Jurisdiction E and F Provider Outreach and Education Advisory Group (POEAG) - March 10, 2026

POEAG Member and Noridian Attendees

JE: Avery Malate, Becky Clearwater, Ellyn Staebler, Luci Hendrickson, Mitchel Kaye, Sara Jasper, and Susan LaPadula

JF: Carol Self, Elaine Heilman, Heather Pazak, Jana Weis, Kayla Probert, Lisa Beyer, Nicole Bratlie, Romina Hillier, Temika Nelson and Trisha Anderson

Noridian Attendees: Teresa Cirelli, Corinne Medina, Dani Gisvold, Kim Phillips, Tim Morrissey, Tracy Schutt, Valerie Cavett, Julie Schroeder, and Kelsey Slettebak

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).

Prior POEAG Member Recommendations

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

  1. 12/10/24: Pulmonary Rehabilitation Services in a Skilled Nursing Facility (SNF)
    All of the CMS guidelines state that pulmonary rehabilitation cannot be reimbursed when performed in a SNF. If there is a claim example, we can look to see how it processed through our system.
    1. 6/10/25: We received one claim example regarding pulmonary rehab services performed in a SNF.
      • The claim did not include pulmonary rehab (PR) codes, 94625 and 94626. The codes on the claim example were 94060, 94760, 94664, are for pulmonary diagnostic testing, pulse oximetry services, inhaler education, etc. and are not under the pulmonary rehab. These services are respiratory therapy codes, which would be services allowed in a SNF.
      • Pulmonary rehab includes:
        • 94625 - Physician or other qualified health care professional services for outpatient PR; without continuous oximetry monitoring (per session) or
        • 94626 - Physician or other qualified health care professional services for outpatient PR; with continuous oximetry monitoring (per session)
      • Vendors are visiting SNFs, selling that their program is endorsed by Medicare. They provide diagnosis codes, CPT codes, and it doesn't seem correct.
        • Suggestion: 22X Type of Bill (TOB) or 23X TOB, 0460 Revenue Code
        • Suggestion: Follow-up with CMS and once providers have all of the information, MACs can release a Local Coverage Determination (LCD).
      • If a physical therapist visits a SNF and performs therapy, which codes would they bill?
        Noridian Response: They should bill the code for the service they are providing.
    2. 9/9/25: SNF Part B Billing: Pulmonary and Respiratory Therapy are these allowable services provided within a SNF?
      • Noridian response: Multiple emails and discussions have taken place since our last POEAG meeting.
        • Claim example received from "Tammy": claim did not pay as was indicated. Reached out for additional examples and did not receive any.
        • A SNF resident needing skilled services is covered under Part A Medicare benefits. Almost all services are covered under the SNF stay or exempt due to SNF Coordination of Benefits (CB)
          • A custodial resident is at a non-skilled location and services are covered under Part B of A. The claim example indicated a non-skilled custodial resident.
          • Respiratory therapy is not included in SNF CB for Part B residents, only physical therapy, occupational therapy and speech language pathology are included.
      • Understanding that claims paid on a large scale under Part B
    3. 12/9/25: Request for clarification between LCD Article A57224 and the CMS Internet Only Manual, Claims Processing Manual, publication 100-04, Chapter 7.
    4. 3/10/26: The article referenced has been corrected with the update published on Noridian's website on February 12, 2026.
      • Summary of Changes: Removed Type of Bill (TOB) 022X, Skilled Nursing - Inpatient (Medicare Part B Only) to align with Internet Only Manual (IOM) 100-04, Chapter 7, Section 10.1.1.
      • Members requested an article to be posted to confirm Pulmonary and Respiratory therapy cannot be billed separately for a Medicare patient in a Skilled Nursing Facility (TOB 022X). Once posted, Noridian recommends marking this issue as completed. Members agree.
  2. 3/11/2025: Marriage and Family Therapist (MFT)
    1. MFT providers are receiving letters from Noridian regarding their enrollment status. Letters are sent when Noridian receives a claim from a beneficiary, and the provider is not registered as being able to provide these services. Due to Mandatory Claims Submission, aside from opt out providers, if services are provided to a Medicare beneficiary, the provider is required to submit a claim. If a provider is not enrolled with Medicare, that person is not allowed to see Medicare beneficiaries. Payment needs to be refunded. Noridian may add to an upcoming newsletter or schedule a 30-minute webinar and will reach out to the member as they are looking for next steps to take after receiving the letter. Noridian will look into options for adding information to the letters to assist providers.
    2. How many MFTs have applied to Noridian? The total number of Marriage and Family Therapist in JE and JF is 7,638 and Mental Health Counselor for JE and JF is 6,185. Currently, the pending application for MFT and MHC is 607 total.
    3. 6/10/25: Issue has quieted down
      Noridian: When marriage and family therapists (MFTs) and mental health counselors were rolled out as a provider type, they weren't included in PECOS. We are finding that we are unable to update the specialty from Other to MFT or mental health counselor. We are working on a resolution.
    4. 9/9/25: As of January 1, 2024, Medicare Part B has expanded outpatient mental health benefits to include licensed marriage and family therapists and mental health counselors. A proposal to analyze utilization trends and reimbursement frameworks to guide providers was received.
      • This is being reviewed internally.
    5. 12/9/25: Utilization analysis.
    6. 3/10/26: Analysis continues.
  3. Resident Billing in Mental Health - Can there be additional information that clarifies resident billing under the Mental Health specialty including information about the psychiatry GME primary care exception?
    1. 9/9/25: This will be researched for adding information to the webpage
    2. 3/10/26: Website has been updated to include this information
  4. Opt-out Renewal - Providers coming up on their auto-renewing and have questions.
    1. If they want to opt-in, they need to contact Noridian at least 30 days prior to the renewal date. Do they need to provide communication to patients and if remaining as opting out, do they need their Medicare patient sign a private pay contract again?
      • Noridian will research.
    2. If a provider initially opted out, but now wants to opt-in, does the letter need to state anything specific?
      • Name, address, email, NPI, PTAN, a clear statement regarding not wanting to renew opt-out status, signature, and date
    3. Providers serving dual eligible patients are having a hard time billing appropriately. Do you have resources or trainings?
      • Noridian will research.
    4. Renewal for the first time is coming up. Is it only upon the initial opt-out that the patient needs to sign the private pay contract? Do patients need to re-sign private pay contract?
      • Patient needs to sign opt-out contract every two years. Example is under Forms, Private Contract.
    5. If a provider that has not opted-out of Medicare sees a patient and collected fees, should they pay fees back?
      • In these cases, Noridian sends a letter to the provider and a penalty occurs. The provider has the option to opt out or enroll in Medicare.
      • Noridian will research paying money back
  5. SNF Consolidated Billing Webinar (11/13/25) - Under Arrangement Agreements
    1. Opportunity to add written guidance on Noridian's website. CMS Sample Agreements are often overlooked yet remain essential for ensuring compliance, consistency, and clarity across SNFs. Providing a centralized, accessible reference would strengthen provider understanding and reduce the risk of misinterpretation in this complex area of billing.
      • Noridian response: We received a question from one attendee during the webinar. A response to the attendee was followed up after the webinar.
    2. 3/10/26: Noridian did not respond to all attendees. After talking with the one attendee, it was determined that both the webinar host and the attendee had the same understanding. No changes were made to the webinar education. Noridian stated a written agreement is not required but highly suggested. The reference the attendee indicated has been archived with current information included in the CMS Internet Only Manual, 100-04, Chapter 6, Section 10.4, which states: Whenever possible, SNFs should document arrangements with suppliers in writing, particularly for ongoing services (e.g., labs, x-ray, pharmacies). The word 'should' denotes an optional requirement.
  6. Pre-op Billing. If a patient has a pre-op exam 20 days before surgery, is that included in the global period?
    1. 9/9/25: The current CMS manual section to reference is, CMS IOM, 100-04, Chapter 12, Section 40.1. Global surgery days are determined by the procedure and if there are 10-days or 90-days global period. Any services related to the procedure and performed during the global period would bundle. Reference the CMS MLN Booklet for Global Surgery.
      • 10-day global includes the day of surgery and 10 days following
      • 90-day global includes the day before surgery, day of, and 90 days following
    2. 3/10/26: The CMS edits would deny a related E/M service included within the global days. If the pre-op exam is performed outside of the global days, medical necessity would need to be indicated to bill the service to Medicare. Modifier 57 should be included in the visit when the decision was made for a major surgical procedure. Patients with medical conditions could have a medically necessary reason to complete a pre-op exam outside of the global period. Such as a patient with a cardiac condition and anesthesia may be a concern for the anesthesiologist. Documentation is needed to support the medical necessity.
    3. Counseling on use of prosthetics following implant surgery within 90-day global period. Visit performed by provider within the same group.
      1. Per the CMS MLN Global Surgery booklet, "The global surgical package, also called global surgery, includes all necessary services normally provided by a provider (or members of the same group with the same specialty) before, during, and after a procedure. Providers in the same group practice, with the same specialty, must bill and accept payment as though they're a single physician." Physician assistants working under supervision of the surgeon, within the same group practice, could be viewed as the same specialty.
    4. Member would like to see article posted on both scenarios due to outside representatives providing incorrect information.
      1. Counseling, decision for surgery, patient goes home and decides they need to make a second appointment to ask additional questions. How does that fit into the 90-day global period? Noridian will research.

New Agenda Items

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

  1. Webinar request: Skilled Nursing Facilities (SNFs) Notices Required to Beneficiaries -
    1. Suggestion to provide a webinar that clearly outlines which Medicare denial notices must be issued to beneficiaries and under what circumstances. An updated instructional session would benefit providers as existing guidance no longer reflects the operational realities or current regulatory expectations.
      • Noridian response: Which specific notices need to be referenced? We are currently working on updates for our self-paced education, and this may be an opportunity to include.
        • Member response: Include all notices a patient may receive in a SNF, and a live webinar is important. Will follow-up with suggestion via email.
  2. Noridian Education Experience (NEE) - What topics would our POEAG members wish to have included for our self-paced education?
    1. Residential SUD coverage
  3. Hepatitis B Vaccine Denying by Medicare Contractors - Member has identified a trend regarding Return to Provider (RTP) claims for CPT code 90739 (Hepatitis B Vaccine) across all Medicare Contractors. Effective January 1, 2026, these claims are returning with Reason Code T32200. This is not impacting every single claim.
    1. The DDE narrative states: "Claim contains diagnosis code Z23 and there is no condition code A6 for the following bill types: … 72…"
    2. Current guidelines define Condition Code A6 specifically for Pneumococcal pneumonia and influenza vaccines reimbursed at 100%. Since this definition does not historically include the Hepatitis B vaccine, can you please confirm if this edit is triggering in error, or if there has been a policy update expanding the use of A6?
      • Noridian's Response: Our Part A Provider Contact Center have received calls on this issue across all facility types for the FISS edit 32200. An inquiry ticket was submitted and was escalated to the FISS workgroup.

Top five inquiries to Provider Call Center (PCC) (last 30-days)

  • Part A
    • Missing or invalid code
    • Contractual obligation not met
    • Coding errors or modifiers
    • Claim overlap
    • Medical necessity
  • Part B
    • Coding errors or modifiers
    • IVR or NMP referral
    • 1500 form item
    • Missing or invalid codes
    • Medical necessity

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

2026 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.

  • Part A: March 5 and September 3
  • Part B: April 8 and December 9
  • Submit questions in advance through the Pre-Question Process on our website under the Education and Outreach section.

Please share recommendations for any timing, frequency, size, topics, and provider type(s) for the 2026 ACM schedule.

Noridian Educational Experience (NEE)

Now live on our Education and Outreach section of our website. Some POEAG members helped test and review this new educational opportunity. We appreciate the feedback that was received and are excited to now have this education with continuing education units (CEUs) available. To create an account, a valid NPI and PTAN are required.

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.

  1. MolDX - Coverage has been expanded for one Z-code resulting in duplication for two tests. How do we possibly get a new MolDx Z-code issued?
    1. Email Palmetto directly: moldx@palmettogba.com
  2. Physical therapy referrals - Multiple physicians continue to refer patients for outpatient therapy but will not sign the recertification. What can a physical therapist do without a signed recertification?
    1. Noridian will research.
  3. Office of Inspector General (OIG) report on a skilled nursing facility billing for services not in compliance with the Patient Driven Payment Model (PDPM). Suggestion for the TPE group to provide detailed training on specific errors they have found.

Upcoming Meetings

Meetings for 2026

  • We continue to meet four times per year.
  • When: All meeting times 2-3 p.m. CT, 1-2 p.m. MT, and 12-1 p.m. PT
    • March 10
    • June 9
    • September 8
    • December 8

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

Last Updated Jun 12 , 2026