POEAG 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: Wayne Bradberry, Ronda Buhrmester, Dickon Chan, Leonard Coulombe, Julie Dallmann, Pamela Fritz, Rose Gomez, Dawn Jorgensen, Carolyn Koster, Noel Neil, Robin Nyberg, Maria Sanchez, Jera Sitton, Barb Stockert, Kelly Troutman, Dan Vasilj, Scott Wilson, Michelle Wullstein
• Noridian attendees: Shelly Carlson, Kathy Fulton, Daria Gabai, Collen Harryman, Melissa Kuznia, Amber Mertz, Kate Petersen, Ruth Reese, Mary Reineke, Kloe Roberts, Tracy Schutt, Brenda Swancy, Cindy White.

Standing Agenda Items

• Coronavirus (COVID-19) Public Health Emergency (PHE)
  • Waivers and flexibilities remain in place
    • Extended until October 2021
• Targeted Probe & Educate (TPE)
  • No update on resumption
• Post-Payment Clinical Review
  • Please follow the Medical Review page for up-to-date review information
• Education for Practitioners
  • We continue to seek opportunities

Follow-up Information from Previous Meeting

General

• Updated Dear Clinician letters
  • Still have a few remaining
    • Majority updated including:
      • Documentation of Continue Medical Necessity
      • Medical Records
      • Medical Record Authentication - Tips for Clinicians
      • Many policy-specific
    • Done in early July
• New supplier training and checklists
  • All current
• Physician based education for prior authorization
  • A draft presentation has been completed and is in the review process
• Specific training on telehealth
  • Collaborative webinar with A/B held July 13
    • Did anyone attend? Was it beneficial?
      • No comments
• Additional education requested for use of the CR modifier
  • New resource slides were developed following the April meeting and have been utilized in most webinars for the past two months.
• Suggestions for engaging audiences
  • Still evaluating options like the “pop quiz” suggestion

Durable Medical Equipment (DME)

• Additional Enteral and Parenteral education following retirement of Local Coverage Determinations (LCDs)
  • This was just published July 22 (from proposed to future)
    • We are working on new webinars
• L200 Ventilator webinar
  • Continues to be in process
  • Noridian continues to seek examples of scenarios from the supplier community for inclusion in the webinar
• Post COVID-19 PHE Guidance
  • Send questions to DME POEAG email (DMEPOS-POEAG@Noridian.com) and Noridian forwards to CMS

Orthotics and Prosthetics (O&P)

• Nothing specific to O&P pending

New Items

• Frequently Asked Questions (FAQ) - Philips Respironics Respiratory Products Recall - Revised
  • Initially published June 25, revised July 16
• Use of the KU modifier extended for dates of service after July 1, 2021
  • Impacts wheelchair and wheelchair accessory codes
• New article “Correct Billing for Custom Fitted Orthotics when no Custom Fitting is Completed with no Off the Shelf Equivalent”
  • Published May 7

General

• Member comment: Do we have any education around beneficiary owned equipment?
  • Noridian: We’ve done some focused education on beneficiary owned equipment. 
    • Noridian follow-up: We’ve been adding to our webinars, tutorials, articles (elements required). 
• Member comment: Phillips Respironics recall - Suppliers are seeing increasing calls with beneficiaries saying machine will be replaced. He’s not aware of Medicare issuing anything about this. 
  • Noridian: Correct, CMS is aware that the Beneficiary Contact Center (BCC) is suggesting this to beneficiaries.
    • Member addition: How do you recommend we approach this?
      • Noridian: Be sure to clarify with the beneficiary whether Medicare or another source paid for their device as that makes a difference. Beneficiaries should also register their devices. We are working with 1-800-Medicare to make sure they are giving accurate information. The DME MACs continue to work with the Centers for Medicare & Medicaid Services (CMS) to determine what Medicare can allow.
    • Member addition: Reported that a meeting with Respironics and CMS was held regarding this issue. The BCC is expected to change their script.
    • Member addition: I know there’s the FAQ but is there an official script that is shareable with the supplier community?
      • Noridian: The FAQ is the official script. The FAQ does indicate that for equipment paid for by Medicare, the original supplier is responsible for replacement.   
• Member comment: Under what circumstances could the CR modifier be used for refractive lenses?
  • Noridian: It may be possible to use the CR modifier on the Proof of Delivery, if you didn’t have it signed. However, lenses could be shipped, and a signature is not required, so there does not appear to that there would be many circumstances. Perhaps, if they were lost because of hospitalization for treatment.  
• Noridian: We have a question for the group regarding Standard Written Order (SWO). Would a sample template be of value? What would be the most important part?
  • Member comment: This could be valuable, but a template might make non-Medicare auditors require that specific form, so it could have some consequences. 
  • Member comment: This would not be a good idea. For the required elements of an SWO there’s generally the recommendation to include more detail, but it’s not a requirement. If you list just the basic requirements of the SWO, the providers who are inclined to provide additional details may not in that circumstance. Reliance becomes solely on the medical record and may become problematic.
  • Member comment: Same concerns as others. There will always be a reviewer in an audit who thinks this is the “golden rule” and suppliers would need to appeal saying it’s only suggested and may have trouble proving it is a suggested format and not official. Also, can see payers looking at that SWO template as the “golden rule.” Suppliers are happy CMS is potentially moving away from the Certificate of Medical Necessity (CMN) and this would just be a reintroduction of the same thing. The CMN was a template and it eventually became a full form. Many providers have their own form they want to follow, suggesting a template could open them to potential risk. If suggested forms are created, more than one should be drafted and these should clearly indicate that the “example is not all inclusive.” Many physicians and referrals also have forms that they use that are much more detailed.
    • Noridian: Thank you, and this is exactly the type of input we are seeking from suppliers. We will take this information back and discuss it.
    • Member comment: Appreciates the suggestion but is afraid it will become an official rule.
    • Member comment: Agrees with the panel and having a suggested SWO, unless policy specific, could create more problems with reviewers.

Next meeting: October 21, 2021