Event Summary

J6/JK Ask the Contractor Summary – September 14, 2021

 Event Summary

On 09/14/2021, the NGS J6 and JK Part A POE team conducted the ACT via webinar for our Part A and FQHC providers. Please note that NGS conducts separate ACT calls for our Part B providers as well as for our Home Health and Hospice providers. If you are a Part B, Home Health, or Hospice, provider please check the Events section of our website for education and ACT calls specific to your LOB.

The purpose of the ACT is to provide a way for providers to ask their MAC specific questions about Medicare billing, policies and/or or procedures. In addition, it is an opportunity to share updates, listen to our provider community, and relay the importance of keeping up to date with guidance from CMS. The target audience for ACT sessions includes staff members from all provider types who handle Medicare Part A or FQHC facilities. All Part A and FQHC NGS providers may attend this session, as the information and resources available will largely apply to providers in JK and J6. The ACT serves as a venue for our providers to ask questions and discuss any issues that are of concern to them; therefore, we always encourage providers to presubmit their questions to NGS at least 1 week prior to the event. NGS did not receive any presubmitted questions for this Act call. Providers are strongly encouraged to presubmit questions to ensure that the question is researched prior to the session and a final answer provided during the session.

During the introductory portion of this session, we reviewed the following topics of interest with the participants:

New NGSMedicare.com Walkthrough and Open Q&A Webinars

The redesigned provider content website, NGSMedicare.com, was recently released and provides an easier and more intuitive look and feel to all of the website content.

We are conducting webinars for our providers to attend to gain an overview of the new provider content website and ask any questions. We encourage our providers to sign up for one of the webinars to learn about the new provider content website. A partial list of session dates, listed in Eastern Time, was provided to attendees.

NGS created the NGSMedicare Crosswalk Reference  that compares our existing website to the upcoming new website. The crosswalk was also provided as a handout during the session.

Think Green, Go paperless! Protect Your Bottom Line!                                                  

Reminders about electronic services that are available on our website as well as what NGS is doing to educate providers to think green and go paperless to protect your bottom line were discussed. It was noted that Medicare has been in existence since 1966, serving 27 million people with Medicare, as well as 440,000 providers, 50 Medicare Partners, and 240 members of Congress in 20 states and 5 U.S. territories. NGS is a Medicare Administrative Contractor (MAC) with responsibility in nearly every state via the Jurisdiction 6 and K contracts.

  • Jurisdiction K (JK) MAC includes A/B providers in 7 states as well as providers in 7 states for FQHC and RHC providers, and Home Health & Hospice (HHH) providers in 6 states.

  • Jurisdiction 6 (J6) MAC includes A/B providers in 3 states as well as providers in 44 states for FQHC and 3 states for RHC providers, as well as providers in 13 states for HHH.

The NGS POE Think Green, Go Paperless Campaign Goals include:

  • Bring more awareness to NGS JK and J6 Medicare providers about ‘Go Paperless’ services

  • Work with NGS Incoming Mail Service, Provider Contact Center, and operations for top reasons providers send unnecessary paper

  • Identify any barriers from each line of business regarding hesitancy on adding ‘Go Paperless’ services into facilities and practices

  • Track current and future ‘Go Paperless’ rates to determine campaign success

  • Review current guidance for ‘Go Paperless’ solutions and incentives

NGS supports the CMS Paper Reduction Efforts and the Think Green, Go Paperless Campaign by

  • Conducting meetings with NGS POE and other departments, CMS Regional Offices and provider key stakeholders best approach

  • Creating line of business messages and education on a monthly basis. i.e., EDI Monthly Bulletin

  • Utilizing all NGS education channels: webinar, ACT, Email Update message, social media tools, remit advice and envelope, Medicare BLAST – ARCADE and any outgoing mail opportunities 

  • Tracking success of the ‘Go Paperless’ campaign by data analysis and surveys

  • Possible submission of a CMS Innovation Paper

  • NGS will conduct up to 20 different activities in support of the effort

Please submit any questions or suggestions via email to:

Provider-Based (PBD) Outpatient Reminders

Provider-based outpatient facility billing reminders were provided. The PO and/or PN modifiers are required to be added to claims for services provided in applicable outpatient off-campus provider based locations.

  • The PO  modifier is used to identify services, procedures, and/or surgeries provided at off-campus provider based outpatient department for all excepted items and services furnished

  • The PN modifier is used to identify nonexcepted service provided at an off-campus, outpatient, provider-based department of a hospital 

The CMS article SE18002 “Billing Requirements for OPPS Providers with Multiple Service Locations” is a great tool and includes several examples that all outpatient hospitals subject to the OPPS provider-based outpatient facility billing requirements should review in detail.

The NGS article “Provider Action To Be Taken Following the Provider-Based Mid-Build Audit” refers to  a recent audit that included letters to applicable facilities about PBD that received either an approval letter concerning whether the location should bill with the PO modifier – versus those who received a disapproval letter and should be billing with a PN modifier. Providers were encouraged to review the article, as there are specific actions – claim adjustments - that may need to be completed. All applicable facilities should also submit written confirmation to NGS of your self-assessments.

COVID-19 Related Articles

The COVID-19 Public Health Emergency (PHE) was extended on 07/19/2021 for an additional 3 months. The following articles/websites were provided:

Save The Date!

NGS Provider Outreach and Education will be holding our latest bi-annual virtual conference on Tuesday, 11/9/2021, and Wednesday, 11/10/2021. This two full-day virtual conference will offer a variety of Part A, Part B, FQHC-RHC and self-service sessions. There are no associated charges for the virtual conferences and you may register for as many sessions as you would like! Each session will begin with a presentation and then we will address any questions you may have on the topic of the session. Stay tuned for future notices regarding registration and topics that will be presented during this event.

Upcoming Fundamentals of Medicare Two Part Series

On 09/29/2021, we will be conducting the “Fundamentals of Medicare – Part 1” webinar and one week later, on 10/06/2021, we will conduct the “Fundamentals of Medicare – Part 2” webinar. The Fundamentals sessions are a great first step to prepare for the upcoming Virtual Conferences. Registration is currently available on our website.

NGS Medical Review Announcement

Effective 9/1/2021, NGS Medical Review discontinued sending postpayment additional development requests (ADRs) and is resuming reviews conducted under the targeted probe and educate strategy. Providers should continue responding to postpayment ADR requests already issued. For a refresher on targeted probe and educate please review the National Government Services Part A Medical Review Newsletter September 2021.

Question and Answer Summary

  1. What charges can an FQHC provider bill to Part B? For examples can home health certs, labs, and EKGs. Does it matter if qualifying visit done on same day? In addition, what if there is no qualifying visit?

    The inquirer was requested to attend an NGS FQHC webinar that was to be conducted later on 9/14/20221 that covered all of the coverage and billing rules.

    Certain services are not considered FQHC services because they are not included in the FQHC benefit. Depending on the service provided, FQHCs may be instructed to bill Part B or another insurer/Medicare contractor. An article posted on our website contains the instructions and guidelines on which services are not covered under the Part A PPS reimbursement system, and how to address those claims. Billing for Services Not Included in the FQHC Benefit​​​​​​​

  2. NGS customer service reps are not able to tell providers if Medicare was opened retroactively for a member. They also will not tell a provider when it was opened. Relying on patients to provide that information makes it very difficult for providers. Why can’t the reps provide this information?

    When a Medicare beneficiary is retroactively entitled to Medicare, the Social Security Administration (SSA) Office handles the process, as well as beneficiary notification. Thus, the Medicare beneficiary should receive notification, typically via letter, from SSA with the retroactive entitlement information. The NGS provider call center representatives are restricted as to what type of information can be provided. CMS requires providers to use self-services technology whenever possible to obtain information that is readily available in those tools. Since the NGS self-service tools include Eligibility and Entitlement information, the provider is required to use self-service to obtain such information rather than calling the Provider Contact Center.

  3. Does Medicare Part A pay for outpatient services for a critical access hospital (CAH)?

    Yes, a CAH bills facility services to NGS Part A on a 1450, or electronic equivalent, claim. Please refer to the CMS Internet-Only Manual (IOM) 100-04, Medicare Claims Processing Manual, Chapter 4, beginning with Section 250 for additional information on CAHs.

  1. Is it true that for an FQHC Medicare does not cover the same date for a telehealth visit for a medical reason and a behavioral health issue?

    In general, when there is both a medical visit and a behavioral health visit on the same day of service you report both encounters on the Medicare claim and receive PPS reimbursement for each of those encounters.

    FQHCs are not authorized to serve as a distant site (where the practitioner is during the time of the telehealth service) for telehealth consultations, except during the COVID-19 public health emergency (PHE). Per the CMS COVID-19 Frequently Asked Questions (FAQs) on Medicare Fee-for-Service (FFS) Billing, Section M. Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs), QA 6 & 7: A medical visit and a mental health visit can be furnished on the same day as distant site telehealth services for the duration of the COVID-19 PHE. Distant site Telehealth services should be billed with HCPCS code G2025 and the appropriate revenue code, 052X for a medical visit or 0900 for mental health. Refer to CMS SE20016 “New & Expanded Flexibilities for RHCs & FQHCs during the COVID-19 PHE” for additional details.

  2. Will Medicare pay an FQHC for a CSW providing Behavioral health services?

    Answer: CSWs are listed as a qualified provider to provide face-to-face encounters with a patient to provide behavioral health services.

    Refer to the CMS IOM Publication 100-02, Medicare Benefit Policy Manual, Chapter 13, Section150 – “Clinical Psychologist (CP) and Clinical Social Worker (CSW) Services” for additional information.

  3. What is your understanding of not requiring 3-day stay for a SNF?

    Typically, CMS requires a 3-day qualifying inpatient hospital stay prior to a SNF inpatient stay. The 3-day inpatient stay requirement does not include any outpatient services or observation time.                

    During the PHE, per CMS Special Edition article SE20011 (refer to the hyperlink provided earlier), CMS is waiving the requirement for a 3-day prior hospitalization for coverage of a SNF stay, which provides temporary emergency coverage of SNF services without a qualifying hospital stay, for those people who experience dislocations, or are otherwise affected by COVID-19. In addition, for certain patients who exhausted their SNF benefits, the waiver authorizes renewed SNF coverage without first having to start a new benefit period. Note that this waiver will apply only for those patients who have been delayed or prevented by the emergency itself from commencing or completing the process of ending their up-to-date benefit period and renewing their SNF benefits that would have occurred under normal circumstances.

    ​​​​​​​SE20011 provides additional waiver information in the section “SNF Qualifying Hospital Stay (QHS) and Benefit Period Waivers - Provider Information”. CMS recognizes that disruptions arising from a PHE can affect coverage under the SNF benefit thus the waivers also address when the PHE causes a disruption concerning the process of ending the patient’s current benefit period and renewing their benefits. Please refer to the CMS article SE20011 for additional details.

Posted 9/30/2021