) and then map these variable charges to the single G0463 for Medicare and (most likely) Medicare HMOs Charges may not be greater than Medicare APC payment for the lower level visits (e.g., 99211) Should all payers be charged the same? Issue – Medicare has a claim suspension edit in some cases when payment exceeds submitted charges

14 14 Telephone/Internet Assessment and Management New E/M codes for 2014 Not paid under OPPS or under MPFS 99446, Inter-professional telephone/Internet assessment/management service provided by a consultative physician includes verbal and written report to the patient's treating/requesting physician; 5-10 minutes of medical consultative discussion/ review 99447 … 11-20 minutes 99448 … 21-30 minutes 99449 … 31 minutes or more

15 15 Telephone/Internet Assessment and Management Used when face-to-face contract may not be timely or feasible Not used when the patient has been transferred to the consulting doctor before the assessment May include review of medical records, diagnostic tests, … Majority of the service time (more than 50%) must be devoted to the actual verbal/internet discussion Single code for cumulative time Request for consult must be documented

16 16 Hypothermia Tx 99481, Total body systemic hypothermia for critically ill neonate (per day) (List separately in addition to primary code) 99482, Selective head hypothermia in critically ill neonate per day (List separately in addition to primary code) Add-on codes to 99291-99292, critical care, or 99468-99469, neonate IP critical care Unconditionally packaged (SI N) under OPPS and not paid under the MPFS

17 17 Observation

18 18 Observation Paid as a composite under APCs (APC status Indicator Q3) Two composites in 2013 – 8002 and 8003 Requires at least 8 hours (units of 8) With a high level E/M code reported the day before or day of observation Without a surgical code reported the day before or day of observation

19 19 Observation Changes for 2014 Significant increase in packaged services (e.g., lab and stress tests) Reduction of clinic E/M codes to a single G code (G0463) Required changes to observation composites

20 20 Extended Assessment and Management Composite (EAM) In 2013 there were two composite EAMs – 8002 and 8003

21 21 G0378 (8 or more units) Revenue code 762 (observation) Reported with: G0379 (direct referral) on the same date of service, or 99205 / 99215 (level V clinic visit) on the same date or day before Reported without a surgical (Status T) procedure on the same day or day before National APC Rate (2013) = $440.70 No diagnosis requirement Level I Extended Assessment and Management - APC 8002

22 22 G0378 (8 or more units) Revenue code 762 (observation) Reported with: 99284 / 99285 (high-level ED visit), or 99291 (critical care), or G0384 (high level Type B ED visit) On the same day or day before the observation Reported without a surgical (Status T) procedure on the same day or day before National APC Rate (2013) = $798.47 No diagnosis requirement Level II Extended Assessment and Management APC 8003 High Level E/M

23 23 Extended Assessment and Management Composite (EAM) Effective 1/1/2014 there will be only one composite EAM – 8009 G0378 (8 or more units), revenue code 762 (observation) with no diagnosis requirement Reported with an E/M service: 99284 / 99285 (high-level ED visit)99291 (critical care) G0384 (high level Type B ED visit)G0463 (clinic E/M) Or G0379 (direct referral to observation from physician ofc) On the same day or day before the observation Reported without a surgical (Status T) procedure on the same day or day before National APC Rate (2014) = $1,198.91

24 24 Observation Payment

25 25 G0379 – Direct Referal G0379 – Direct referral to observation, moved to APC 608, payment increased to $327.85 (2014) from $175.79 (2013) 2012 - reimbursed as a 99211 (APC 604) 2013 - reimbursed as a 99205 – new patient clinic level V 2014 – reimbursed between a level IV and V ED E/M Paid only when observation is not paid Improved reflection of the cost associated with direct referrals to observation

26 26 Medicare Physician Fee Schedule Proposed/Final Changes Impacting OPPS

27 27 Provider-Based Clinics CMS acknowledges that there is an increasing trend toward hospital acquisition of physician practices Resulting in increasing numbers of provider-based clinics Medicare payments in these clinics are subject to two co-pays, one for the technical component and one for the professional component Generally the combination of the two results in a higher co-pay than would be present for a free standing physicians office

28 28 Provider-Based Clinics CMS is considering collecting information on these types of visits There several proposed methods for collecting this information: (1) Creating a new POS (place of service) for off campus departments of a provider (2) Creating a new modifier that could be reported with every code provided in an off campus provider based department (3) Asking hospital to break out costs/charges for these cost centers on the cost report

29 29 Provider-Based Clinics CMS has received and reviewed the comments and will let us know what they decide Watch for more information in the coming year

30 30 Incident-To Guidelines Medicare now requires the compliance with state law as a condition of payment for services furnished incident to physician and other practitioner services Would enable the federal government to recover funds paid if services are not furnished in accordance with state law Should not change anything as providers should have already been following the applicable state laws and state practice acts

31 31 Questions and Discussion

32 32 Contact Us Richard Cooley Phone: 518-430-1144 Email: RCooley@EpochHealth.ComRCooley@EpochHealth.Com Matthew Lawney Phone: 845-642-6462 Email: mlawney@EpochHealth.Commlawney@EpochHealth.Com Jean Russell Phone: 518-369-4986 Email: JRussell@EpochHealth.ComJRussell@EpochHealth.Com

33 33

34 34 CPT ® Current Procedural Terminology (CPT®) Copyright 2013 American Medical Association All Rights Reserved Registered trademark of the AMA

35 35 Disclaimer Information and opinions included in this presentation are provided based on our interpretation of current available regulatory resources. No representation is made as to the completeness or accuracy of the information. Please refer to your payer or specific regulatory guidelines as necessary.

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