Provider Outreach and Education Advisory Group (POE AG) Meeting Minutes - September 9, 2025

POEAG Member and Noridian Attendees

JE: Angela Amey, Avery Malate, Becky Clearwater, Mitchel Kaye, Sara Jasper, Susan LaPadula and Tameka Island

JF: Anna Gauslow, Anna Swiader, Carol Self, Dawn Davidson, Jana Weis, Kayla Probert, Lisa Davies, Mollie Brooks, and Trisha Anderson

Noridian Attendees: Teresa Cirelli, Cheryl Hanson, Corinne Medina, Dani Gisvold, Jan Ervin, Miriam Ocampo-Funderburk, Tim Morrissey, Tracy Schutt, Val Cavett, Carynne Godfrey, Emily Blume, Emily Salvatore, Erica Westbrock, Hailey Smith, Jennifer Joyce, Julie Schroeder, Kelsey Slettebak, Lexi Kibbie, Sarah Zietlow, Tammy Urness and Scott Oien

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. 9/12/23: 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
      • 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? The CPT book states same or related problem. The diagnosis code would not be the only determining factor.
      • 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? It doesn’t state one way or the other and CMS is silent on this.
      • 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.
    4. 9/10: Discussions have taken place and a final draft version is not ready currently.
    5. 12/10/24, 3/11/25, 6/10/25, 9/9/25: Remains an open item without guidance at this time.
  2. 12/10/24: Pulmonary Rehabilitation Services in a Skilled Nursing Facility (SNF)
    All of the CMS guidelines state 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: XXXX  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. 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 of 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.
  4. Skilled Nursing Facility (SNF) CMS Mandatory Off-Cycle Revalidations
    1. 6/6/25: CMS Extends Mandatory SNF Off-Cycle Revalidations to August 1, 2025. On April 17, 2025, CMS formally announced an extension for the mandatory off-cycle revalidation deadline for skilled nursing facilities (SNFs). Noridian updated our website and published an article on May 1.
    2. 9/9/25: In July, CMS extended mandatory SNF revalidations again. The new date is January 1, 2026. Banner has been updated on our website. Guidance for SNF Attachment on Form CMS-855A (PDF)

New Agenda Items

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

  1. Complexity Add-on Codes - G2211 or G0545
    1. G2211 is an add-on code to 99202-99215. CMS provided guidance on when it would be appropriate to add this code to an office or outpatient E/M code. The key element is to show a long-term patient-provider relationship for single, serious or complex conditions. This code is not limited to any specialty. MM13473
      1. These codes significantly underutilized compared to expectations. After speaking with providers, many expressed that they lack strong, specialty-specific examples. While the CMS MLN Matters resource provides a good baseline, providers indicated that having more detailed examples tailored to their specialties would help them feel confident in using these codes.
      2. Additionally, it would be helpful to provide examples related to managing a serious single illness being managed long term. This should include what documentation is expected in the record, how many visits are typically involved, and guidance for situations where the provider recommends the beneficiary see another specialty etc.
        • These recommendations will be passed along to CMS.
    2. G0545 is an add-on code to 99221-99223 and 99231-99236. This code is for compensating the complexity of treating infectious disease patients. Only applies to hospital inpatient or observation care when performed by infectious disease specialist. CMS has limited information on requirements for G0545 currently.
  2. G0447 - face-to-face counseling for obesity, 15 minutes
    1. Medically Unlikely Edit (MUE) allows 2 units. Receiving denials on initial claim and through appeal. Examples will be provided.
  3. Ultrasound code 76942 billed with 20610 or 20611
    1. Modifier 59 was billed on 76942 with the 206XX codes. 20610 code description states without ultrasound. 20611 code description includes ultrasound and should not be billed separately. CPT book shows 76942 is not reported in conjunction with these codes.
  4. Acupuncture - 97813. Can both a professional and a facility fee be billed?
    1. No. This service cannot be billed with modifier 26 (professional) and TC (technical). With a zero indicator for PC/TC:
      0= Physician Service Codes--Identifies codes that describe physician services. Examples include visits, consultations, and surgical procedures. The concept of PC/TC does not apply since physician services cannot be split into professional and technical components. Modifiers 26 and TC cannot be used with these codes. The RVUS includes values for physician work, practice expense and malpractice expense. There are some codes with no work RVUs.
  5. Pre-op Billing. If a patient has a pre-op exam 20 days before surgery, is that included in the global period?
    1. 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
  6. 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. This will be researched for adding information to the webpage
  7. TPE Review - Physical Therapy Plans of Care
    1. Documentation received for Targeted, Probe and Educate (TPE) reviews is missing the initial and current Plan of Care (POC). Also missing the signature on the POC.
      • Facilities undergoing TPE review and participating in education meetings after the decision is rendered, they are being told the POC is considered a delayed POC meaning the non physician practitioner did sign but it was signed beyond the 30 days and the reason is not provided. Once it was explained, the facility asked how to move forward but no information was provided by Noridian. How can this be resolved?
      • Teresa will work with TPE and add information to the website
  8. Telehealth - waiting for CMS update. Currently, the flexibilities are set to expire at the end of September. Congressional action would be needed to allow the flexibilities to continue.
    1. In-person requirements are going to apply starting October 1, except for RHC and FQHCs, in the meantime, if nothing occurs, will there be additional information published around the in-person visits?
      • Yes, we are actively working on this.
  9. CMS Strategic Direction
    1. The CMS Innovation Center’s strategic direction focuses on empowering Americans to achieve their health goals and live healthier lives.
    2. https://www.cms.gov/priorities/innovation/about/strategic-direction

Questions from Noridian:

CERT Non-Response Increase - Noridian is seeing an increase in CERT errors related to no response to medical records requests. This would be an opportunity to encourage timely response and coordination with third parties. How do offices handle a CERT request? Any suggestions to improve internal visibility when requests are received?

  1. Way to get a slide or a summary? CARYNNE SENDING TO TERESA
    1. Is Noridian able to provide laboratories with ordering provider facing materials that they can include in their communications?
      • We do offer an ordering provider letter, signed by our Medical Directors, and it includes information on why it's important for them to provide that information to the laboratories. We will be sure to promote this more in the future.
  2. Those of us who attend webinars all the time, see the same rolling slides every time. Would you dedicate a portion of the webinar to these important points? Also including it in nursing facility education would be beneficial.
    • We will discuss different options with the team and provide a follow-up next meeting.

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

  • Part A

    Missing or Invalid Code
    Coding errors or modifiers
    Claim overlap
    CWF Rejects
    Offsets

  • Part B

    Coding errors or modifiers
    Status
    Frequency or Dollar Amount Limitation
    Duplicate
    Payment Explanation or calculation

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

Virtual Two-day Symposium Coming - October 14-16

We are actively planning our Harvesting Knowledge: Noridian's Fall Symposium. The event will include three half days. Registration is now open on our Education and Outreach section of the website.

  • Oct 14: 9-1 am CST
  • Oct 15: 1-5 pm CST
  • Oct 16: 9-1 am CST

2025 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: February 27 and July 17
  • Part B: May 7 and December 3
  • 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 2025 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.

Upcoming Meetings

Meetings for 2025

  • 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 11
  • June 10
  • September 9
  • December 9

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

Last Updated Dec 04 , 2025