POE AG Meeting Minutes - October 20, 2021 - JA DME

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

Attendees

• Member Attendees: Dawn Cetti, Pamela Durbin, Mindy Eberheart, Pamela Fritz, Dexter Glasgow, Sharee Hummer, Kimberly Hanson, Crissy Hill, Dawn Jorgensen, Paul Kesselman, Tugba Koca, Maria Koehnlein, Bridget Lascala, Jeanette Leon, Eileen Levis, Gary Marano, Bill Noyes, Jan Palmer, Caryn Plessinger, Kristine President, Kimberlie Rogers-Bowers, Peter Rugh, Randy Stevens, Rachelle Tritinger, Yvonne Weiler, Donald Weschler.
• Noridian Attendees: Shelly Carlson, Kathy Fulton, Daria Gabai, Collen Harryman, Melissa Kuznia, Amber Mertz, Kate Petersen, Kloe Roberts, Tracy Schutt, Brenda Swancy, Cindy White.

Standing Agenda Items

• Coronavirus (COVID-19) Public Health Emergency (PHE)
  • Waivers and flexibilities remain in place, look for update soon
    • Last extension expires December 2021
• Post COVID-19 PHE Guidance
  • Send questions to DME POEAG email (DMEPOS-POEAG@Noridian.com) and Noridian forwards to CMS
• Sequestration suspension extended to December 31, 2021
• Targeted Probe & Educate (TPE) Resumed
  • Member Comment: Webinars are helpful, they provide good overview.
• Post-Payment Clinical Review Ended
  • Member Question: Is this regarding MAC Additional Documentation Requests (ADRs) or a separate type of review?
    • Noridian: Yes, this is regarding ADR reviews. Now that TPE has resumed, these will discontinue.
  • Member Question: Is there a published list of HCPCS codes subject to TPE?
    • Noridian: TPE is a supplier-focused review so there isn't a list of HCPCS available.
  • Member Question: To clarify, post-pay ADRs by HCPCS are halted and now TPE will go into supplier-specific audits, correct?
    • Noridian: Yes, this is correct.
• Education for Practitioners
  • Continue to seek opportunities
  • Provided a tutorial to the American Association of Nurse Practitioners on oxygen and PAP that is in the final approval process

Follow-up from Previous Meeting

General

• Updated Dear Clinician Letters
  • Per request, continuous glucose monitors (CGM) checklists and clinician letters have been updated:
    • Checklist to assist clinicians with coverage and documentation requirements
    • Clinician directed letter that advises them as to what type of documentation is necessary in medical records to support payment of glucose monitors and related supplies
    • Clinician directed letter that reminds them that ongoing need for and use of DMEPOS item must be documented in patient's medical record
      • Member Comment: We used the CGM checklist as an example for internal operations, they are always very helpful.
• Suggestions for engaging audiences
  • Incorporating more website tours during presentation - feedback has been extremely positive
  • Working on implementing “pop quizzes”
• HIGLAS Recoupment by TIN
  • Currently there is not a way from the remittance advice or the portal that suppliers are able to get the PTAN that the recoupment was taken back on without calling the Provider Contact Center.
    • Member Question - Is it continually being looked into? Can you let them know it's an ongoing issue? When we call to get details, it varies on how successful it is to get the information needed.
      • Noridian: At this point, it is a federal issue rather than a DME MAC one; however, we will continue to report your comments and pass your feedback on to the Contact Center.

DME

• Level 200 Ventilator Webinar
  • Three scenarios completed, looking for two more
• Frequently Asked Questions – Philips Respironics Respiratory Products Recall – Revised
  • Initially published June 25, revised July 16
  • Frequently Asked Questions (FAQ) posted on Noridian website
  • No updates, waiting on further direction
• Physician-directed Prior Authorization (PA) Education
  • Webinar will be presented on October 27 at 1 PM CT
  • Part B will also be in attendance
• Joint POEAG to develop education for clinicians ordering DMEPOS
  • In progress
  • Tentatively looking at development by policy
    • Suggestion - CGM, there constant commercials, it seems to be a hot topic
    • Suggestion - Enteral and parenteral nutrition (after checklists have been reviewed)

O&P

• Nothing pending

New Items

General

• L200 Respiratory webinars
  • In-process as of October for oxygen, pap, nebulizers
• Ask the contractor teleconference (ACT)
  • Scheduled for November 11
  • General - all topics
• Last mini - ACT
  • Scheduled for December 6
  • Topic suggestions?
• Open meeting announcement - Nebulizer proposed local coverage determination (LCD)
• Open meeting announcement - Pneumatic Compression Devices proposed LCD

Suggestions from POE Advisory Members

1. Next Meeting: January 2021 - date to be determined
   
   Noridian: Does this third Wednesday continue to work for the majority?
   
   Member Responses: Yes
2. Member Question: With the Advance Beneficiary Notice of Noncoverage (ABN) guidelines effective October 14, is the change the based on the date the beneficiary signed the ABN or the date of service? For example, the beneficiary signed the ABN in June, it's in place right now, and we planned to renew it in June 2022. Now with this change, is this ABN valid ongoing or do we have to have it resigned since it was signed prior to October 14?
   
   Noridian: If it wasn't set to renew after October 14, no renewal is needed, unless there is a change in condition. We are hosting an ABN webinar on November 4 that details these changes:
   • Jurisdiction A Schedule of Events
   • Jurisdiction D Schedule of Events
3. Member Question: Regarding CGM, one of our referral sources was under the impression they were no longer requiring covid-related comments in the notes and they were stating others are telling them that beneficiaries do not need to meet requirements due to COVID. Is there any education on this topic?
   
   Noridian: The waivers and flexibilities issued allow for the coverage criteria to not be enforced; however, there has to be a medically necessary reason for the CGM. There hasn't been information from CMS on what to expect after the PHE. If the beneficiary is able to see their doctor and go through all of the normal criteria and they do not qualify, it's good to be cautious.
4. Member Question: Has CMS given instruction to the DME MACs regarding having specific documentation that the beneficiary couldn't be seen due to COVID?
   
   Noridian: No, but medical necessity must be documented.
   
   Member Comment:  There hasn't been any education when it comes to DME-infused drugs; utilization is going down, not up; the policies are extremely limiting
5. Member Question: Is the November 4 ABN webinar specific to DME or all of Medicare?
   
   Noridian: It is a DME-focused webinar.
6. Member Question: What is Noridian's travel availability in 2022?
   
   Noridian: We are planning on traveling, unless the PHE changes.
7. Member Question: Can there be clarification published on power tilt being added to manual tilt and space chairs? They are being approved by Advance Determination of Medicare Coverage (ADMC) but there aren't any coverage criteria.
   
   Noridian: We will look into this suggestion.
8. Member Question: Miscellaneous and custom codes are manually priced but I'm not able locate a publication stating what percent of MSRP they are being reimbursed at. Can this information be published? Cannot otherwise classified (NOC) drugs also be addressed, how are they priced?
   
   Noridian: There is an article that addresses pricing at this link: Pricing - JA DME - Noridian (noridianmedicare.com)
9. Member Question: On October 1, CMS added K0127 for oral appliances, is there any indication of how it will impact E0486?
   
   Noridian: Even though the PDAC has approved a new oral appliance, it doesn't mean the LCD will cover it. E0486 is the only covered code per the policy at this time.
10. Member Question: There was an article published on October 7 regarding Purewick. There is no LCD guidance, are there plans for these to be added to the LCD?
    
    Noridian: An item does not have to have a National Coverage Determination (NCD) or LCD for coverage consideration, please utilize the article published on October 7 for coding guidance.