Provider Outreach and Education Advisory Group (POEAG) Meeting Minutes - January 24, 2024

Attendees

POEAG: Anna Markiewicz; Barb Stockert; Bill Noyes; Carlota Martinez; Carolyn Koster; Celeste Lane; Crissy Hill; Dawn Cetti; Dawn Jorgensen; Gary Marano; Heather Werner; Jeannette Leon; Kelly Troutman; Kimberlie Rogers-Bowers; Kimberly Hanson; Kristi Sanders; Maria Koehnlein; Marsha Lawrence; Mary Stoner; Melinda Eberhart; Noel Neil; Pamela Fritz; Patty Donndelinger-Bogyo; Paul Kesselman; Randy Stevens;  Rececca Erickson; Rhonda Turner; Ronda Buhrmester; Sharee Hummer; Tanya Ward; Theresa Mccraary; Tugba Koca; Wayne Bradberry; Wendy Russalesi

CMS: Pamela Durbin

Noridian: Amber Mertz; Ashley Decoteau; Colleen Harryman; Conner Dingle; Corinne Medina; Dan Schmidt; Kate Petersen; Kelsey Slettebak; Kloe Roberts; Mary Reineke-Ferguson; Ruth Reese; Shelly Carlson; Tanya Gillies; Tracy Schutt

POE Advisory Group Mission and Goals

Mission

  • To determine the best methods of providing quality education and training to our supplier community.

Goals

  • Develop timely, useful, relevant educational opportunities for our suppliers
  • Provide input in the creation, implementation and review of Provider Education and Training
  • Determine innovative, cost effective methods of using technology in provider education and training CMS Internet Only Manual (IOM), Publication 100-09, Chapter 6

Standing Agenda Items

  • Education for Practitioners
    • Continue to seek opportunities

Follow-up from Previous Meeting

General

  • Joint POEAG to develop education for clinicians ordering DMEPOS
    • Seven meetings have been held focusing on sleep
      • Suggestions
        • Provide education during residency
        • More webinars for providers on DME requirements
        • Update clinician checklist
    • Newsletter
    • Please email POEAG or speak up if would like focus group to continue
  • Sleep focus group accomplishments
    • Updated Positive Airway Pressure (PAP) clinician checklist to be more thorough
    • Updated PAP documentation checklist to be more thorough
    • Wrote series of articles addressing known issues, i.e.,
      • 12-month sleep study requirement
      • Oral appliance issues
      • Recall
    • Created newsletter with PAP resources for practitioners
    • Worked with medical directors to accept REI measurements
    • Collaborated with CGS to potentially allow sleep study > 12 months
      • If the sleep study is older than 12 months, it could potentially be accepted as long as there was a F2F that had notes stating the condition has remained the same and the study is still accurate - added to Noridian website under Browse by DMEPOS Category > PAP Devices.
        • Member response: Language is not clear. Can examples be provided?
          • Noridian response: The language is vague to follow the Standard Documentation Requirements Policy Article and due to beneficiary conditions easily changing within 12 months. Ultimately, the decision is up to the treating practitioner.
    • Started education for American Academy of Sleep Medicine (AASM) to bridge gap between PAP and polysomnography (PSG) LCDs
  • Collaborative MAC education
    • Awaiting 2024 schedule of events
  • Level 200 webinars
  • Supplier complaints due to differences between CGS/Noridian processes
    • Identify in claims processing
      • Issue with interpretation with in-person evaluation and sleep test
        • Waiting on clarification from DME Medical Directors (DMDs)
    • Possible action item for webinars
      • Awaiting comments from CGS on PAP webinar

DME

  • Suppliers and DME claims data revealing many GW modifier denials
    • Hospice is educating on the GW modifier.

O&P

  • Lower Limb Prosthetics (LLPs) level 200 webinar
    • Please send scenarios you would like to see included
      • For example, claims that suppliers thought would be paid but were denied during prior authorization.
    • Send to the POEAG email address

New Items

General

  • Ask the Contractor Meeting (ACM)
    • Scheduled for 2024
      • February 8, 2024, 2 p.m. CT
    • General - all topics

DME

  • Lymphedema
    • MLN Matters: Change Request (CR) 13286
    • Effective date of service on/after January 1, 2024
    • No planned Local Coverage Determination (LCD) or Policy Article (PA)
    • New dedicated webpage
      • Noridian Medicare website > Browse by DMEPOS Category > Lymphedema Compression Treatment
  • Intravenous Immune Globulin (IVIG)
    • Demonstration ended December 31, 2023
    • IVIG becomes permanent Medicare benefit
      • Effective date of service on/after January 1, 2024
    • Dedicated webpage
    • Noridian Medicare website > Browse by DMEPOS Category > Intravenous Immune Globulin (IVIG)
    • MLN3191598 fact sheet

O&P

Question for Suppliers

Would you like to see a passcode added to Noridian letters to use for verification if a call is received from Noridian about the letter? Noridian would need to provide the passcode to the supplier to continue the discussion.

Member feedback:

  • This is a good idea because there is a lot of scamming, an extra security measure
  • A passcode is a good idea and provides a level of comfort and safety especially for smaller providers.
  • If I don't have the letter, it won't be of any assistance; many companies have processes in place to ensure it is a legitimate call (many members agree with this)
  • A supplier echoed the hesitation. If it's used as an option only, that could be very helpful. Another is hesitant to require a code because additional documentation requests (ADRs) don't always get to where they are supposed to be. There are times we call regarding a claim and didn't realize there was an ADR. This could also make it difficult to not get information because they didn't have the code.

Suggestions from POE Advisory Members

  • Regarding IVIG, I'm hearing from suppliers that they didn't realize they should bill in 15-minute increments. This might be good to include as an email update (and reference the LCD).
    • Noridian response: Noridian will take this into consideration.
  • The IVIG LCD has a chart that describes timeframes and units Ideally, this would go up to 24 and 25 since infusions can last a longer time.
    • Noridian response: Additional units can be added to the website. We can add a comment to the webpage.
  • If a provider is submitting a claim for one unit, education could be provided on a one-on-one basis.
    • Noridian response: This will be researched.
  • Regarding usage of discarded drugs, currently CMS states providers that furnish a Part B drug from a single dose container but don't administer should use the JZ modifier. Can clarification be provided on JW and JZ when the time is appropriate?
    • Noridian response: Noridian contacted this member directly.
  • Thank you for the lymphedema education, it's been very helpful. I want to suggest adding it to Webinars on Demand so suppliers not able to attend can hear the information.
    • Noridian response: We are waiting for clarification from the DMDs and would like to have that information included in the webinar recording. Once we have that, we plan on posting.
  • Regarding surgical dressings, suppliers are receiving denials (CO-151) on collagen. The Noridian tool reflects that this item can be in place for up to seven days, but these are being replaced daily. Is there a system edit?
    • Noridian response: The member will fax examples of denied claims.
  • The Surgical Dressings LCD suggests that compression bandages can be changed weekly unless they are part of a multi-layer compression dressing change. We interpret this as all dressings should be changed at once, but if the compression bandage is reusable, do you change that with the dressing change? How often is this supposed to be utilized? There seems to be pushback with referral sources.
    • Noridian response: Noridian will contact this member directly.
  • Can you tell me if the compression for the A6552 that in the MLN states 30-40 was changed to 20-40 in the Noridian handout? Also, can the two nighttime garments be given two at once every two years as per the MLN or once each year? Do we need to provide the three gradient compression garments on the same date of service?
    • Noridian response: A6552 as listed was corrected in the webinar handout for the 1/11/24 and 1/23/24 presentations. We have submitted the dispensing/billing garments/items separately versus collectively to the medical directors and yes, it is three items/garments per body part.
  • Which category on the 855S needs to be updated to include the new lymphedema codes?
    • Noridian response: This question would need to be directed to the National Provider Enrollment (NPE) contractor.
  • Compression garment suppliers need an LCD and a checklist. Did you know that when trying to find policy on certain subjects, the website directs the viewer to a particular LCD, for example the KX modifier?
    • Noridian response: The DMDs are currently reviewing the need for an LCD/policy article for lymphedema. As soon as a decision is made, we will let the supplier community know.
  • How do you distinguish the multiple body parts for lymphedema? I know for Medicare we can add a narrative but not all insurances accept narratives electronically.  Will there be multipliers added like surgical dressings to state how many limbs are affected?
    • Noridian response: Distinguishing the multiple body parts would be in the medical records from the physician and also it can be written in the comment section on the claim form. At this time there are not going to be multipliers as there are in the surgical dressing policy.
  • How often do we need new chart notes and prescriptions for lymphedema?
    • Noridian response: There is not a specific requirement identified for how often new chart notes are required, however we would expect to see ongoing documentation demonstrating that medical necessity continues to be met. A new Standard Written Order (SWO) would be required if the course of treatment changes from the original SWO or a change in items/garments. Additionally, we would recommend reviewing the continued need section of the Standard Documentation requirements.
  • When the MAC is taking back money, at the bottom of the remittance advice could they reference the beneficiary in addition to the Additional Documentation Request (ADR) letter? It would help when applying the cash without having to search for the ADR letter.
    • Noridian response: Due to system limitations, this information is unable to be added.
  • Has anything changed to the Standard Written Order (SWO) as what items can be listed? Can all PAP supplies be included such as nasal mask and full-face mask or should they be listed as one or the other? Also, has the detailed written order been discontinued?
    • Noridian response: All supplies should not be listed, rather only the specific supplies provided should be listed. The detailed written order was replaced with the SWO in 2020.

Upcoming Meeting

Next Meeting: April 24 at 12 p.m. CT

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