Jurisdiction E and F Provider Outreach and Education Advisory Group (POEAG) - June 9, 2026

POEAG Member and Noridian Attendees

JE: Amy Fanelli, Angela Amey, Ellyn Staebler, Mitchel Kaye, and Sara Jasper

JF: Carol Self, Elaine Heilman, Jana Weis, Kayla Probert, Nicole Bratlie, Romina Hillier, Sarah Luther, Temika Nelson and Trisha Anderson

Noridian Attendees: Teresa Cirelli, Conner Dingle, Dani Gisvold, Jan Ervin, Kate Peterson, Sarah Fjeld, Taryne Lenaris-Mims, Tim Morrissey, Daylann Robertson, Erica Westbrock, Gina Ahlf, Jared Gibbon, Julie Schroeder, Tanisha Barnhardt, and Vanessa Cirelli

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's 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.
    5. 6/9/26: Respiratory Care in Skilled Nursing Facility article was posted to Noridian's website on June 4.
      • Noridian recommends marking this issue as completed
  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.
    7. 6/9/26: Analysis continues. There are some codes billed by these provider types that are not payable under Medicare with a few listed as Medicaid only codes (G9919, G9920, T1014, and H-codes).
  3. 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 to sign a private pay contract again?
      • Noridian response: Current opt-out provider will automatically renew every two years. Notification letters are sent 90 days before renewal date. To end an opt-out status and re-enroll in Medicare, written cancellation letter received by mail must be submitted at least 30 calendar days before opt-out period expires.
    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. Make sure this is received by Noridian at least 30 calendar days before auto renew date.
    3. Providers serving dual eligible patients are having a hard time billing appropriately. Do you have resources or training?
    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 contracts?
      • Patients must re-sign a new opt-out contract every two years when the providers opt out status renews, and before the patient is seen. Example is under Forms, Private Contract.
    5. If provider that has not opted-out of Medicare sees a patient and collected fees, should they pay fees back?
      • Yes, any collected fees need to be returned. Medicare regulations under Social Security Act, Section 1848 (g)(4) mandates claims to be submitted for all Medicare patients. In cases where a provider has not submitted a claim, Noridian sends a letter to the provider and a penalty occurs. The provider has the option to opt out or enroll in Medicare.
    6. CMS resources found in Internet Only Manual (IOM), Publication 100-02, Medicare Benefit Policy Manual, Chap 15, section 40 and IOM, Publication 100-08, Program Integrity Manual, Chap 10, Sections 10.6.12, 10.7.14
  4. 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. 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. 3/10/26: 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
    5. 6/9/26: Noridian response: The issue is getting too specific for Noridian to respond. The answer may be determined per documentation indicated for the patient. If the patient requested an additional visit to discuss more questions, the decision for surgery doesn't seem to be finalized. If the previous visit was already billed with the understanding the decision for surgery was completed, the documentation would need to support why another visit would be billed with modifier 57 to indicate the decision for surgery was made again on another date. It is the provider's responsibility to include complete documentation, including their though process with the patient's decisions.
  5. SNF PDPM Education Request - 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.
    1. The OIG report identified noncompliant billing in the state of New York. After discussing with Noridian's TPE team, it was identified no changes in trending and our website offers resources. A webinar will not be planned.
  6. 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 and a live webinar is important. Will follow-up with an email.
        • Email was not received.
  7. Hepatitis B Vaccine Denying by Medicare Contractors
    1. 3/10/26: A trend was identified on CPT code 90739 (Hepatitis B Vaccine) being Returned to Provider (RTP) with reason code T32200 across all Medicare contractors. This started January 1, 2026, but is not impacting on every claim. The DDE narrative states: "Claim contains diagnosis code Z23 and there is no condition code A6 for the following bill types: ... 72..."

      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 will research
    2. 6/10/26: Vaccines were denying in the beginning of 2026, and a system update was performed to allow the claims to process correctly. Any claims denied have been reprocessed. If denials are identified, please reach out to our Provider Contact Center.
      • No further questions, considered closed

New Agenda Items

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

  1. Noridian Education Experience (NEE) - Now available to providers and suppliers across all jurisdictions. This expansion ensures consistent access to high-quality, self-paced education regardless of location. NEE is a modern, centralized platform that streamlines provider education into one user-friendly experience, making it easier to find and complete training that supports day-to-day operations and compliance needs. With 24/7 access to a growing library of courses, providers can complete training at their own pace across key Medicare topics. Many courses offer Continuing Education Unit (CEU) credit, supporting ongoing professional development. NEE now serves as Noridian's primary destination for self-paced education, replacing YouTube tutorials as content is modernized and enhanced to improve accessibility, consistency, and overall learning outcomes. As part of ongoing efforts to improve the user experience, NEE registration has been simplified. Providers and suppliers are no longer required to enter a National Provider Identifier (NPI) and Provider Transaction Access Number (PTAN) combination. Instead, registration now requires only the NPI. This enhancement reduces complexity, streamlines the registration process, and helps users more quickly access available training resources. What topics would our POEAG members wish to have included for our self-paced education?
    • Opt-Out topic would be one to consider
  2. Modifier 25 - Providers are requesting clarification on the differences between CMS guidelines and the AMA CPT guidelines.
  3. Radiation Oncology CPT Code 77263 - AMA CPT coding differs from the American Society for Radiation Oncology (ASTRO) coding guidelines. Which guideline should be followed?
    • Noridian response: Usually, the national association coding guidelines from ASTRO are unified with AMA CPT. For this code there is a difference. Noridian would follow the AMA CPT code description to determine the full service is documented and look at ASTRO guidelines for clinical practice guidance and education.
      • 77263: Therapeutic radiology treatment planning; complex requires highly complex blocking, custom shielding blocks, tangential ports, special wedges or compensators, three or more separate treatment areas, rotational or special beam considerations, combination of therapeutic modalities.
  4. Incarcerated Patient - I have tried asking about this topic in a few ways so I thought it would be best to bring to the POEAG meeting for clarification and wondering if information could be added to the Noridian site for Part A IPF Billing Guide and B Incarcerated Beneficiary webpages.
    MLN 908084 Patients in Custody Under a Penal Authority was updated July 2025 and includes an exception for incarcerated patients. It discusses the scenario where the state or local government enforces payment requirement by billing and seeking collection for individuals in a certain legal status. One example is not guilty by reason of insanity. Do I understand this MLN to state that if State or Local law states a patient is responsible for the charges when they are in a mental hospital due to not guilty by reason of insanity or not guilty by reason of lack of criminal responsibility, a facility could then bill with a condition code of 63 on the facility claim or a QJ if it is a professional claim to Medicare? If the State or Local law does not indicate the patient is responsible for the charges or they do not enforce the payment requirement, then the services are not billable to Medicare?
    • Noridian response: The MLN states "The state or local government entity enforces the payment requirement by billing and seeking collection from all such individuals in custody with the same legal status (for example, not guilty by reason of insanity)…" There is no broad exception for any specific legal status. It depends on how the state or local government enforces payments requirements for that specific legal status. If the provider has the proof of state enforcement, and Medicare is billed, condition code 63 for Part A, or modifier QJ for Part B, would be appended.
      • Member asked to have added to IPF Billing Guide for Part A. Noridian will review.
  5. Place of Service - The Mental Health Part B page under Psychotherapy and Evaluation and Management (E/M), only lists Office (11), Inpatient (21), and Outpatient (22) as covered places of service. It does not include Nursing Facility (32). I looked through the resources at the bottom of the page, and I didn't see any reason that POS 32 would not be a covered place of service. I understand it is not being covered in SNF (31) as it would be part of the facility payment, but not POS (32). Is there a resource I am missing on why it would not be covered in POS 32?
    • Noridian response: Thank you for requesting clarification. The webpage was updated on June 8 to reflect the correct places of service.
  6. Short Stay Reviews - We would like to know who took over short stay reviews when Livanta, the QIO for California, became Commence Health.

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: September 3
  • Part B: 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. Create an account

Locate on Noridian's website under the Education and Outreach section.

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. Member asked about POEAG webpage and the past minutes, it's all 2025 information. Is there a timeframe this is generally updated?
    • Noridian response: This should have been updated, will have this updated by end of the week.
  2. Are we required to do interim claims for IPS? Or is this an option?
    • Noridian response: this is an option
  3. Member asked about the new CMS Medicare Advantage Grievance process. They have been struggling with the new process. Want to know if there's a contact.
    • Noridian response: This has been sent out for a contact and no response has been received yet.
  4. Member asked about the Sequestration Calculation Alert article posted on the Part A website. Asked if there is a start and completion date for claim processing yet? And if we find claims were missed, who should we escalate these too?
    • Noridian response: Noridian still has this listed on our website. We are still working with FISS and have no update currently. We meet weekly to discuss and hope to have an answer soon.
  5. Member asked if there will be any discussion in upcoming meetings about either the 2027 Medicare Proposed or Final Rule updates?
    • Noridian response: We usually see these proposed rules at the beginning of July. Providers are encouraged to send feedback to CMS when it's asked for. Final rules don't usually come out until November. We must wait for CMS' final guidance before we can provide any education.
  6. Noridian shared the National AB MAC Ambulance Provider/Supplier Coalition Meeting on 9/16 - The MACs will present information on Current Active Medical Review, Additional Documentation Requests (ADRs), and the Comprehensive Error Rate Testing (CERT) program. We will then provide answers to your pre-submitted questions. If time permits, we will take live questions.

    MACs involved with the coalition include:
    • Palmetto GBA
    • Wellpoint Federal
    • CGS Administrators
    • First Coast
    • Wisconsin Physician Services (WPS)
    • Novitas
    • Noridian

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