NDC (National Drug Code) for Drugs Administered and Billed
The National Drug Code (NDC) is a unique 10-digit, 3-segment numeric product identifier assigned to each medication. The segments identify the labeler or vendor, the product (strength or dosage form), and the trade package (package forms and sizes).
Medicaid has historically been about the only payor that required the NDC be included on claims when billing drugs prior to issuing payment; however, there are more payors that are now requiring the NDC be included when billing drugs. For those providers who bill drugs in addition to the procedure(s) performed, Anesthesia Billing (ABI) is requesting you submit the NDC with your charge tickets so those codes can be entered when billing the drugs. We appreciate your help with this. This will help increase your revenues and decrease your aging.
RAC (Recovery Audit Contractor) Audits
Recovery Audit Contractor (RAC) vendors are being paid on a contingency basis for identifying Medicare and Medicaid overpayments paid to providers through various auditing and review processes. Anesthesia Billing (ABI) has started seeing refund requests due to some of these audits. At this point, the main focus seems to be the place of service (POS) being charged when there is an accompanying facility claim for the same date of service (DOS), which does not match. In other words, if the facility bills an inpatient POS and the professional provider bills an outpatient POS, a refund is being requested from the professional provider.
Because the comparison between facility and professional claims is an easy target, it is important the professional claims match what is being billed by the facility. Billing the correct POS is as important as billing the correct procedure code and diagnosis code. It appears all four RACs are using automated review to locate these types of mistakes. ABI has also seen some overpayment refund requests from a few managed care payors. We foresee this becoming a more common occurrence as all payors are trying to eliminate fraud and abuse.
ABI suggests you take this time to enhance current documentation weaknesses that may exist. This includes making sure medical direction requirements are clearly documented, improving medical necessity documentation, improving documentation practices relative to the provision of evaluation and management services, and ensuring the charge tickets you submit to ABI are accurate and complete. By taking just a few extra minutes to ensure accuracy and completeness, this will help decrease the possibility of overpayment requests being presented to your practice.
5010 Version – Required New Electronic Claims Filing Version
The Centers for Medicare and Medicaid Services (CMS) is requiring a transition from Version 4010 to Version 5010 for the electronic filing of claims. This transition has been mandated to take effective on January 1, 2012 and will entail extensive changes. The primary reason for this change is to get ready of the change from ICD-9 to ICD-10 diagnosis coding that is set to become effective October 1, 2013.
There is nothing you need to do as providers to prepare for this change other than to be financially prepared for possible payment delays. The implementation of Version 5010 is strictly in software programming. All vendors ABI utilize have been working diligently throughout this past year to become ready for this change. Because the change to the new Version is extensive and there are so many changes that affect many different entities, it is nearly impossible to know everyone is 100% ready.
With the lack of knowledge as to how the change to 5010 will impact all affected, we would like to bring to your attention, there may be a delay in payments. To what extent, we do not know. CMS has predicted that some payments may be disrupted for up to a year because some payors will not be ready. For claims that are not 100% compliant or payors who are not 100% ready to accept the 5010 electronic claims, we will receive denials. Please keep in mind, your claims will be paid; however, those payments may be delayed disrupting your cash flow. Though we are optimistic the majority of your claims will process without incident, we highly recommend you devise a plan to withstand any possible revenue disruptions that may occur.
If you have any questions regarding the Version 5010 conversion, please do not hesitate to contact Stephanie Kurtz at (316) 281-3710 or by email, skurtz@anesthesiabilling.com.
CRNAs and Medicare Reimbursement for Pain Management
A couple Medicare Administrative Contractors (MACs) have issued bulletins indicating they will deny CRNAs reimbursement for chronic pain management services provided to Medicare patients. Those carriers we are aware of currently are Noridian Administrative Services, which serves states in the northwest and Wisconsin Physician Services (WPS) who oversee Iowa, Kansas, Missouri and Nebraska. Noridian was the first to release a bulletin which sparked immediate response from effected CRNAs, effected state organizations, and the AANA Board. WPS would soon follow with their bulletin.
Here is a portion of the bulletin by WPS:
Chronic Pain Management
Chronic pain is the common symptomatic manifestation of a wide range of underlying medical conditions. Treatment of the chronic pain disorder begins with a detailed medical assessment aimed at developing a diagnosis or diagnostic evaluation plan, which will then lead to an appropriate and comprehensive therapeutic plan. The assessment skills required for the evaluation of the chronic pain state and the development of the consequent plan of care not part of the CRNA training curricula. If the CRNA is an Advanced Registered Nurse Practitioner (ARNP) or Clinical Nurse Specialist (CNS), or working incident to a physician or Non-Physician Practitioner (NPP), epidural injections may be reimbursed incident to the physician’s or NPP’s (NP, CNS, and PA) management of a patient with chronic pain when such services are medically reasonable and necessary.
If you would like to read the entire WPS bulletin, you can find online here: http://wpsmedicare.com/j5macparta/resources/provider_types/crna-pain-management.shtml
(“Accept” the permissions to read the bulletin)
If you are providing chronic pain management, it is recommended you have the following in place:
- Evaluation by a physician (or NP-Nurse Practitioner) who is responsible for the plan of care as well as follow-up care.
- Diagnosis by the physician or NPP (Non-Physician Practitioner).
- Order for the pain management.
- Detailed records including response to treatment (improvement) etc. that should be sent to the physician.
Although ABI has not yet seen any of these denials from Medicare and feel the key word is ‘chronic’ pain management, we are continuing to watch for this and will let you know as soon as we see any changes occur in payments.
Medicare Revalidation Applications
CMS has begun and will continue to submit lists of providers who need to be revalidated to the various Medicare Carriers. The Medicare Carrier then sends an application to the provider. Some of you have already received your application and others of you have yet to receive it. You may personally receive this application at your address. It is imperative you forward the application to our office once received. Once we have filled out the necessary information in the application on your behalf, there will be a signature required and possibly additional information we do not have for you. We will send everything to you for your signature(s) and flag any additional information you need to fill in. We need you to return these at your earliest convenience to our office.
If these applications are not submitted in a timely manner, your participation with Medicare will be terminated. You will then be required to start the process from the beginning to become participating again with Medicare and they will not backdate your participation. Please do not hesitate to contact Sheila Burns with any questions at (316) 281-3716 or by email, sburns@anesthesiabilling.com.
Changes in Authorization Requirements
The 2012 Prior Authorization Lists have been updated and are available on line. Check the website to review which service/procedures require prior approval.
Effective January 1, 2012, interventional pain management services will require a Prior Authorization regardless of Place of Service. The following CPT codes are included in this requirement:
Sacroiliac joint injections 27096, G0259, G0260
Translaminar epidural steroid injections 62310, 62311
Facet joint injections 64490 – 64495, 0213T* – 0218T*
Transforaminal epidural steroid injections 64479, 64480, 64483, 64484, 0228T* – 0231T*
Neurolytic injections 62280 – 62282
Spinal denervation 64620, 64622, 64623, 64626, 64627
Regional sympathetic block 64510, 64520
Intradiscal procedures 22526, 22527, 62287, 62292
* By default, any T code is designated by the Health Plan as experimental/investigational.
abinsights Contact Information
abinsights readers are invited to submit comments, questions, tips, and suggestions for articles on any subject related to billing, collections, coding, reimbursement, and compliance. Send to: Anesthesia Billing, Inc., P O Box 388, Newton, KS 67114-0388. Phone 316-281-3700. Fax 316-282-4322.
Our purpose is to help you meet inevitable challenges. We hope to deliver practical knowledge and solutions drawn from top resources and business publications in every issue, knowledge you can use today.
Reasonable attempts have been made to be accurate. However, medical billing, collections, coding and compliance are part science, part art, and even experts sometimes differ. Neither Anesthesia Billing, Inc., the editors, publisher, contributors, or consultants warrant or guarantee the information contained will be applicable or appropriate in all situations. For information specific to your practice, consult a qualified professional.
The information included in this publication is provided, among other things, to alert you to legal developments and should not be considered legal advice. Specific questions about how this information affects your particular situation should be addressed to your attorney.
Editor: Philip Blann (pblann@anesthesiabilling.com).
No Comments