Provider Outreach and Education Advisory Group (POEAG) Meeting - September 13, 2022

Roll Call

POEAG Member or Other (CMS) Attendees

Dawn Davidson, Jana Weis, Mollie Brooks, Trisha Anderson, and Alexis Christian-Abbott

If you have recommendations for new POEAG members, please encourage them to fill out the registration form; we would love to expand our membership.

Noridian Attendees

Teresa Cirelli, Elizabeth Barton, Becky Paluch, Cheryl Hanson, Dani Aasen, Erin Swaidner, Jan Ervin, Katie Wik, Reanna Doele, Tammy Ewers, Tim Morrissey, Julie Schroeder, and Jennifer Joyce

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. 11/16/2020. Educate on Inpatient Transfers vs Leave of Absence.
    1. Noridian is producing an Education on Demand tutorial on "Transfers, Interrupted Stays and Leave of Absence" that is expected to be available November 1. It is currently under review.
  2. 12/10/2020. Billing Unlisted Codes.
    1. 09/14: A member requested to have more visibility to the internal listing the call center uses for unlisted codes. POE continues working with the call center and our claim processing teams on this possibility. A webpage is under development to assist with unlisted codes and is anticipated to be published early-2022. This topic will be shared with our Contact Center as a Customer Service Representative (CSR) education opportunity so they may avoid referencing internal-only resources.
    2. 12/14: Developing a table to indicate "Top Unlisted CPT" and pairing it with "Preferred Description" (if documentation supports). Ongoing discussions on details are taking place with Medical Review, Adjudication and Appeals teams. The group identified the code with the most errors as 33999.
    3. Trisha had brought this issue to Noridian’s attention and appreciates the work being done as this impacts providers. Customer Service Reps (CSRs) at Noridian continue to reference an internal list when answering calls for unlisted codes.
    4. 03/08: Work continues with internal departments. Members appreciate the updates and work on this recommendation.
    5. 06/14: Internal workgroup members have changed but activities continue, and an update is expected at the September meeting.
    6. 09/13: Medical Review and Provider Education are working on this project. Working individually with a few providers on their unlisted code billing issues.
  3. 06/08/2021. Prior Authorization Updates.
    1. 09/14: The webinar series for Prior Authorization for Certain Hospital Outpatient Department Services was completed in August. Based on frequently asked questions during the webinars, the presentation was updated throughout the summer. One suggestion was to add the reason codes to the PA webpages; this is in the works with the Provider Contact Center.
    2. 12/14: Development to add the reason codes to the PA webpages has started. Plan to have webpages updated beginning of 2022.
    3. 03/08: The webpage updates continue to be in progress.
    4. 06/14: We are looking to add the reason codes to the PA webpage and anticipate an update during the September meeting.
    5. 09/13: Reason codes have been added to the website on 8/31/2022. The reason codes include 39621 and several C54xx codes found on the Part A webpage: Reason Code Guidance - JF Part A - Noridian
  4. 09/14/2021. Donor Claim Denials.
    1. 09/14: A POEAG member previously worked with someone on donor claims denying as duplicate claims when Q3 modifier was appended. Noridian will contact and work with the POEAG member through the example claims and training opportunities internally or externally.
    2. 12/14: Contact from Noridian with the POEAG member to better understand the two claim denials in question and potential larger impact.
    3. 03/08: Noridian is working on the system edits, NCCI edit bypass options, and claim processing for claims billed with modifier Q3 to determine if there are gaps in the implemented claim processing solution.
    4. 06/14: Awaiting guidance Noridian and will ensure POEAG member is contacted as her claims are still not paying. Will be included on future agenda as a follow up and will work with Noridian’s edit team to provide progress.
    5. 09/13: Noridian was able to connect with the member and follow all pending claims through to successfully process. The member appreciated the resolution of this issue.
  5. 12/14/2021. Back to Basics Tutorials.
    1. 12/14: Noridian will offer a tutorial series for new provider staff members to gain exposure and learn more about the basics of Medicare.
    2. 03/08: Tutorial sessions are in development and will be available by early summer.
    3. 06/14: We are still on track with the goal of to begin publishing the basic tutorial series and will provide an additional update on our progress in September.
    4. 09/13: Due to an unexpected leave of absence, this program will be a top priority and expected to be coming out soon. Exciting News! The Medicare basics will be developed into a two-day Symposium being planned for the Spring - March into Medicare. Members were asked to share topic suggestions for this symposium which are welcome through poeag@noridian.com or during a future POE AG meeting.
  6. 03/08/2022. PT modifiers and ASC.
    1. 03/08: Noridian was asked to update the ASC webpage to include the PT modifier information.
    2. 06/14: PT modifier is available on the Modifier webpage. as it is not specific to ASCs.
      1. POEAG member indicated a prior meeting indicated PT was not appropriate in an ASC. The reference received indicated the deductibles did not apply, not that the ASC does not allow the PT modifier. There still may need to be changes made. They’ve not had claim denials but they did receive direction from a PCC indicating it is inappropriate to use the PT in the ASC. They had planned to use this with 33; it did pay. This may require PCC education.
        1. Teresa will return to the call center and research the resource, the webpage, our guidance, and claim processing. If we are not allowing it in an ASC, the POE AG member requested communication be published.
    3. 09/13: For Medicare purposes, modifier 33 is only appropriate when appended to anesthesia services (Type of Service = 7).
      1. Anesthesia for screening colonoscopy that becomes a diagnostic colonoscopy, the anesthesia code 00811 should be submitted with modifier PT, specific for colorectal cancer screening test, converted to diagnostic test or other procedure. This will trigger the claims processing system to not apply the deductible to the service, but co-insurance will still apply.
      2. Modifier 33 and modifier PT should not be submitted on the same claim line for HCPCS 00812.
      3. Beneficiary coinsurance and deductible does not apply to anesthesia code 00812 when furnished in conjunction with screening colonoscopy services and when billed with Modifier 33.
      4. Preventive Services Chart | Medicare Learning Network® | MLN006559 May 2022 (cms.gov)
      5. The POEAG member will be contacted directly to review this issue. It appears to be a specific issue for one provider.
  7. 06/14/2022. Nerve block LCD and Policy Article A52725.
    1. Webinar for Facet Joint Intervention held on July 12. Questions and Answer from the webinar were posted as a Latest Updates article on our website on 8/31.
    2. The POEAG member that posed the question and will review the published article and contact Noridian with her observations.
  8. 06/14/2022. Welcome New Medicare Part B Provider Packet.
    1. Noridian had brought this topic to the POEAG member asking for input on the Part B welcome packet the POE team had been sending to newly enrolled providers. This process is being revamped with Provider Enrollment sending the new provider packets.
  9. 06/14/2022. E/M service for unrelated problems.
    1. A member thought a second E/M would be allowed by a different doctor in same specialty, same entity.
    2. Claims would deny upfront and would need to provide documentation that the reason for the second E/M is unrelated. Reference, ‘Medicare Claims Processing Manual, chapter 12, section 30.6.7.B - Office/Outpatient E/M Visits Provided on Same Day for Unrelated Problems. "As for all other E/M services except where specifically noted, the Medicare Administrative Contractors (MACs) may not pay two E/M office visits billed by a physician (or physician of the same specialty from the same group practice) for the same beneficiary on the same day unless the physician documents that the visits were for unrelated problems in the office, off the campus-outpatient hospital, or on campus-outpatient hospital setting which could not be provided during the same encounter (e.g., an office visit for blood pressure medication evaluation, followed five hours later by a visit for evaluation of leg pain following an accident)."
    3. To support reporting the services separately, maintain distinct documentation for each service.
    4. This item has been resolved.

New Agenda Items

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

  1. Modifier 59 vs X Modifiers - Looking for a better understanding of the X modifiers and when modifier 59 should be used instead. Will the X modifiers count for purposes of the multiple surgery reduction (similar to 59)?

    Noridian’s Response: CMS will accept either modifier 59 or one of the X {E, P, S, U} modifiers. The X modifiers provide additional detail for the reason the additional service(s) are submitted. Neither modifier 59 or the X modifiers will replace the multiple surgery reduction modifier 51. These modifiers have different indications when appending to billing codes for appropriate reimbursement. Medicare will apply the Modifier 51 on the appropriate surgical service if appropriate; we ask that providers not apply the code to their claims.

    The POEAG member will share this with their team as they are using modifier 59 by default more than the others. Multiple surgery reduction, modifier 51, will also be reviewed with their claim team. Other POEAG members shared they do use the X-modifiers frequently as modifier 59 may not fall into the X-modifier criteria. Members may reach out to Noridian as they gain more insight from internal teams. A member from an association will be watchful for related member questions on this topic and notify Noridian if there are industry questions.

  2. Molecular Syndromic Panels for Infectious Disease - Requesting education on Article A58726
    • We receive quite a few denials for this article that was updated 6/2. When reviewing the policy, the list of group 8 has some limitations about the number of codes.
    • What is Noridian’s interpretation of same intended use? I interpret if we are testing for the same infectious agent, others wonder if it’s testing for the same diagnosis.
    • In addition, there is no payable diagnosis list for group 8, but we are seeing CO50 denials when only one code from group 8 is billed. It appears there either may be some editing issues and/or we have some confusion on this article.

    Noridian’s Response: Medical Review along with the Medical Directors are reviewing the article and the education request. The member appreciates the research and contacts that have been made. Following the POEAG meeting, an update was posted on 9/29:

    Article - Billing and Coding: MolDX: Molecular Syndromic Panels for Infectious Disease Pathogen Identification Testing (A58720) (cms.gov)

  3. Evaluation and Management (E/M) translation of ‘prescription drug management’ meaning for the 2023 guidelines.
    • CMS is working with the AMA. People are focusing on the translation of ‘management’ and that the MDM column 3 is now ‘risk of test or treatment to the patient management’. There is definitely a mindset that because it says prescription (RX) management, if a provider prescribes, then they get credit for this area.

    Noridian’s Response: One drug is not the same as the next for the patient. Prescription drug management documentation would need to show the work and/or risk involved by the billing provider when managing a prescription. For example, 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? Jana indicated this is a very layered question as the old guideline FAQs along with other MACs had published before removing items from nonprescription with reasoning and over the counter drug impacts for those with moderate complexity being the doctor responsibility. This is a topic providers are seeking instruction as there is a mindset of "patient comes in with strep, antibiotic is subscribed". With the new guidelines, provider’s need to show they are not just prescribing but they are managing and following up. As part of continuing education, if this can be published in FAQs with examples to guide on what would or wouldn’t qualify may help differentiate. This would be part of moderate in the risk table, and there are questions. While nothing may come in the upcoming Final Rule, the POEAG member indicated 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. Comprehensive Error Rate Testing (CERT) staff have been actively contacting providers this summer that did not respond to requests for medical records. August 22 was the deadline to submit records for the 2022 CERT review. Additional information on CERT can be found on these websites CMS Comprehensive Error Rate Testing (CERT) and CERT C3HUB. Noridian is looking at ways to get the CERT resources more widely advertised. It is important Noridian work with providers to bring down the volume of providers who are nonresponsive to the CERT request for medical records.
  5. MAC Customer Experience (MCE) Satisfaction Survey Update: POE routinely promotes the importance of providers completing these satisfaction surveys from our tutorials, webinars, websites and other interactions. Surveys reflect the webinar presentation content is informative. Here are a few comments from recent webinars.
    • Participants appreciate the knowledge they receive from our events.
    • Providers have sent technical issue concerns to Noridian which resulted in Webinar-on-Demand recordings being pursued and published.
    • Webinar-on-Demand recordings are appreciated and allow additional access to listen to our educational recordings. A POEAG member shared she does not suggest we publish the webinars for longer than 60 days as things change.
    • Opportunities to consider included expanding webinar topics, access questions and answers after the webinar, and awareness of content overload for the timeframe scheduled.
    • POEAG member input for 2023 specific webinar topics are requested to avoid the "repurposed" webinars each year. There are some items such as Modifiers and the Local and National Coverage Determinations which we do multiple times in a year. If members have topic suggestions, please share those with Noridian.
    • Please know we truly value each survey completed as every survey and their comments are reviewed by reps, leadership, management. This is for webinars, webpages, tutorials, event recordings. Your voice drives our education plan.
  6. Two-Day Virtual Symposium - Registration is open for September 21 and 22. Guest speakers will include CMS, Carrier Medical Director, Provider Enrollment, RAC, SMRC, and DME. Additional Noridian topics from Education Representatives will be presented.

Upcoming Education and Training Events

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

Webinars and Schedule of Events

2022 ACTs

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

  • March 23 (Part A), April 20 (Part B), September 28 (Part A), and October 19 (Part B) from 3-4 p.m. CT.
  • 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 2022 ACT 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 made 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.

  • Webinar suggestions for the benefit period and Part B series in 2023 are desired education sessions.
  • Modifier 93 is up and coming in CMS so this would be good to discuss for telemedicine and telephone when the Final Rule is released as it will impact mental health. The new chronic pain management codes will be a topic to share with providers managing chronic pain. There is a listing of underutilized services and is an educational opportunity. There is a disconnect with how the beneficiaries understand services such as AWV and IPPE. Beneficiaries feel these are head-to-toe examinations. They are hoping to comment on the "hear your voice" comment period offered by CMS.
  • E/M changes underway for 2023 would be beneficial to everyone. There had been critical care clarification and add-on when a total of 104 minutes is documented. There is confusion from what AMA is advising which makes it hard to train for Medicare population and non-Medicare. For time related services, it appears CMS is moving away from midpoint. It would be helpful to release when they do permit billing at the midpoint. Practices have heard that counseling and coordination of care at 50 percent is no longer necessary for inpatient and outpatient when following the CMS guides for 2021 E/M changes. Published guidance would be helpful. MDAPP specialty designation from 2023 proposed rulemaking and state-rules for APP with MD in same specialties that differ based on taxonomy and Medicare enrollment with E/M edits on same/day rules make it difficult with CMS and AMA guidance differences. FAQs on the website would be helpful. CMS will need to guide MACs on the rules we are to follow; the feedback is appreciated.
    • Time rules come up quite a bit and the 50 percent rule is not being recognized by all payers anymore. The key differentiating factor is the new time rules and non-face-to-face (FTF) time where providers are spending time for parallel codes and they must reflect what they were performing outside of FTF, documenting time correctly.
  • A52725 article for education has been asked by POE of the Noridian MR team; Teresa will work with MR on a status update. If there are SMART edit issues, the contact center is the best point of contact for issues with the rejected claim. Why do some claims not have comments within the portal; the member will work with Teresa on the example from July. It is nice to work the claims with the SMART edits before they deny. It’s a challenge with the edit when they disagree with the edit and the volume involved. The LCDs had not processed consistently with A and B; Teresa will research the prior communication and provide an update.

Upcoming Meetings

Scheduled Meetings for 2022

When: All meeting times 1-2 p.m. CT

  • December 13

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

 

Last Updated Feb 08 , 2024