Provider Outreach and Education Advisory Group (POE AG) Meeting Minutes - March 11, 2025

POEAG Member and Noridian Attendees

JE

Avery Malate, Becky Clearwater, Candice Kahue-Antone, Cheryl Bradley, Chrystina Ingram, Sara Jasper, Bradley Muldrow, and Tameka Island

JF

Anna Gauslow, Carol Self, Dawn Davidson, Lisa Beyer, Mindy Gale, and Sarah Luther

Noridian Attendees

Teresa Cirelli, Cheryl Hanson, Dani Aasen, Jan Ervin, Kim Brantley Phillips, Miriam Ocampo-Funderburk, Tim Morrissey, Val Cavett, Emily Salvatore, Tracy Schutt, Angie Griffin, Jessica Weathers, Tanisha Barnhardt, Daylann Robertson, and James Marko

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 and 3/11/25: Remains an open item without guidance at this time.
  2. 12/10/24: Patient Eligibility Through Noridian Medicare Portal
    CMS directed MACs to disable the eligibility lookup function through the Interactive Voice Response (IVR) system in March 2025. Providers and facilities will need to obtain eligibility information through the Noridian Medicare Portal (NMP). Education started in November and providers currently utilizing the IVR for eligibility searches are being contacted. Noridian has been offering education sessions for providers to enroll in the NMP.
    1. 3/11: Noridian disabled the eligibility from the IVR on March 3, 2025. Our call center has received a few calls. Members did not have any comments.
  3. 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. Avery will send a claim example

New Agenda Items

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

  1. Marriage and Family Therapist (MFT)
    1. Topic 1: CAMFT is hearing from providers who call our Legal, Ethical and Business hotline that they are receiving letters from Noridian regarding their Medicare provider status and the need to enroll as a provider. We believe these letters are the result of Medicare beneficiary patients submitting requests for reimbursement for services covered by Medicare. Can you tell us more about these letters and what providers who have not taken action regarding to Medicare are being instructed to do?
      • Are they being required to enroll as Medicare providers?
      • Are they being directed to repay any fees to their Medicare beneficiary patients if they collected fees for services from the Medicare beneficiaries without being opted out?
      • How much time do providers have between becoming aware that they need to enroll as Medicare providers (i.e. should not have been collecting private fees from Medicare beneficiaries if they have not already opted out) and enrolling?
      • Must these providers pay back their patients immediately?
      • Once enrolled, will Noridian only pay claims for services that were rendered to a Medicare beneficiary up to 30 days prior to the provider's enrollment?
      • How many providers have received these letters since MFTs and MHCs became eligible Medicare providers in 2024?
      • Could Noridian perhaps do a training for providers who find themselves in this situation so that they know all of the steps that they need to take in order to "right the ship" so to speak?
      • CAMFT continues to put information about MFTs' Medicare eligibility in our newsletters, magazine, social media posts, etc. to get the word out.
        • 03/11/2025: Noridian has received questions regarding Licensed Associate Counselors (LAC) and billing their services incident to Licensed Clinical Social Worker (LCSW), MFT or MHC provider types. These provider types are not eligible to be a supervising provider which would not meet incident to requirements.
        • CMS Marriage and Family Therapists & Mental Health Counselors
        • What Criteria Must MHCs Meet to Enroll in Medicare?
          1. Possess a master's or doctor's degree which qualifies for licensure or certification as a mental health counselor, clinical professional counselor, professional counselor under the State law of the State in which the individual furnishes the services defined as mental health counselor services
          2. Performed at least 2 years or 3,000 hours of post master's degree clinical supervised experience in mental health counseling in an appropriate setting such as a hospital, SNF, private practice, or clinic
          3. Are licensed or certified as a mental health counselor, clinical professional counselor or professional counselor by the State in which you perform services
            • Additionally, addiction counselors and alcohol and drug counselors who meet all the applicable requirements of an MHC may enroll in Medicare as MHCs and bill Medicare for MHC services.
        • §1848(g)(4) - https://www.ssa.gov/OP_Home/ssact/title18/1848.htm
        • CMS Internet Only Manual (IOM) Publication 100-04 Chapter 1 Section 70.8.6.1.A

          70.8.6.1 - Monitoring Claims Submission Violations (Rev. 12909; Issued: 10-24-24; Effective: 11-26-24; Implementation: 11-26-24)

          A. General

          Section 1848(g)(4) of the Social Security Act requires physicians and suppliers to submit claims to Medicare carriers for services furnished on or after September 1, 1990. It also prohibits physicians and suppliers from imposing a charge for completing and submitting a claim. Physicians and suppliers who fail to submit a claim or who impose a charge for completing the claim are subject to sanctions. CMS is responsible for assessing sanctions and monetary penalties for noncompliance.

          Physicians and suppliers are not required to take assignment of Medicare benefits unless they are enrolled in the Medicare Participating Physician and Supplier Program or, in the case of physician services, the Medicare beneficiary is also a recipient of State medical assistance (Medicaid) or the service is otherwise subject to mandatory assignment.
        Noridian response during call: These 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. Topic 2: How many MFTs have applied to be Medicare Fee-For-Service providers to date? How many MFT providers are enrolled as Medicare FFS providers to date? How many MFTs provider applications are pending at this time? How long is it generally taking to process new provider applications? Is there a backlog of provider applications/MFT and/or MHC provider applications?
      • 03/11/2025: 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.
  2. Opportunity to update Noridian Medicare homepage - Demo
    We've identified opportunities based on POEAG member feedback to improve the Noridian Medicare homepage, making it more user-friendly and accessible for individuals utilizing screen readers. Test pages are currently available, and feedback is being solicited from POEAG members to ensure the proposed updates are effective and inclusive.
    Member Question: Was this tested on multiple types of devices?
    Noridian Response: We are currently in the development stage, and yes, this will be tested.
    Member Comment: The only drawback seen right now is the extra click to get to Latest Updates, for example.
    Noridian Response: We have this noted and it may be easier to create a bookmark directly to the pages accessed often.
  3. Request from POEAG to add Document Control Number (DCN) definition table to Direct Data Entry (DDE) User Manual
    The request received action and an update to the DDE User Manual will include the DCN definition table in the April release. Thank you for the suggestion to add the DCN table.

Top five inquiries to Provider Call Center (PCC)

  • Part A
    • Missing or Invalid Code
    • Payment explanation or calculation
    • Contractual obligation not met
    • Incomplete information provided
    • Claim overlap
  • Part B
    • Coding errors or modifiers
    • Missing or invalid codes
    • Medical Necessity
    • 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 April 9-10 - "An Ounce of Prevention"

Registration is now open. Speakers include Provider Outreach and Education from both Part A and B reviewing prevention techniques, vaccines in preventive care, best practices for wellness visits, colorectal cancer screenings, avoiding cost report adjustments, care management, and inpatient rehabilitation. We will also have speakers from Provider Enrollment, DME, CERT, and one of our Medical Directors.

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.

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.

Member Comment: In addition to MFT members, this member also represents, they are being told LPCCs by the Contact Center that they are not eligible; however, that is simply another term.

Noridian Response: This information will be passed along to our call center.

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. General Medicare updates - each quarter, Noridian offers a Quarterly Medicare Updates webinar that may be helpful to meet this request.
  2. Refreshers on utilization of the benefit period webinar
  3. Physical therapy updates - Did the recent webinar address the recent update to the recertification process? Yes, this was addressed, and the webinar recording is available on our website under Education and Outreach > Webinar on Demand Recordings.
  4. Brief revalidation education session

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.

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