Provider Outreach and Education Advisory Group (POEAG) Meeting Minutes - December 12, 2023

Roll Call

POEAG Member or Other (CMS) Attendees

JE: Avery Malate, Candice Kahue-Antone, Mitchel Kaye, Susan LaPadula, and Tameka Island
JF: Anna Gauslow, Carol Self, Dawn Davidson, Jana Weis, Lisa Davies, Mindy Gale, Mollie Brooks, and Kathy Brawley

Noridian Attendees

Teresa Cirelli, Cheryl Hanson, Dani Aasen, Erin Swaidner, Jan Ervin, Kim Phillips, Miriam Funderburk, Tammy Ewers, Tim Morrissey, Val Cavett, Julie Schroeder, Jennifer Joyce, Kathryn Grueneich, Tiffany Anderson

POEAG Mission and Goals

The primary function of the POE Advisory Group is to assist Noridian in the creation, implementation and review of our provider education and training strategy and efforts. The input received from these groups will affect the way educational materials and correspondence are presented, the content contained in them and how Noridian can best provide resources for the provider community.

Prior Meeting Minutes

The prior meeting minutes were distributed to POEAG members and published to the website(s). We house the previous two years of meeting minutes. It is broken down into Jurisdiction E or F. We have completed this entire year as a combined group, so now the minutes are the same for both groups. I think it’s been useful to have everyone together, and I hope you feel that way also.

Prior POEAG Member Recommendations

Below are the POEAG member prior meeting recommendations and the progress or resolution for each item.

  1. 9/13/2022. Evaluation and Management (E/M) translation of ‘prescription drug management’ meaning for the 2023 guidelines.
    1. People are getting hung up is on the translation of ‘management’ and that the MDM column 3 is now ‘risk of test or treatment to the patient management’. There is a mindset that because it says prescription (RX) management, if a provider prescribes, then they get credit for this area.
    2. Noridian’s Response: One drug is not the same as the next. Prescription drug management documentation would need to show the work and/or risk involved by the billing provider when managing a prescription. Is the prescription something that could be harmful to the patient’s health? Will it interact with other drugs the patient is taking? Is the prescription a non-complex drug for a patient with no allergies or complications? Example - a patient taking anticoagulants. Did the patient have a stroke? Is there a risk they may bleed out?
    3. POEAG recommended this would be one of the best topics for planning upcoming webinars. POE will take this to the Medical Directors to pursue with CMS or publish specific by Noridian. The member stated there should be more structure with managing these services.
    4. 12/13: POE is working with Medical Directors for educational opportunities.
    5. 03/14: POE is working with our Medical Directors to see how we can put together this educational opportunity. It may be an opportunity to put together another webinar or an article and include the Prescription Drug Management.
    6. 06/13: Draft article continues to be discussed with Medical Directors. We are looking at ways to incorporate POEAG member suggestions:
      1. Providers are looking for specific documentation requirements. Compliance staff find a challenge educating clinical staff without specific documentation guidance. Other MACs have posted specific documentation requirements.
      2. Internally, staff is looking for the condition requiring medication management.
      3. Members requested including scenarios that would not support medication management. Example: provider refilling medication that is more preventive and the provider is not managing a condition. Medicare is based on lab results.
      4. In the spirit of burden reduction and documenting less, providing documentation guidance for prescription management would benefit providers.
    7. 12/12: Active discussions have taken place and a final draft version is not ready currently. We will have something soon to share. I’m hoping to have it out to you this month, it is requiring a lot of discussion internally.
      1. POEAG member: We know how to support prescription drug management in the note. What it boils down to is the documentation. If the provider selects a code and doesn’t back it up in the documentation, we have to query providers for additional information to support appeals if necessary. Providers state factors were considered when selecting the level, but didn’t document it. I thank you for the consideration to do that extra look for providing feedback for our providers.
      2. Noridian response: It could be a brief sentence to whoever is providing the service, that the risk for this particular is higher because of xyz (comorbities, age). We don’t need a whole page or paragraph.
  2. 9/12:  Suggested Evaluation and Management (E/M) education articles
    1. Copy and paste in Electronic Health Record (EHR) - Some providers copy and paste the history and exam since it is no longer required to choose the E/M level. Old habits are hard to change, and this is not discussed in the current E/M guidelines. Suggestion to develop article with the Noridian Medical Directors.
    2. On-line digital E/M services - 99421-99423
      1. There is specific language within AMA CPT about on-line evaluation and management within seven days of a previous E/M for same problem is not reportable. Would the same problem mean same diagnosis as reported on the claims?
      2. The CPT code book states that all professional decision making and assessment or subsequent management by physicians or qualified health professionals in the same group practice contribute to the cumulative time of the digital on-line E&M. Would this include same provider and provider specialty?
      3. Lastly, would the date of service be the date the on-line inquiry was initiated by the patient? Sometime the messages can span over multiple days so keeping track of the seven days is critical.
    3. 12/12: Those discussions will be had with our CMDs. I couldn’t find all the answers, so it may be something we need to bring to CMS.
  3. 06/13: New A Skilled Nursing Facility (SNF) Five Claim Probe and Educate
    1. CMS Change Request (CR) 13164 provides guidance on the strategy to reduce improper payments for SNF claims and educate providers on correct billing.
    2. Medicare Administrative Contractors (MACs) will sample five claims from each SNF under all jurisdictions.
    3. Global and one-on-one education will be available.
    4. 09/12: POEAG member requested an update on Part A findings for the SNF Probe and Educate review.
      1. MR Part A started the required review of SNF providers for the 5-Claim Probe and Educate reviews in June. Each provider receives a written notice at the time their facility is being implemented. At this time, due to provider response timeframes and MR review timeframes we do not have any trending to share on the providers that were started June-August.
    5. 12/12:  For the SNF 5-claim reviews, here are pieces of documentation that are most commonly missing from provider ADRs submissions:
  4. Certifications or Re-certifications, and reason for delay if late
    • Signature logs
    • Signed physician orders for skilled services
    • Signed copies of physician H&P or Progress notes
    • Therapy treatment notes and logs
    • Nursing treatment logs
    • All documentation for the entire SNF admission to support the Minimum Data Set (MDS) coding of the Health Insurance Prospective Payment System (HIPPS) billed on the claim.
  5. Discussion: Medical Review is considering a checklist with these items. Any questions?
    • POEAG members like the idea of a checklist. Asked to clarify the timeframe for the SNF claim review.
      1. Noridian: CMS requested MACs to review all of the SNF providers in our jurisdictions. The review will continue until all SNFs have been reviewed.
    • POEAG member: Just a comment and question. It’s going to be done after all MACs in every jurisdiction, it can go from next year and so. I am glad to see the common errors Noridian is finding, could a deeper dive into the errors be shared? For example:
      1. HIPPS billed not matching the MDS, more specificity on what they are saying relative to this type of review. This way, as providers, we can update our educational strategy for staff.
      2. On the Appeals side, could example be provided on how the error rate is calculate, whether 5-claim review or regular review? We’re trying to calculate the error rate and it’s not matching on our end. That would be helpful for providers to do necessary self-review for the organization.
      3. Lastly, adding steps on how providers can upload documentation to the Noridian portal would be helpful. In our case, some of the providers have struggled with uploading those records. Sometimes it’s not user friendly.

Agenda Items

Prior to the meeting, Noridian solicited agenda topics from members and evaluated significant program changes to discuss.

  1. Introducing Medicare dental services related to cancer treatments.
    1. Website has information on eligible providers, billing, and documentation. Dental can be found under Browse by Specialty.
  2. Introducing Medicare Family Therapist (MFT) and Mental Health Counselor (MHC) provider enrollment.
    1. Enrollment opened November 2, 2023, for the MFT and MHC providers to submit PECOS or paper applications to start billing for services provided on or after January 1, 2024. That’s coming up within three weeks, that’s quick that they’ll be able to start billing for services. If you have someone in your clinic and facility, now is the time to get them enrolled. We are still waiting on how coverage will look. Some language indicated they would need to possess a Masters or Doctorate degree and have performed 2 years or 3,000 hours of clinical. If you pass Enrollment, congratulations! You’ll be all set to start billing after we get that additional guidance from CMS. Do any of you have a counselor or marriage therapist in your community?
      • One POEAG member indicated they are currently enrolling providers for these specialties
    2. Noridian is waiting for additional guidance from CMS to implement the claims processing guidelines for this new coverage. The 2024 CY Physician Final Rule indicates:
      • An MFT or MHC is defined as an individual who possesses a master’s or doctor’s degree, is licensed, or certified by the State in which they furnish services, and who has performed at least 2 years or 3,000 hours of clinical supervised experience.
  3. Recommendation for in depth webinars regarding Medicare Final Rules
    1. Outpatient Physical Therapy (PT), Occupational Therapy (OT), Speech Language Pathology (SLP)
    2. Outpatient Prospective Payment System (OPPS)
    3. Skilled Nursing Facility (SNF)
    4. Physicians
      • 12/12: Noridian has planned a Physician Final Rule webinar on January 10 and 17. PT/OT/SLP will be included. We are working on developing for SNF and the OPPS.
  4. Has there been an update for ESRD to know if the face-to-face visit must take place during dialysis or if it could take place before (sometime an hour before) and on the same date. Several providers have asked if this has changed or updated to ensure the timing of their visit is in line with coding requirements. Change request 2622 from 2003 and OIG report states physician must have been physically present with the patient at some time during the dialysis.
    1. The CPT manual says: Codes 90935, 90937 are reported to describe the hemodialysis procedure with all E/M services related to the patient’s renal disease on the day of the hemodialysis procedure. It appears the 2003 CR still stands as it is more specific than the CPT definition.
  5. Top five inquiries to Provider Call Center (PCC). This will be included as a standing agenda item.
    1. Part A
      1. Missing or invalid code(s)
      2. Payment explanation or calculation
      3. Contractual obligations not met
      4. Coding errors and modifiers
      5. Claim Overlap
    2. Part B
      1. Coding errors and modifiers
      2. Claim form 1500 item
      3. Referral from self-service on the Interactive Voice Response (IVR) or Noridian Medical Portal (NMP)
      4. Duplicate denials
      5. Medicare Secondary Payer (MSP) questions
  6. Reviewing EDI Reports for Rejections - Internally, we’ve found that providers may not be fully understanding Noridian Custom Edits (NCE). They are Part B front end edits to provide information or reminders on claims that are likely to deny without additional information. The NCE will reject a claim to allow the additional information to be added. Before we can process these claims, they need to be updated and re-submitted.
    1. NCE rejections will show on the electronic 277CA report.
    2. For discussion: Are POEAG members involved in billing familiar with the report? What is your process to review NCE rejections? This may be an area we can include education if providers are not familiar with it.
  7. Noridian’s MAC Customer Experience (MCE) Workgroup would like to hear from POEAG members.
    1. What opportunities for improvement are available on the Noridian website?
    2. Has anyone experienced any website issues?
    3. Are you able to find what you’re looking for?
    4. What about our site is easy to navigate?
  8. MCE Satisfaction Survey Update: Surveys reflect the webinar presentation content is informative. We review the survey comments and look for opportunities to improve educational topics, webinar materials and presentation skills. Here are a few recommendations for future education:
    1. Behavioral Health - We always like to have that suggestion come in. Cheryl is focusing her education here.
    2. Claim Denials and Submissions - It can take care of some of those items in the top call centers inquiries.
    3. Critical Access Hospital (CAH)
    4. Clinical Research - Interesting, I’m not sure how that education would go unless we have a certain topic.
    5. Cost Reports
    6. Documentation Requirements
    7. Gynecology - I know we have gynecologists in Medicare. We don’t have anything on our website, so it’s something we need to look into.
    8. Hematology
    9. Inpatient/Outpatient Hospital Billing
    10. Laboratory Billing
    11. Supervision Requirements
    12. Neurology
    13. Orthopedics

Upcoming Education and Training Events

Providers can view Ask the Contractor Meetings (ACMs), webinars, and related training opportunities by visiting the "Education and Outreach/ Schedule of Events" section of our website.

Webinars and Schedule of Events

New! Virtual Two-day Spring Symposium - April 17 and 18

Watch for education sessions to be posted soon.

2024 Ask the Contractor Meetings (ACMs)

CMS requires quarterly ACMs (formerly ACTs). Noridian offers a question-and-answer portion within each webinar to help streamline applicable topics, audience, and questions for experts.

  • March 20 (Part A), April 10 (Part B), August 28 (Part A), and November 6 (Part B) from 3-4 p.m. CT, 2-3 p.m. MT, and 1-2 p.m. PT
  • Submit questions in advance through the Pre-Question Process on our website

Please share recommendations for any timing, frequency, size, topics, and provider type(s) for the 2024 ACM schedule.

Provider Contact Center Training

CMS approves training for Customer Service Representatives (CSRs) for up to eight hours per month. The training improves consistency and accuracy, understanding of issues, and knowledge retention. POE participates in training Customer Service Representatives each month.

POEAG member recommendations for PCC training topic or related recommendations are welcome.

Electronic Mailing List (Listserv)

Noridian’s email list is routinely distributed Friday mornings with a CMS-authored MLN Connect sent out each Thursday. Noridian’s providers will benefit by seeing outreach opportunities and register as those events are available.

New POEAG Suggestions and Recommendations

During each meeting, all POEAG members are asked to provide suggestions on ways to increase education, improve training methods, CSR training topic recommendations, or elaborate on topics discussed during the meeting.

  • New Complexity Code G2211 - Is there any opportunity for additional education on this new code? We are struggling a bit on how to use this code and the necessary documentation. If you’re hearing anything from CMS on that code, I think there’s a lot of interest into properly capturing it. Would like to know how it applies to new patient codes as an add-on code. It’s unclear due to the ongoing contact with the patient. Examples would be helpful.
    • Response - Sometimes CMS hasn’t issued guidance, so we have to wait on that part. Education is still being developed and we will see if this can be included in the January webinar.

Upcoming Meetings

Meetings for 2024

We continue to meet four times per year. We try to do them around the same time as quarterly updates. Any suggestions for changing these proposed time or dates?
When: All meeting times 2-3 p.m. CT, 1-2 p.m. MT, and 12-1 p.m. PT

  • March 12
  • June 11
  • September 10
  • December 10

Thank you for attending today’s meeting. We look forward to working with all of you again.

Last Updated Mar 06 , 2024