Provider Outreach and Education Advisory Group (POE AG) Meeting Minutes - December 13, 2022

Roll Call

POEAG Member or Other (CMS) Attendees

Anna Gauslow, Carol Self, Dawn Davidson, Lisa Beyer, and Mollie Brooks

Noridian Attendees

Teresa Cirelli, Elizabeth Barton, Cheryl Hanson, Dani Aasen, Erin Swaidner, Jan Ervin, Katie Wik, Reanna Doele, Tammy Ewers, Tim Morrissey, Val Cavett, Daylann Robertson, Jennifer Joyce, Julie Schroeder, and Tanisha Barnhardt

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 “Interrupted Stays, Leaves of Absence, and Transfers” that is expected to be available in December.
    2. 12/13: The tutorial was published on December 13 to our Part A Education on Demand Tutorials webpage.
      1. Education on Demand Tutorials - JF Part A - Noridian
  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 paring 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. The member that brought the issue to our advisory group appreciates the work being done as this impact’s providers. Customer Service Reps (CSRs) at Noridian continue to reference an internal list when answering calls for unlisted codes.
    3. 03/08: Work continues with internal departments. Members appreciate the updates and work on this recommendation.
    4. 06/14: Internal workgroup members have changed but activities continue, and an update is expected at the September meeting.
    5. 09/13: Medical Review and Provider Education are working on this project. Working individually with a few providers on their unlisted code billing issues.
    6. 12/13: Not everything is able to be shared on our website. Noridian will work with individual providers as needed based on inquiries received. There were no additional questions or recommendations as of today. This is now considered resolved.
  3. 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 2-day Symposium being planned for March 8 and 9 – March into Medicare.
    5. 12/13: We are excited to offer our March symposium. It is our plan to have the “Save the Date” announcements published soon. We are finalizing the session topics to prepare for a successful event. The original idea stemmed from POEAG and we are proud to be able to meet your recommendations.
  4. 9/13/2022. Molecular Syndromic Panels for Infectious Disease
    1. 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.
    2. 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.
    3. 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.
    4. Noridian’s Response: Medical Review is reviewing the article and the education request. 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)
    5. 12/13: The member initiating this recommendation noticed the published article and shared their appreciation and finalization of this topic from Noridian.
  5. 9/13/2022. Evaluation and Management (E/M) translation of ‘prescription drug management’ meaning for the 2023 guidelines.
    1. People are getting confused on the translation of ‘management’ and that the MDM column 3 is now ‘risk of test or treatment to the patient management’. There is a mindset that because it says prescription (RX) management, if a provider prescribes, then they get credit for this area.
    2. Noridian’s Response: One drug is not the same as the next. Prescription drug management documentation would need to show the work and/or risk involved by the billing provider when managing a prescription. 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?
    3. POEAG recommended 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. 12/13: POE is working with Medical Directors for educational opportunities which may be a webinar or published article. We will provide an update at the next POEAG meeting.

New Agenda Items

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

  1. Appeal Issues
    • Noridian’s appeal team has found providers have hired offshore companies to reduce accounts receivables. The offshore billers are submitting multiple, unnecessary appeal requests. Some are duplicate appeals because the response was not received within two days.
    • Surgical modifiers is one of the largest reasons providers are submitting appeals. Noridian’s POE and appeal experts are collaborating to co-host a webinar in February 2023 based on our appeal analysis. Additional issues we are seeing is submission of the same appeal via reopening and redeterminations up to 20 times for the same claim. Congress defines the Medicare allowed fee schedule and providers are submitting appeals to dispute the approved Medicare Physician Fee Schedule (MPFS) which cannot be appealed. We are receiving automated appeal submissions after 30 days which is less than Medicare contractors are permitted for time to process redetermination requests. There are over 200 appeal dismissals every day for requests that are ineligible for appeals.
    • POEAG members were asked to share what experience and resolution they had pursued to address this issue.
  2. Common requests for education topics received through surveys from our website and following our webinars has resulted in the following recommendations being pursued by Noridian:
    • 2023 Evaluation and Management Changes and Guidelines
      • Chronic Pain Management
      • Critical Care Services
      • Billing for Time
    • 503B Pharmacies and How Drugs Should be Billed
    • Facility Based Education
    • Data on Denials, How Many Overturned Through Appeals Processes
    • Various specialty requests have been or will be scheduled: Gastrointestinal endoscopies (12/15/2022), Eye care (webinar recording available 12/2022), Radiation oncology, Shoulder debridement, Iron Infusion therapy
  3. MAC Customer Experience (MCE) Satisfaction Survey Update: Surveys reflect the webinar presentation content is informative. We review the survey comments and look for opportunities to improve educational topics, webinar materials and presentation skills. Here are a few comments from recent webinars:
    • Participants continue to appreciate the knowledge they receive from our events.
    • Providers are pleased with having the Webinar-on-Demand recordings. We have expanded the availability from two months to now being available for six months.
    • Including polling questions or web site tours are always a favorite to be engaged during the webinar.
    • Opportunities to consider the timeframe scheduled and allowing time for questions and answers. Requesting examples instead of reading from slides. We have extended some webinar durations from 60 to 90 minutes to address the feedback on the time for material, questions and answer or breaking the material into a multi-part series.
    • POEAG member input for 2023 specific webinar topics are requested to avoid the “repurposed” webinars each year. In our next POEAG meeting, we will share the new webinars and recordings we will be producing based on survey recommendations.
    • Please know we truly value each survey completed as every survey and the comments are reviewed by reps, leadership, management. This is for webinars, webpages, tutorials, event recordings. Your voice drives our education plan.

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

2023 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.

  • Subject to change: March 22 (Part A), April 19 (Part B), August 30 (Part A), and October 11 (Part B) from 3-4 p.m. CT.
  • Submit questions in advance through the Pre-Question Process on our website. Having the pre-submitted questions helps ensure Noridian has the proper experts from our teams (medical review, contact center, medical directors) available to assist.

Please share recommendations for any timing, frequency, size, topics, and provider type(s) for the 2023 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; most often a few hours on Fridays.

POEAG member recommendations for PCC training topic, days of the week, times in the month, 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.

  • A member requested guidance on CPT code 90935 coverage processing against a Noridian Custom Edit (NCE) for a Part B LCD. This has been shared with our Medical Review team to further investigate. Uncertain if this is provider specific or widespread issue, unaware of other members experiencing an issue with this service. We will share our results in a future meeting if not directly with this member.
  • A member requested education regarding the Evaluation and Management (E/M) changes for 2023 to include changes to 99281 emergency department visit as it appears to have removed a component. The Relative Value Unit (RVU) assignment section included an example of using the code when a nurse removes sutures performed by different provider or different location. We know incident to is not permissible in an outpatient setting. We are challenged with how to use this code if there is not a qualified practitioner involvement. Previously, we’ve billed auxiliary staff under facility charges (G0463). How would we use this CPT? What should be included in the medical record and related examples should be included for the E/M education.
    • Noridian shared other MACs also have this point of clarity posed to CMS and are awaiting their guidance.
  • Requested education on how claims should be billed when the dollar amount is larger than seven digits allowed on the claim. From the claims we billed, we are experiencing a lower reimbursement than our cost for J3490, drug Ambuttra. They have to split and add modifiers due to limitation on units.

Upcoming Meetings

Meetings for 2023

We continue to meet four times per year. New in 2023 based on feedback received from membership, we will combine into one meeting to include both Jurisdictions E and F.
When: All meeting times 2-3 P.M. CT/12-1 P.M. PT

  • March 14
  • June 13
  • September 12
  • December 12

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

 

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