Provider Outreach and Education Advisory Group (POEAG) Meeting Minutes - April 24, 2024 - JA DME

POE Advisory Group Mission and Goals

Attendees

Members: Wayne Bradberry, Ronda Buhrmester, Kristine Cram, Dawn Cetti, Patty Donndelinger-Bogyo, Rebecca Erickson, Lauryn Estrella, Jason Freeman, Lisa Gannon, Kimberly Hanson, Crissy Hill, Sharee Hummer, Dawn Jorgensen, Paul Kesselman, Tugba Koca, Maria Koehnlein, Carolyn Koster, Jeanette Leon, Marsha Lawrence, Gary Marano, Anna Markiewicz, Carlota Martinez, Noel Neil, Yvette Nugent, Christina Padden, Jan Palmer, Wendy Russalesi, Maria Sanchez, Kristi Sanders, Barbara Stockert, Dan Vasilj, Yvonne Weiler, Tanya Ward, Heather Werner

Noridian: Melissa Betts, Shelly Carlson, Ashley Decoteau, Ashlee Erickson, Colleen Harryman, Corinne Medina, Amber Mertz, Ruth Reese, Mary Reineke-Ferguson, Dan Schmitt, Tracy Schutt, Kelsey Slettebak, Brenda Swancy

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
• Collaborative MAC education
  • A/B DME Workgroup
    • Nebulizer and Related Drugs: 06/04/2024
    • Positive Airway Pressure (PAP): TBD
    • Lower Limb Orthosis: TBD
  • CERT Task Force: June 18, 2024, 12 p.m. CT

Follow-up from Previous Meeting

General

• Level 200 webinars
  • Please send scenarios you would like to see included
    • Send to DME POEAG email (DMEPOS-POEAG@Noridian.com)
  • Member question: What scenarios are you looking for regarding L200 examples? Do you need the claim number?
    • Noridian response: Examples include denials that suppliers see frequently, medical necessity denials, strange denials
    • An example for surgical dressings is showing medical records that clearly state, "sheer wound" and there would be discussion on why it was denied as noncovered.
    • Please do not email claim numbers (due to Protected Health Information); however, please send a summary of the scenario and a POE representative will reach out
    • L200s are very successful with our suppliers, and we want to provide more of them
  • Member question: What is the timing of the L200 webinars as far as question submission and when is the webinar happening?
    • Noridian response: We are looking for input right now and we always welcome your ideas.
  • Member question: As a manufacturer, we receive contacts by beneficiaries, clinicians, hospital staff, etc., on issues they are having regarding access to items, prior authorization, quantities, no payment, etc. Are these acceptable examples?
    • Noridian response: Yes, please send these. They will help suppliers and improve our education to suppliers.
• Supplier complaints due to differences between CGS/Noridian processes
  • Identify in claims processing
    • Issue with interpretation with in-person evaluation and sleep test
      • Clarification provided by DMDs that there is some flexibility, if the sleep study is greater than 12 months, can have follow-up evaluation that documents no changes in the beneficiary's condition
  • Possible action item for webinars
    • Comments on the PAP webinar were received from CGS

DME

• Bill IVIG in 15-minute increments - email update
  • Noridian wrote a Did You Know article
  • Provider submitting claim for one unit, one-on-one education could be provided
    • 1:1 education was offered
    • Noridian has an e-visit request form on our website for 1:1 education
  • IVIG LCD chart with timeframes/units go up to 24 and 25
    • Noridian adding comment to webpage indicating no limit
• Lymphedema
  • MLN Matters: Change Request (CR) 13286
    • Joint DME MAC publication posted February 29, 2024
  • "Lymphedema Compression Treatment Items - Correct Coding and Billing - Revised"
    • Noridian Medicare website > Policies > Medical Director Articles > 2024

O&P

• Lower Limb Prosthetics (LLPs) level 200 webinar
  • Please send scenarios you would like to see included
  • Send to the POEAG email address
    • DMEPOS-POEAG@Noridian.com

New Items

General

• Ask the Contractor Meeting (ACM)
  • Scheduled for 2024
    • May 9, 2024, 2 p.m. CT
  • General - all topics
• Refill requests extended from 14 to 30-day timeframe
  • Beneficiaries not required to count remaining supply when need refill
  • Mode of communication for refill up to supplier
  • Contact regarding refills no sooner than 30 calendar days
    • Prior to end of current supply
  • Documentation supports delivery no sooner than 10 calendar days
    • Prior to end of usage
  • Effective 1/1/2024 and after
• Revised CMS-588 Electronic Funds Transfer (EFT) application
  • New form required as of May 1, 2024

DME

• Billing power seat elevation system
  • Wheelchair accessory, power seat elevation system (E2300) HCPCS code change
  • On or after April 1, 2024, use HCPCS E2298
• External Upper Limb Tremor Stimulator Therapy
  • Essential tremor symptoms significantly impair ADL performance
  • Effective date of service April 7, 2024, and after
• IVIG
  • Q2052 billed in 15-minute increments
    • Did You Know article, " Did You Know Intravenous Immune Globulin (IVIG) Suppliers Should be Billing Services in Time Increments?"
      • Member thanked Noridian for providing this to suppliers
  • Table in policy article added to webpage
    • Note will be added to table that there is no limit to number of increments
• PAP
  • DMDs published letter on 2/8/24 regarding SWO for PAP and RAD masks
    • Offers flexibilities with mask description on SWO
    • Description may be general/say "offer mask of choice"/ list multiple mask options
    • Extends to accessories such as headgear, pillows, cushions, tubing
      • Noridian released article on March 19 which includes this flexibility

O&P

• Additive manufacturing of custom fabricated orthotic devices now acceptable
  • I.e., 3-D printing
  • Must adhere to CMS' DMEPOS Quality Standards
    • Appendix C
  • Joint DME MAC and PDAC publication
    • Noridian website > Policies > Medical Director Articles > 2024 3-D Printed Orthotic Devices - Correct Coding
      • February 1, 2024

Question from Noridian

• What are your thoughts on DME hosting a two-day symposium with CEUs offered?
• Overall response is positive, many members think this is a great idea and would be very helpful; however, we may not have too many attendees that have daily job requirements. It may be more management attending.
• One suggestion is to have a medical director(s) open up the symposium or close it out with a brief 30-minute timeslot. There is potential for very high attendance with this.
• A member asked if there would be a cost, but it would be free-of-charge.
• Another member suggested one day vs. two unless you designate one day for policies and procedures and then add in specific blocks for key product areas.  We always need reminders and updated education.

Suggestions from POE Advisory Members

Member suggestion: Education regarding place of service 27 would be helpful. Some services (infusion, for example) cannot be provided on the street. What is the intent for using 27?

Noridian response: Noridian will look into providing this education.

Member suggestion: How do we handle a beneficiary that becomes non-compliant with positive airway pressure (PAP)? We were given instruction that we cannot bill the beneficiary without an Advance Beneficiary Notice of Noncoverage (ABN), even if a registered letter requesting the beneficiary sign the ABN is not returned. Can education be provided on what suppliers can do in these situations?

Noridian response: Correct, if the beneficiary does not meet compliance, a signed ABN must be on file in order to bill that person. With PAP and continued coverage criteria, as soon as day 61, notify the beneficiary if they don't meet compliance by day 91, it will not be covered. The supplier has all rights to pick up the equipment and at that point, a police report may be filed.

Member question: Can more research be done on exceptions for not having a signature? Some beneficiaries won't sign the ABN once they have the equipment.

Noridian response: Noridian will look into including more information on what can be done. There is information in the Internet Only Manual, Publication 100-04, Claims Processing Manual, Chapter 30, Section 50.8.1, about deliveries not completed in person and that it must be followed-up with a signed ABN.

Member suggestion: Recently, physicians have received audits for Standard Written Orders (SWOs) and they've denied; however, some physicians are exempt from writing one. Now these denials need to go to the Administrative Law Judge (ALJ). Can the auditors receive training on this exception?

Noridian response: As clarification, the SWO Policy Article states: "In those limited instances in which the treating practitioner is also the supplier and is permitted to furnish specific items of DMEPOS and fulfill the role of the supplier in accordance with any applicable laws and policies, a SWO is not required. However, the medical record must still contain all of the required SWO elements." The member will provide examples.

Member question: Regarding the change of how PAP masks can be listed on the SWO, can a supplier send our own generated form that lists everything, and the physician can check off which ones are applicable, and send it back?

Noridian response: This is acceptable after receiving the initial order or they can add a general description such as 'mask of choice' to the SWO.

Member question: Regarding the revised CMS-588 form, if we are already receiving electronic funds, do we need to do anything?

Noridian response: Nothing more needs to be done if you are already enrolled.

Upcoming Meeting

Next Meeting: July 24, 2024