POE AG Meeting Minutes - October 19, 2022 - JA DME

Attendees: Kim Branson; Ronda Buhrmester; Kristine Cram; Dawn Cetti; Melinda Eberhart; Valerie Eriole; Pamela Fritz; Sharee Hummer; Catherine Hamilton; Kimberly Hanson; Crissy Hill; Dawn Jorgenson; Paul Kesselman; Tugba Koca; Maria Koehnlein; Jeannette Leon; Bridget LaScala; Gary Marano; Noel Neil; Jan Palmer; Erica Rochelle; Kimberlie Rogers-Bowers; Wendy Russalesi; Randy Stevens; Mary Stoner; Yvonne Weiler; Jon Shreter

CMS Attendees: Pamela Durbin; Richard Longway; Rebecca Russo

Noridian Attendees: Melissa Betts; Shelly Carlson; Colleen Harryman; Tanya Gillies; Kate Petersen; Ruth Reese; Mary Reineke-Ferguson; Kloe Roberts; Dan Schmitt; Tracy Schutt; Kelsey Slettebak; Brenda Swancy

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

• Coronavirus (COVID-19) Public Health Emergency (PHE)
  • Waivers and flexibilities remain in place
  • Extension announced October 13, 2022
• Post COVID-19 PHE Guidance
  • Send questions to DME POEAG email (DMEPOS-POEAG@Noridian.com) and Noridian forwards to CMS
• Sequestration adjustment returned to the full 2% on July 1, 2022
• Education for Practitioners
  • Continue to seek opportunities

Follow-up from Previous Meeting

General

• Joint POEAG to develop education for clinicians ordering DMEPOS
  • Three meetings have been held focusing on sleep
    • Great suggestions being worked on
      • Provide education during residency
      • More webinars for providers on DME requirements
      • Update clinician checklist
  • Looking for supplier volunteers for a similar Glucose meeting, willing to recruit practitioners
    • Meetings to start in 2023
• Collaborative MAC education
  • Respiratory
    • December 1, 2022
  • Therapeutic Shoes for Persons with Diabetes CERT Taskforce
    • November 2, 2022
• MLN Connects January 12, 2022
  • CMS released the required face-to-face (F2F) and written order prior to delivery (WOPD) list effective April 13, 2022
  • Seven items in addition to the power mobility devices
  • Additional items added to the required prior authorization list
  • Five orthoses and six power mobility devices
  • MLN Matters Number: SE20007 Revised
• Hospice and DME education
  • In the process of creating education

DME

• Philips Respironics Respiratory Products Recall
  • On going
  • Medical director discussions
    • During the PHE, if there is documentation from the treating provider that states the beneficiary’s medical condition has not changed since the previous sleep study and the evaluation by the treating physician is within a year of the DOS for initial issue of a CPAP, then DME MACs will accept this documentation in lieu of a repeat sleep study to meet the timely documentation requirement.
• Removal of Certificate of Medical Necessity (CMN) and DME Information Form (DIF)
  • January 2023

O&P

• PAR emergent situations
  • CMS released additional information on emergent situations
    • The ST modifier should be utilized by suppliers when a beneficiary requires a brace on the same day. If the health or life of the beneficiary is jeopardized without the use of the orthic device. And the beneficiary’s emergent need cannot wait for the two-day turnaround time.
      • These claims will be subject to prepayment review
  • Providers under the competitive bid exception
    • Should continue to utilize the KV modifier
      • These claims may be subject to prepay review

New Items

General

• Ask the contractor teleconference (ACT)
  • Scheduled for 2022 - November 10
  • General - all topics
• Level 200 webinars
  • Please send scenarios you would like to see included
  • Send to the POEAG email address
• Considering 2023 in-person event
  • Held centrally for JA and JD
    • Attendees are interested
• Quarterly updates
  • DME highlights from weekly email
  • Hot topics
  • New format went out in September
  • Is this beneficial?

Suggestions from POE Advisory Members

• CGS has stated that patients with T3 or higher SCI, they are considered immunocompromised and therefore do not need to qualify for A4353 with UTIs. This is not in any educational material. Can Noridian add this to supplier education resources?
  • This direction is not part of the Local Coverage Determination (LCD)/Policy Article (PA) and therefore could be part of CGS' internal processing. We will take this back for review and if any changes occur we will follow up.
• Can additional education be given regarding the FreeStyle Libre 3? Practitioners have a tough time understanding that we can't bill Medicare because it hasn't been approved because it doesn't have the reader.
  • Noridian will visit with our Part B counterpart and add information to the following:
    • Webinar
    • Browse by DMEPOS Category > Glucose Monitors webpage
    • Clinician Checklist
• Another attendee also shared that the FreeStyle Libre website states this is not reimbursed by Medicare so this could also be a resource.
• Regarding the elimination of the DME Information Form (DIF), is Noridian going to be able to process claims without the information from the DIF? Should the industry reach out to CMS to encourage not to eliminate this? Since the DIF is a supplier form, is it causing more problems with claims processing by eliminating it?
• Staff is getting concerned that instruction hasn't been provided yet.
  • Noridian hears your concerns; all teams at Noridian have received the same information and training. You are more than welcome to communicate your concerns with CMS. Noridian will be prepared for the implementation.
• With the high error rates and confusion with incident to for therapeutic shoes, can you provide additional guidance on this in your education?
  • We will reach out to our Noridian Part B counterparts to add "incident to" to our education, thank you for the suggestion.
• Can Noridian give us the key words and language auditors are looking for in the documentation? There is frustration with cases going to the Administrative Law Judge (ALJ) and them being turned over immediately. Why can't Noridian pay these immediately? This frustration has been building up over the years and is getting worse.
  • Noridian is not able to provide exact wording to put into medical records, but we can look into adding language to the Clinician Checklists to offer additional clarification. One tip is to add an additional document explaining where the medical necessity is in the documentation.
• If the policy doesn't give specific diagnosis codes, then everything is discretional. When it comes time for the audit, the reviewer may see something different. We have to know whether or not we should provide an item.
• There can't be gray areas, and this could be contributing to the high error rate over the years.
  • Some of the requirements in the LCD remain statutory, only an act of Congress can change those. We hear what is being said, but we cannot give specific phrases. We will make our education as clear as possible, but each practitioner needs to provide thorough records to show the medical need. CMS is allowing DME MACs to expand education and work more and more with the practitioner community, we have work to do here to help them understand the Medicare requirements.
• Can additional education be added on appealing Comprehensive Error Rate Testing (CERT) denials to lower the CERT rate?
  • This is a great suggestion and we will look to make sure we have this available.

Upcoming Meeting

• Next Meeting: 2023