Medicare Updates from WPS GHA AAHAM Hawthorn Chapter & HFMA of Greater St. Louis

(CMS Internet-Only Manual (IOM) 100-09, Chapter 6, Section 20.8.6.) CMS prohibits any entity other than WPS GHA or CMS from recording this presentation. (CMS Internet-Only Manual (IOM) 100-09, Chapter 6, Section 20.8.6.)

Agenda Program News and Updates Medicare Outpatient Observation Notice Discarded Drugs – JW modifier Social Security Number Removal Initiative Changes for Quality of Care Reviews

Agenda Announcements Midwestern UPIC New Recovery Audit Contractor (RAC) WPS GHA Portal Multi-Factor Authentication A Day With Medicare

Program News and Updates Recent and Upcoming Changes Program News and Updates

Medicare Outpatient Observation Notice (MOON) The NOTICE Act Medicare Outpatient Observation Notice (MOON)

NOTICE Act Inform patient of implications of observation status Not a Part A benefit Possible increase in cost sharing Does not count toward 3 day qualifying stay Required for SNF coverage

Required March 8, 2017 The MOON Standardized notice required by all hospitals Including critical access Required March 8, 2017

Who Receives the MOON Given to beneficiaries who are: Entitled to Medicare benefits Even if: No Part B coverage Member of MA plan Medicare isn’t primary Receiving observation services > 24 hours Even if subsequently admitted as inpatient or transferred

Written and Oral Notice Deliver written notice No later than 36 hours after start of observation services Sooner if discharged or admitted as inpatient Oral explanation also required In conjunction with written notice Document that explanation was provided

Signature Requirement Must be signed by patient or their representative Staff giving notice signs if patient refuses Must include: Name and title of staff member Statement certifying notice was presented Date and time of refusal

24 Hour Timeframe Clock time documented in chart Patient begins receiving observation services In accordance with physician’s order 24 hours measured in “elapsed” time Not billed time

Observation Time Ends All medically necessary observation services are completed Could coincide with or occur before discharge

Modifier JW Discarded Drugs

Policy for JW Modifier Indicates drug discarded/not administered to any patient Single dose vial Single use package Mandatory as of January 1, 2017 Prior use at MAC discretion Document discarded drug in medical record

Applies To Physician’s office CAH OPPS Status indicator “G” or “K” ASC

Does Not Apply To Inpatient settings RHC FQHC Pharmacies and compounding pharmacies

Inappropriate Use Multi-dose vials Unlisted drugs No payment expected from any payer Drugs under Competitive Acquisition Program (CAP) Amount discarded cannot be quantified Services packaged into APC rates Status indicator “N” Drugs dispensed, but not administered

Documentation Medical record must contain Amount of drug administered Amount of drug discarded

Billing 2 separate lines on same claim Number of units administered Number of units discarded With JW modifier Charges for each line should reflect amount billed Coinsurance and deductible applied

Example 1 Single use vial 90 units administered 10 units discarded 100 units of drug 90 units administered Billed on one line 10 units discarded Billed on second line with JW modifier

Example 2 Single use vial 20 mg administered 5 mg discarded 1 unit = 25 mg 20 mg administered 5 mg discarded Single line billed with 1 unit JW not appropriate

Overfill Discarded drug policy does not apply to “intentional overfill” ASP based on FDA approved label Amount in excess No expense to provider Cannot bill Medicare

Social Security Number Removal Initiative New Numbers, New Cards Social Security Number Removal Initiative

Background HIC contains SSN of primary beneficiary Prefix or suffix gives additional details New rules mandated by MACRA Decrease risk of identity theft Increase safety of Program funds Unique numbers and redesigned cards Deceased, active and new beneficiaries

Medicare Beneficiary Identifier Where: C – Numeric 1 thru 9 A – Alphabetic Character (A...Z); Excluding (S, L, O, I, B, Z) N – Numeric 0 thru 9 AN – Either A or N ***NOTE: Alphabetic characters are Upper Case ONLY Position 1 – numeric values 1 thru 9 Position 2 – alphabetic values A thru Z (minus S, L, O, I, B, Z) Position 3 – alpha-numeric values 0 thru 9 and A thru Z (minus S, L, O, I, B, Z) Position 4 – numeric values 0 thru 9 Position 5 – alphabetic values A thru Z (minus S, L, O, I, B, Z) Position 6 – alpha-numeric values 0 thru 9 and A thru Z Position 7 – numeric values 0 thru 9 Position 8 – alphabetic values A thru Z (minus S, L, O, I, B, Z) Position 9 – alphabetic values A thru Z (minus S, L, O, I, B, Z) Position 10 – numeric values 0 thru 9 Position 11 – numeric values 0 thru 9

Transition Timeline Systems ready by 4/1/18 HIC or MBI used until 12/31/19

During Transition Message on eligibility response when new card sent RA will include MBI if HIC was used Beginning 10/1/18 Limited use of HIC after transition period Appeals, adjustments, etc.

Changes for Quality of Care Reviews QIO Manual Update Changes for Quality of Care Reviews

Beneficiary Complaints Quality of Care Reviews Providers 14 days to send medical records Once record request received Faxing records recommended QIO 30 days to complete review

Good to Know Announcements

Integrating Safeguard Functions Midwestern UPIC

Integrating Integrity UPIC ZPIC/PSC Medicare Medicaid MIC

Midwestern Jurisdiction Administered by AdvanceMed Eliminate duplication Improve efficiency Detection and prevention of fraud, waste and abuse

New Recovery Audit Contractor (RAC) Cotiviti New Recovery Audit Contractor (RAC)

Cotiviti Recovery Auditor for Regions 2 & 3 Teleconference held 02/09/17 Recording of call in WPS GHA’s Learning Center

Combining Websites to Serve You Better WPS GHA Portal

And the Two Shall Become One WPSGHA .com (Portal) MedicareInfo .com (C-SNAP) WPSMedicare.com

Welcome to the WPS GHA Portal WPS GHA’s new provider on-line experience

Public vs. Transactional Functions No PHI or PII No login required LCDs News Education information Articles Departmental information Fees Contains PHI and/or PII Unique user name and password required for login Used to check: Eligibility Claim status Redetermination status Online RAs

Multi-Factor Authentication Don’t Delay, Opt-In Today! Multi-Factor Authentication

Multi-Factor Authentication (MFA) CMS requirement Voluntary For now! Unique temporary code to verify identification To access transactional side of Portal

Education Opportunities! WPS GHA’s Learning Center & ADWM Education Opportunities!

WPS GHA’s Learning Center Online access to WPS GHA education Live Events On-Demand training Certificate of Achievement Available after completion of all course content May include pre/post assessment May include a follow up survey May be turned into accrediting organizations for CEUs

WPS GHA’s Learning Center https://wpsgha.litmos.com

A Day With Medicare Who What Why When Where How (much) Any provider in Jurisdiction 5 What 12 breakout sessions Keynote speaker Q & A forum Why Opportunity for education Improve National Paid Claims Error Rate When April 25, 2017 July 11, 2017 July 13, 2017 Where St. Charles, MO Salina, KS Des Moines, IA How (much) Free!

Questions

Disclaimer WPS GHA has produced this material as an informational reference. Every reasonable effort has been made to ensure the accuracy of this information at the time of publication. WPS GHA makes no guarantee that this information is error-free and bears no liability for the results or consequences of the misuse of this information. The provider alone is responsible for correct submission of claims. The official Medicare Program provisions are contained in the relevant laws, regulations and rulings and can be found on the Centers for Medicare & Medicaid Services (CMS) website at www.cms.gov.

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