Provider Outreach and Education Advisory Group (POE AG) Meeting Minutes - December 10, 2024

POEAG Member and Noridian Attendees

JE

Angela Amey, Avery Malate, Becky Clearwater, Candice Kahue-Antone, Cathy Atkins, Cheryl Bradley, Gloria Beazley, Luci Hendrickson, Mitchel Kaye, Rob Sikorski, Sara Jasper, Stacey Singer, Susan LaPadula, Tameka Island, Valene O'Donnell, and Wendy Alfaro

JF

Anna Gauslow, Carol Self, Dawn Davidson, Jana Weis, Lisa Beyer, Lisa Davies, Mindy Gale, Mollie Brooks, Sarah Luther, and Susan Albaitis

Noridian Attendees

Teresa Cirelli, Cheryl Hanson, Dani Aasen, Jan Ervin, Kim Brantley Phillips, Lori Weber, Miriam Ocampo-Funderburk, Tim Morrissey, Val Cavett, Heidi Klein, Jennifer Joyce, Julie Schroeder, Kathryn Grueneich, Sue Bennett-Coyne, Emily Salvatore, Daylann Robertson, Gretchen Kirklewski, Erica Westbrock, Tammy Urness, Tracy Farahmand, Tracy Schutt, Kate Petersen, Marci Eckroth, Alicia Mahle, Angie Griffin

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. 9/13/2022: Evaluation and Management (E/M) translation of 'prescription drug management' meaning for the 2023 guidelines.
    1. People are getting hung up 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.
      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?
    2. 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.
      1. 12/13: POE is working with Medical Directors for educational opportunities.
      2. 03/14: POE is working with our Medical Directors to see how we can put together this educational opportunity. It may be an opportunity to put together another webinar or an article and include the Prescription Drug Management.
      3. 06/13: Draft article continues to be discussed with Medical Directors. We are looking at ways to incorporate POEAG member suggestions:
        1. Providers are looking for specific documentation requirements. Compliance staff find a challenge educating clinical staff without specific documentation guidance. Other MACs have posted specific documentation requirements.
        2. Internally, staff is looking for the condition requiring medication management.
        3. Members requested including scenarios that would not support medication management. Example: provider refilling medication that is more preventive and the provider is not managing a condition. Medicare is based on lab results.
        4. In the spirit of burden reduction and documenting less, providing documentation guidance for prescription management would benefit providers.
      4. 09/12: Active discussions have taken place and a final draft version is not ready currently. We will have something soon to share.
      5. 12/12: Active discussions have taken place and a final draft version is not ready currently. We will have something soon to share.
      6. 09-10: Draft article shared.
      7. 11/8/24: Published to website - item will now be closed.
  2. 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
      1. 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.
      2. 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.
      3. 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: Remains an open item without guidance at this time.
  3. 9/10/24: Skilled Nursing Facility (SNF) education requests
    1. Skilled Nursing Facilities SNFs are requesting a Comprehensive Medicare Denial Letter class specific to Part A and Part B within the SNF. They seek comprehensive samples of the current CMS versions of these letters, along with detailed explanations of the purpose, timing, and required content that must be presented to the Medicare Beneficiary or Responsible Party in a timely manner.
    2. Provide information on Appointment of Representative options and statutory guidelines for a beneficiary unable to sign the notice. Kindly include links for students to the CMS websites displaying the current full letters. In the SNF setting, multiple CMS denial letters are utilized, each supported by CMS regulations.
      1. A "deeper dive with comprehensive content coverage" would be greatly appreciated. This is an important subject for both Beneficiaries and Provider's Liability. Therefore, we recommend focusing solely on this subject matter in one training for attendees and students of Skilled Nursing Facilities SNFs.
      Noridian response: We will work to create a presentation including all SNF notification for Part A and Part B.
    3. 12/10: Additional questions regarding SNF Education and Certification
      1. Would Noridian Medicare consider addressing Provider Outreach and Education Training for Skilled Nursing Facilities and other Providers regarding debt collection practices? This also ties into the September 2022 Joint Letter from CMS and CFPB. The Consumer Financial Protection Bureau CFPB issued an advisory opinion on Oct. 1, 2024, warning debt collectors — including third-party revenue cycle management companies — that they are violating federal law when they collect on inaccurate or invalid medical debts.
      2. CMS announced that all skilled nursing facility (SNF) providers will receive off-cycle provider enrollment revalidation notices from their Medicare Administrative Contractor (MAC) starting in October 2024 through December 2024.
        1. The notices aim to collect additional data on ownership, managerial, and related party information not previously required. This information is to be submitted in a new Appendix on the revised Form CMS-855A (September 2024 version).
        Noridian response: Noridian's provider enrollment team has been providing education on the requirements of recertification. CMS requests all questions to be directed to their email address.
      3. Due to disaster declarations, CMS will be extending the revalidation due dates for all SNFs in Florida, Georgia, South Carolina, North Carolina and Tennessee until May 1, 2025.
      4. The agency released updated guidance on Friday, October 11 with an email address so providers can ask questions directly (SNFDisclosures@cms.hhs.gov).
      5. In October, CMS updated sub-regulatory guidance so that fewer people have to report personal identifiable information, such as social security numbers and dates of birth.

New Agenda Items

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

  1. Opportunity to update Noridian Medicare homepage
    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 internally to ensure the proposed updates are effective and inclusive. We'll be launching a focus group to identify further accessibility improvements and other areas for enhancement. If you're interested in being part of a focus group, please let us know and your contact information will be forwarded to the appropriate team members working on these projects.
  2. Patient Eligibility Through Noridian Medicare Portal
    CMS directs 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.

    Information was posted on our website on October 3, 2024: Disable Beneficiary Eligibility Information from MAC IVR Systems
  3. Top five inquiries to Provider Call Center (PCC)
    1. Part A
      1. Missing or Invalid Code
      2. Payment explanation or calculation
      3. Contractual obligation not met
      4. Coding errors or modifiers
      5. Incomplete information provided
    2. Part B
      1. Coding errors or modifiers
      2. IVR or NMP referral
      3. Missing or invalid codes
      4. MSP
      5. 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

Virtual Two-day Symposium Coming in March

Watch for information to be posted soon.

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.

Dates will be posted soon.
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 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.

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.

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