Provider Outreach and Education Advisory Group (POEAG) Meeting Minutes - July 21, 2022

Attendees

POEAG: Wayne Bradberry; Ronda Buhrmester; Glenn Closurdo; Cindy Coy; Patty Donndelinger-Bogyo; Crissy Hill; Marsha Lawrence; Noel Neil; Robin Nyberg; Jan Palmer; Charles Robinson; Erica Rochelle; Maria Sanchez; Jera Sitton; Barb Stockert; Mary Stoner; Dan Vasilj; Michelle Wullstein; Lesleigh Sisson

Noridian: Amber Mertz; Brenda Swancy; Cindy White; Colleen Harryman; Dan Schmitt; Kelsey Slettebak; Kloe Roberts; Melissa Betts; 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

  • Coronavirus (COVID-19) Public Health Emergency (PHE)
    • Waivers and flexibilities remain in place
      • Extended until October 6, 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 Meetings

General

  • Joint POEAG to develop education for clinicians ordering DMEPOS
    • Two meetings have been held focusing on sleep
    • Great suggestions
      • Provide education during residency
      • More webinars for providers on DME requirements
    • Looking for supplier volunteers for a similar Glucose meeting, willing to recruit practitioners
  • Collaborative MAC education
    • Glucose Monitors and Supplies
      • August 25, 2022
    • Respiratory
      • November (TBD)
    • Pneumatic Compression Devices CERT Taskforce
      • October 5, 2022 (tentative)
  • 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 continue

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 - August 9, and November 10
    • General - all topics
  • Removal of Certificate of Medical Necessity (CMN) and DME Information Form (DIF)
    • January 2023
  • Level 200 webinars
    • Please send scenarios you would like to see included
    • Send to the POEAG email address

Suggestions from POE Advisory Members

  • Prior Authorization (PA)
    • For clarification, to bypass PA for emergent situations, the KV or ST modifier can be used. Is this correct?
      • Yes, the KV is for providers that supply the brace during the office visit in a competitive bid area and the ST is for emergent situations for suppliers. Documentation must be available that supports the emergent situation and this is up to the treating practitioners.
  • Advance Beneficiary Notice of Noncoverage (ABN)
    • The Noridian website implies that ABNs should be used if suppliers do not have a supplier number. We are seeing suppliers having beneficiaries sign ABNs for covered items and then charging the beneficiaries.
      • This is correct. The Internet Only Manual, Publication 100-04, Chapter 30, Section 50.11 states: "ABNs for Medical Equipment and Supplies Claims Denied Under §1834(j)(1) of the Act (Because the Supplier Did Not Meet Supplier Number Requirements) (Rev. 10862; Issued: 07-14-21; Effective: 10-14-21; Implementation: 10-14-21) To qualify for waiver of the RR under §1834(j)(4)(A) and §1879(h)(1) of the Act (unassigned and assigned claims, respectively) for medical equipment and supplies for which payment will be denied due to failure to meet supplier number requirements under §1834(j)(1) of the Act, the ABN must state that Medicare will deny payment for any medical equipment or supplies because the supplier does not have a supplier number. The supplier should keep the ABN on file for documentation that the beneficiary has knowledge of this particular denial and that the beneficiary accepts financial liability. This relieves the supplier, which has duly notified a beneficiary of its lack of a supplier number and the fact that Medicare will not pay, from the necessity of obtaining a signed agreement from the beneficiary every time the beneficiary does business with the supplier."
  • Prosthetic Denials
    • Have there been any updates on the CO261 claim denials for prosthetics? These are causing access to care issues now because suppliers can't be paid for older services, now the beneficiary needs new services, and they are being turned away. Claim denial examples that have been researched can be provided. We are finding the surgeon has billed for the wrong level of amputation.
      • We have not received any updates on this; however, Noridian is aware and is discussing with CMS. We will provide information as we receive it.
  • Beneficiary-Owned Equipment
    • In the article "Beneficiaries Entering Medicare with Equipment from Another Payer", it states "Once the beneficiary-owned item is placed on file, subsequent supply claims do not require a narrative." However, our suppliers are still receiving denials.
      • Suppliers receiving these denials need to call reopenings to have "beneficiary-owned" added to the narrative.
    • The suggestion was given to add the ability to add narratives through reopenings in the Noridian Medicare Portal.
  • Modifier Lookup Tool
    • It was noticed that upper extremity orthosis codes are missing the RT and LT modifiers and this is not consistent with the Supplier Manual. In addition, finger modifiers have been corrected in the tool but the YouTube video is incorrect.
    • Noridian updated the Modifier Lookup Tool last week for the fingers. We are in the process of updating the DME on Demand Tutorial and that should be posted shortly. We will look into updating the tool for the upper extremity orthosis codes and appreciate the feedback.
  • Change of Modalities
    • When a beneficiary is using a PAP device for a few months, then the physician changes the beneficiary to a BiLevel, we always get a denial for same or similar. We appeal and it's overturned. Is there a way to streamline this to avoid the appeal process and delay in payment?
      • No, Noridian needs to see the documentation for change in medical need.
    • Is this going to be under prior authorization approach? The delay of cash is causing problems.
      • Noridian has not received communication of any additions to the prior authorization process at this time.
  • Upcoming Oxygen Changes
    • With the oxygen changes coming up, is there any feedback on the template approach?
      • We have not heard anything yet, but we have communicated supplier's concerns to CMS and will educate as soon as we receive information.
  • Finger Orthoses
    • We have finger orthoses claims denied for multiple digits even though modifiers are being used. Medically Unlikely Edits (MUEs) are three but if we bill more than one, they are denied. Even if they are billed for different days and different digits, they are denied.
      • These need to be appealed with documentation to show medical necessity for the additional digits.

Upcoming Meeting

  • Next Meeting: October 20, 2022

 

Last Updated Jul 22 , 2022