Jurisdiction E and F Provider Outreach and Education Advisory Group (POEAG) - December 9, 2025

POEAG Member and Noridian Attendees

JE: Avery Malate, Becky Clearwater, Cheryl Bradley, Luci Hendrickson, Sara Jasper, and Susan LaPadula

JF: Anna Swiader, Dawn Davidson, Lisa Beyer, Mindy Gale, Nicole Bratlie, and Romina Hillier

Noridian Attendees: Teresa Cirelli, Corinne Medina, Dani Gisvold, Kim Phillips, Tim Morrissey, Tracy Schutt, Val Cavett, Kelsey Slettebak, Dan Schmitt, Daylann Robertson, Marci Eckroth 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.
      • 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.
      • 9/10: Discussions have taken place and a final draft version is not ready currently.
      • 12/10/24, 3/11/25, 6/10/25, 9/9/25: Remains an open item without guidance at this time.
      • 12/9/25: Item will be removed due to no CMS policy or written guidance.
  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. 12/9/25: Request for clarification between LCD Article A57224 and the CMS Internet Only Manual (IOM), Claims Processing Manual, Publication 100-04, Chapter 7.
      • IOM does not state respiratory services as a service that can be billed. This will be researched.
  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.
    5. 12/9/25: Utilization analysis has been requested.
  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)
    3. 12/9/25: Requested update. CMS has not provided an update to the Medicare contractors.
      Noridian response following meeting: CMS published information in the MLN Connects Newsletter for December 11, 2025. Revalidation deadline is indefinitely suspended.
  5. 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.
    2. 12/9/25: Call reference numbers provided. Explained CMS allows up to 22 visits for codes G0447 and G0473 combined, in a 12-month period.
      • First month: 1 face-to-face visit every week
      • Months 2-6: 1 face-to-face visit every other week
      • Months 7-12: 1 face-to-face visit every month if the patient loses at least 3 kg (6.6 lbs.) during the first 6 months
  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. 9/9/25: This will be researched for adding information to the webpage
    2. 12/9/25: Webpage to be updated.

New Agenda Items

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

  1. New Provider Packet - Streamlined Updates
    • Revisions for new providers will ensure essential information is highlighted in the email for easier readability with resources to locate additional information.
  2. 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.
        • Member requested to send out to all attendees
  3. CWF Errors Related to Medicare Advantage Plan - Requested discussion regarding notice on Noridian website
    • Member not in attendance.
  4. Inpatient at One Facility - Needs Service from Another Facility
    1. Clarification on appropriate billing when inpatient at one facility requires a service from another facility due to not having the resources needed at admitted facility.
    2. Example: Patient at hospital A which is an Inpatient Psychiatric Facility (IPF), but hospital A does not have an Orthopedic Surgeon. Client is sent to hospital B to see the Orthopedic Surgeon and then returns to hospital A after the visit.
      • Would hospital A be responsible for reporting technical services at hospital B on their inpatient facility claim since the patient was inpatient status at hospital A during that time?
      • Reviewed the IOM manual for guidance and didn't see clear guidance. There is a notice about no special rules for billing IPF inpatient ancillary services and IPFs are subject to the 1-day payment window for outpatient bundling rules. The one-day payment window rule does indicate reporting services on the bill in certain scenarios:

        40.3 - Outpatient Services Treated as Inpatient Services (Rev. 3030, Issued: 08-22-14, Effective: ASC X12: January 1, 2012, ICD-10: Upon Implementation of ICD-10, Implementation: ICD-10: Upon Implementation of ICD-10, ASC X12: September, 23 2014)

        A. - Outpatient Services Followed by Admission Before Midnight of the Following Day (Effective For Services Furnished Before October 1, 1991)

        When a beneficiary receives outpatient hospital services during the day immediately preceding the hospital admission, the outpatient hospital services are treated as inpatient services if the beneficiary has Part A coverage. Hospitals and A/B MACs (A) apply this provision only when the beneficiary is admitted to the hospital before midnight of the day following receipt of outpatient services. The day on which the patient is formally admitted as an inpatient is counted as the first inpatient day.

        When this provision applies, services are included in the applicable PPS payment and not billed separately. When this provision applies to hospitals and units excluded from the hospital PPS, services are shown on the bill and included in the Part A payment. See Chapter 1 for A/B MAC (A) requirements for detecting duplicate claims in such cases.
      • The billing procedures to avoid duplicate claims indicate that a hospital must have billing procedures in place for outpatient services included in the DRG when at another hospital.
      • The Noridian IPF billing guide page does indicate the IPF is responsible for the services at another facility but does not clarify if the ancillary services should be reported on the inpatient claim or not.
        • Noridian Response: Hospital A reports all services on the UB-04 claim. Professional services would be billed by the practitioner to Part B
      • CMS IOM, 100-04, Chapter 3, Section 10.4 states: All items and nonphysician services furnished to inpatients must be furnished directly by the hospital or billed through the hospital under arrangements. This provision applies to all hospitals, regardless of whether they are subject to PPS.
      • If patient goes to hospital B and returns to hospital A on the same day, hospital B must look to hospital A for payment under an arrangement. Hospital B cannot bill anything to Medicare while the patient is an inpatient at a different hospital. Patients cannot be inpatient and an outpatient at the same time.
      • If patient is at hospital B overnight, the interrupted stay policy applies (190.7.1 & 190.10.7) hospital B can bill Medicare.
      • CMS IOM 100-04, Chapter 3, Section 40.3 excerpt is specific to Outpatient Services Followed by Admission Before Midnight of the Following Day (Effective For Services Furnished Before October 1, 1991). It does not apply to this situation.
      • Avoiding duplicate claims is referring to the arrangement between both providers. Similar to ones found on Best Practices Guidelines.
    3. Suggestion to add verbiage to the Noridian IPF billing guide will be reviewed. Noridian will research updating billing guide.
  5. Medicare Crossover Claims. Medicare crosses over claim to Medicare Advantage Cost plan (Medica Prime and Health Partners). The Medicare Cost plan is primary insurance, but only when the provider is in network. If the provider is not in-network, then the claim should be filed to Medicare (Noridian). Member is submitting claims to Noridian, then receiving denials due to Noridian crossing over the claims to the Cost plan. Should Noridian be crossing over a claim to a Medicare Cost plan?
    • Noridian doesn't cross claims over to a Medicare Advantage plan. The claim would deny from Noridian indicating the patient is enrolled in an HMO plan. If a patient has a Medicare Advantage plan, all claims would be processed by that plan and not traditional Medicare. When a provider is out-of-network, the Medicare Advantage plan should process as such.
    • Noridian will research with CMS when it is a Medicare Cost plan. Two claim examples were reviewed for the same patient. The first claim went towards the patient's deductible. The second denied as a duplicate claim. Claims can cross over to other payers when that payer has selected an option to crossover Medicare claims is set up.

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

  • Part A
    • Missing or Invalid Code
    • Contractual Obligation Not Met
    • Claim overlap
    • Duplicate
    • IVR/NMP Referral
  • Part B
    • Coding errors or modifiers
    • 1500 Form Item
    • Status
    • Missing/Invalid Codes
    • Duplicate

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. Opt-out Renewal - Providers coming up on their auto-renewing and have questions.
    • 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.
    • 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
    • Providers serving dual eligible patients are having a hard time billing appropriately. Do you have resources or trainings?
      • Noridian will research.
  2. Members had questions on previously processed appeals by Livanta. Since their contract termed on August 11, 2025, their voice message says to call the MAC and disconnects. When we call Noridian, we are told to call Livanta. Is there anyone able to assist with our questions?
  3. Request for a webinar on A to B billing. The last one I see is from 2022.
    • Noridian will look into adding one to the schedule.
  4. Members prefer calendar invite to this meeting.

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