Provider Outreach and Education Advisory Group (POEAG) Meeting Minutes - October 14, 2020

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.

Member attendees: Kim Brummett, Ronda Buhrmester, Dawn Cetti, Kristine Cram, Rose Gomez, Sharee Hummer, Kimberly Hanson, Crissy Hill, Dawn Jorgensen, Paul Kesselman, Tugba Koca, Jeannette Leon, Bridget LaScala, Eileen Levis, Gary Marano, Joe McTernan, Rica Nebrich, Noel Neil, William Noyes, Yvette Nugent, Tina Padden, Jan Palmer, Joyce Perrone, Wendy Russalesi, Randy Stevens, Rachelle Tritinger, Yvonne Weiler, Maria Koehnlein

CMS attendee: Alikia Mack

Noridian attendees: Cindy White, Courtney Willis, Diana Duchscherer, Mary Reineke-Ferguson, Tracy Schutt, Jessica Bennett, Tanya Gillies

Standing Agenda Items

  • Coronavirus (COVID-19) Public Health Emergency (PHE)
    • Waivers and flexibilities in place
    • CMS resource pages
    • Noridian resource pages
    • Beneficiary Authorization of Benefits (AOB) - Needs signature prior to billing
      • Suppliers expressing concern because AOB is a part of proof of delivery and signature requirement is waived on this. This question is with CMS currently.
  • Targeted Probe & Educate (TPE)
    • Results on Noridian website (Medical Review > Medicare Review Results)
    • Suspended during COVID-19 PHE
      • No update when it will resume
  • Post-Payment Clinical Review
    • Post-payment review initiated in August
      • Urological (A4351 and A4352)
      • Knee Orthoses (L1833 and L1851)
    • Member Question - Received post-payment reviews on wound care and ostomy supplies. Is this a random review item or part of TPE?
      • Noridian Response - Did these come from Noridian or another contractor?
        • Member Comment - So far coming from Medicare Administrative Contractor (MAC) and majority came from Jurisdiction C
      • Noridian Response - They could be selecting different items for review. MACs have the ability to evaluate what they select for review
    • Member Question - Is Noridian mirroring the TPE process for post-pay reviews, such as 10 claims are reviewed and if the supplier does well, Noridian goes to another supplier
      • Noridian Response - The post-pay review is not a supplier-specific review, this is a product category review, so the parameters are different than TPE. Medical Review (MR) indicated that the reviews are random based on the code. There is no provision in post payment review to exempt a supplier after so many claims reviewed.
    • Member Comment - Suppliers are having difficulty in obtaining records from doctor’s offices, due to limited staff to pull medical records, especially prior to PHE, and getting the records is not a priority. The 45-day timeframe is a concern among many clients. Hopefully there is flexibility to allow an extension to suppliers providing records.
      • Noridian Response - Advise clients to submit what they have so they aren’t ignoring the request. We know suppliers are not required to have records in advance, but this is one reason we suggest suppliers do obtain records initially.
    • Member Question - Can suppliers ask for an extension on providing the records to Noridian?
      • Noridian Response - Per Medical Review, any request for an extension would be handled through the supplier contact center.
    • Member Question - Are post-payment reviews limited to claims submitted and processed prior to PHE?
      • Noridian Response - We are reviewing claims with a date of service (DOS) prior to March 1, 2020
    • Member Question - I haven’t found Additional Documentation Requests (ADRs) in the Noridian Medicare Portal (NMP). Is this function working?
      • Noridian Response - Per Medical Review, the notification letters are visible in the message center of the NMP under letter inquiry. Suppliers can submit documentation in response to the letters in the NMP as well.
    • Member Comment - Many times doctor’s offices are telling us a patient hasn’t been seen due to COVID. We must explain to them that our requests are not during COVID (pointing out pain-point for suppliers)
      • Noridian Response - Please continue to emphasize that the date in question was prior to the COVID-19 public health emergency (PHE) and that prior records are what is needed. We do thank you all for continuing to be on the front lines caring for Medicare beneficiaries at this time.
    • Member Comment - Clients are receiving requests from Recovery Audit Contractors (RACs), Supplemental Medicare Review Contractor (SMRC), Unified Program Integrity Contractors (UPICs) and they are all responding the best they can but it’s difficult because it’s not only MAC audits they are receiving
  • Education for Practitioners
    • Added as a standing item as we look for opportunities
    • Suggested emphasis on dictation of medical records which Noridian incorporates into all practitioner education opportunities
    • Noridian partners with A/B for global education opportunities

Follow-up Information from Previous Meeting

General

  • Physician based education for prior authorization
    • Pending
  • Text alert option for companies not allowing usage
    • Pending
  • Weekly listserv for upcoming webinars
    • Under consideration
  • Advertisement on NMP for upcoming webinars
    • Reviewing with portal team

DME

  • Oxygen webinar with A/B MACs held September 29
    • Very positive survey results
  • L200 Ventilator webinar
    • Continues in process
    • Noridian continues to seek examples of scenarios from the supplier community for inclusion in the webinar
  • Provide denial rate affirmation on prior authorization and conduct targeted training
    • Prior Authorization Request (PAR) resumed in August, so will return to investigation
  • Suggestion for education on billing oxygen when beneficiary has commercial insurance primary and Medicare secondary
    • Project in progress
  • Home infusion codes moving to Part B January 1, 2021
    • Collaborative webinar scheduled October 21 at 1 p.m. CT
    • Member Comment - Thanks for scheduling home infusion therapy (HIT) webinar. Looking at the summary, it looks like billing-specific issues. Wanted to share there are a lot of questions on enrollment and home health on how this is changing their involvement with patients. It varies depending on if it’s a HIT drug or non-HIT drug. Education needed for providers, suppliers, and home health.
      • Noridian Response - Emphasis will be made on enrollment and we will make sure home health is addressed.
    • Member Question - Is there more information coming down the road with Change Requests (CRs)?
      • Noridian Response - As we receive information, we will pass it on. We do ask for questions prior to the webinar so we will make sure those are included in the presentation.
  • Post COVID-19 PHE Guidance
  • KU Modifier Education
    • Article published June 10
    • Webinars provide guidance
    • Association meetings received article information

O&P

  • O&P Training Program for Competitive Bid
    • Webinars and educational materials are being prepared
    • Dates to be announced soon
  • Ask the Contractor Teleconference O&P specific
    • November 12 at 3 p.m. ET
  • Member Question - Is Jurisdiction A planning to publish any data on prior authorization for lower limb prostheses since it is currently only applicable for service in Pennsylvania?  Any data you can share before full implementation in December would be helpful
    • Noridian Response - We have a lower limb prosthesis (LLP) webinar scheduled for November 11. MR is sharing information with those creating the webinar and will continue to do so. Make sure you get the word out that the webinar is available, and registration is on our website.
  • Member Comment - The New York State Podiatric Medical Association (NYSPMA) meeting in January is virtual. Is Noridian able to attend?
    • Noridian Response - Provide that communication with us through the DMEPOS Education Speaker Request form. We will make every effort to attend. We’ve attended many virtually now and with the different platforms available, the technological challenges have increased but it’s always great way to get information out.

New Items

General

  • GoToWebinar not supporting Internet Explorer
    • Utilize alternative web browsers

DME

  • Retirement of Enteral Nutrition and Parenteral Nutrition Local Coverage Determination (LCD) announced October 8, effective November 12
    • Correct coding and billing articles
    • Member Question - Is Noridian planning to do any webinars regarding Enteral and Parenteral LCD?
      • Noridian Response - Webinars may be scheduled, however all information will be taken from the correct coding and billing article
    • Member Comment - The reference to the National Coverage Determination (NCD) has many questions. The NCD has language referring to a Certificate of Medical Necessity (CMN), what constitutes initial approval, and ongoing three-month approval. Is it referring to the DME Information Form (DIF)? There isn’t one for every three months, only the revised. The NCD says the patient must qualify for a pump but a pump is standard. It simply can’t be given without a pump.
      • Noridian Response - There should be minimal change if the DME Medical Director (DMD) article guidance is followed but email general questions and we will work to be sure that education incorporates those questions in education.
  • Intravenous Immune Globulin (IVIG) demonstration ends December 31, 2020
    • DOS driven
    • Article published October 7

O&P

  • L1686 Prefabricated Hip Abduction Orthosis - Correct Coding
    • DMD article published September 17
    • Regarding L1686, American Orthotic & Prosthetic Association (AOPA) has concerns about the code and what it includes. It is formulating a response for DMDs and DME MACs.
      • Noridian Response - Thank for you sharing your concerns with them.

Suggestions/Questions from POE Advisory Members

  • Why are the enteral and parenteral LCDs being retired?
    • Noridian Response - The joint DME article states it is due to the evolution of enteral and parenteral nutrition clinical paradigms.
  • When submitting a claim for prosthetic code that has a prior authorization number, does that code get billed separately?
    • Noridian Response - The authorized code is not required to be billed separately
  • During the LLP Prior Authorization webinar a month ago, it was stated that for a  prior authorization after January 1, the supplier will need to also submit a copy of the Pricing, Data Analysis and Coding (PDAC) verification for the product that has one of the codes that require PA and PDAC. This is not the case with Jurisdictions B and C and wanted to confirm that the information for Noridian is that they will require it.
    • Noridian Response - Noridian continues to seek clarification.
  • Can we recommend that a Dear Physician letter for continuous glucose monitor (CGM) for patients that have tried it but no longer want to use it? It needs to explain that once a patient switches to the CGM, it has to be a significant change to switch to other supplies. We are seeing patients that don’t like the technology or can’t afford the co-pay.
    • Noridian Response - There was not an article as noted on our call. The following information was shared with POE for educational purposes: Suppliers, beneficiaries and treating practitioners should be aware that CMS considers standard glucose monitors (BGM) and CGM to be same or similar equipment and thus subject to the 5-year reasonable useful lifetime regulation.  Replacement sooner than 5 years is only available if the item is lost, stolen, irreparably damaged or there is a change in medical necessity.  There must be documented reasons in the medical record why the CGM is no longer medically necessary and the physician is now ordering a BGM to replace the CGM. Patient preference would not be sufficient justification and the beneficiary could be offered an Advance Beneficiary Notice of Non-coverage (ABN).
  • The SMRC is doing a project on CGM. If another contractor is focused on a HCPCS code, would a MAC also do a review on that same item?
    • Noridian Response - In general no but it could be possible.
  • Noridian Question: Does anyone have any feedback regarding the DME on Demands that have been moved to the YouTube platform?
  • Feedback: Our only issue was having employees trying to access them, but they were blocked from YouTube. We were able to get them access and the feedback is good, easy to use.
    • Noridian will update our slide to alert other suppliers that YouTube access can be restricted to certain addresses

Noridian Question: We are in the process of scheduling 2021 meetings. Does this day and time work for everyone? The response from many is yes.

 

Last Updated Thu, 12 Nov 2020 20:15:20 +0000