POE Advisory Group Details

6/7/2022 Jurisdiction 6 Part A and FQHC POE Advisory Group Meeting Minutes

Meeting Minutes

Meeting Time: 10:00 a.m. to 12:00 p.m. CT

Member Attendees: Todd Bergstrom, Kimberly Bischel, Deloris Di Re, Luci Hendrickson, Cindy Kennedy, Vera Loftin, Sara Luther, Nancy Richman, Lori Sanders

Guest Speaker from CGS: Kathryn Torro

National Government Services Associates: Jean Roberts, Michael Davis, Laura Brown, Allison Hamilton, Kathleen Gates, Michelle Vannatter-Johnson, Christine Janiszcak, Kathy Windler, Charity Bright, Casey Jones, Nathan Kennedy, Paul Root, Linda Mayer, Alicia Forbes

Agenda

  1. Welcome, Introductions, & Approval of Minutes from Previous Meeting
  2. Guest Speaker
  3. Updates
  4. Review of Educational Materials and Suggestions for Additional Education
  5. Open Forum & Suggestions for Education
  6. Upcoming Events  and Additional Information
  7. 2022 Meeting Schedule

I. Welcome, Introductions and Approval of Minutes from Previous Meeting

Jean Roberts, J6 POE Consultant, NGS

Jean welcomed everyone to the meeting and noted that minutes from the previous meeting, on 3/1/2022, were posted to the National Government Services website within 30 business days of that meeting. Minutes from the 3/1/2022 meeting were approved as written.

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II. Guest Speaker

Kathryn Torro, Provider Outreach and Education Sr. Analyst, JB DME MAC, CGS Administrators, LLC

Kathryn provided updates concerning the elimination of CMNs and DIFs as per CMS MLN Matters Special Edition article SE22002. CMS is committed to advancing health equity by understanding and addressing the burdens, disparities, barriers, and challenges people experience in Medicare Fee for Service. One burden that we can eliminate is the submission of forms called CMNs and DIFs; therefore, CMNs and DIFs will no longer be extended and will not be required for any claims with dates of service on or after 1/1/2023. CMS will no longer process claims with a CMN or DIF attached for dates of service on or after 1/1/2023. Suppliers must continue to submit CMN and DIF information for claims with dates of service on or before 12/31/2022 when required to process the claim.

Kathryn also provided some reminders concerning the DMEPOS PA Program. During the March 2022 meeting the DMEPOS PA Program for LLPs, PMDs, and orthoses were discussed. The PA for orthoses includes three phase-in dates applicable to when each DME Jurisdiction will begin PA for orthoses: 4/13/2022, 6/12/2022 and 10/10/2022. Specific codes applicable to the Orthoses PA Program. The following claim types are excluded from any PA program, unless otherwise specified: VA, IHS, MAPs, Part A and Part B Demonstrations and Claims from Representative Payees (Note: Claims from Representative Payees will only be excluded for PA programs that are not implemented on a national level. Once the PA program becomes national, this exclusion will not apply.)  

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III. Updates

Jean Roberts, J6 POE Consultant

Prior Authorization Exemption Process

Michelle Vannatter-Johnson BSN, RN, Clinical Review Nurse Lead - Clinical Operations - Prior Authorization

Michelle reviewed the seven services now applicable to the PA OPD: blepharoplasty, botulinum toxin injections, panniculectomy, rhinoplasty, vein ablation, cervical fusion with discectomy and implantation of spinal neurostimulators and discussed the exemption process. On August 1, current exempt providers will receive ADR for 10 post-pay claims; the provider has 45 days to submit the applicable records and NGS has 45 days to review the records. On November 2, a notice of continuation of the exemption or a withdrawal from exemption will be issued and providers may also request to opt-out. On December 18, withdrawn providers may begin submitting PARs for DOS on/after 1/1/2023. On 1/1/2023: Approved exempt providers continue on the 2023 exemption cycle. Also on 1/1/2023: Providers withdrawn from exemption, providers who did not achieve a 90% PAR affirmation rate, or providers who opted-out of exemption submit PARs for applicable services. She also discussed how to qualify for the 2023 exemption cycle.

There are instances when the documentation we receive is missing key elements to support payment. When time allows, NGS makes every effort to reach out to the provider and allow for the submission of additional documentation; however, due to time constraints, there is no guarantee that we will call for additional documentation and we cannot accept late submissions. Check your submission against the ADR to make sure you have included everything to support payment of that claim. In addition, we ask that you submit the ADR letter with the claim so we can ensure the information gets routed to the appropriate place and processed correctly and timely. Michelle noted some keys to success: Provide NGS with an appropriate contact person for additional questions, monitor mail locations - know and monitor where the letter is being sent to and look for the pink envelope; ensure timely responses (45 days for initial submissions and NGS allows a 48 hour turnaround time if and when we make contact for additional records for additional requests); submit all requested documentation, include a completed ADR cover sheet for each claim and separate each submission and ensure you provide the correct service, correct date of service, and correct beneficiary.

Michelle encouraged member to register/attend an upcoming webinar on the PA Exemption Process that will occur on 6/22/2022. For additional information on the PA Exemption Process and timeline, refer to the NGS website > Resources > Medicare Compliance > Prior Authorization > Exemption Process.

Medical Review and Case Management Update

Alison Hamilton, RN, Clinical Review Nurse Senior

Alison stated that the TPE is a strategy designed to educate providers and reduce future denials.  There are 2 informative resources that would be beneficial to review:

Providers selected for TPE will receive a notification letter enclosed in a pink envelope containing information about the upcoming review and ADRs will distributed for the specific claims selected for review. Please ensure you are communicating with your team and/or mail department to ensure the ADRs are routed to the appropriate person(s) to allow for timely response. To avoid preventable denials please be sure to designate a specific individual as your facility’s point of contact. To improve the effectiveness and efficiency of your time in the TPE Process be sure to provide valid contact information to NGS upon receiving a notification letter by emailing the Case Management email box identified in the letter. Also, ensure that medical records are submitted promptly upon request; ADRs must be responded to prior to the 45 day deadline (based on the date on the ADR) for each claim selected. Another tip is to double check your submission to ensure that all the required documents are included for all applicable for all dates of service and if there is any concern as to whether the signatures are legible you are encouraged to include a signature log.

Allison noted that you have the ability to respond to Medical Review ADRs quickly and securely by submitting your supporting documentation electronically via NGSConnex. If you have not yet registered for NGSConnex, you can visit the NGS website and click 'Create Account’ to register today. The NGSConnex User Guide has step- by-step instructions on use of the portal and video tutorials are available to you on the NGS YouTube channel.

NGS encourages providers to contact the Case Management Team upon receipt of their results letter to sign up for one-on-one provider education. During this individualized education session, we will discuss claims/denials you have received, as well as answer any questions your facility may have regarding the policy or the TPE process. Do note that the educational sessions are not a forum to appeal nor do the result letters and/or the educational sessions extend the appeal period (120 days). If you choose not to reach out for education within 2 weeks of the date of this letter, this will be tracked as a refused offer.

  • When requesting education, include the following in your request: Subject line “Request for Education - Case folder ID MRP0000XXXXXXX regarding edit-5XXX1 (2) (3) for provider number- XXXXXX.” In the body of the email, please include contact name, telephone number where the listed contact can be reached, email, fax number.
  • Reminder: Do not send PHI or PII.

Allison noted that the NGS Case Management Team is available should you have any questions or concerns related to Medical Reviews and/or Comparative Billing Reports:

  • Jurisdiction K: JKACaseManagement@anthem.com
  • Jurisdiction 6: J6ACaseManagement@anthem.com

Part A CERT and Provider Enrollment Updates

Laura Brown, NGS J6 POE Consultant

CERT Update

Laura updated attendees on the current status of CERT reviews for the November 2022 reporting period, for claims received from 7/1/2020 through 6/30/2021. The CERT error rate fluctuates until the reporting period ends in November of each year. NGS continues to work with providers submit appeals when applicable. The current top CERT errors identified include:

  • Incorrect coding is currently the top error – example: the discharge status code was incorrect
  • Insufficient documentation – example: incomplete physician’s certification, recertification
  • Not Medically Necessary – example: an inpatient admission was determined to not medically necessary and the invasive procedure should have been billed as an outpatient procedure

Laura noted that the CERT Documentation Contractor has moved – the new address is:

  • CERT Documentation Center
    Attn: CID
    8701 Park Central Drive, Suite 400-A
    Richmond, VA 23227

Laura also provided several resources on CERT:Laura also provided several resources on CERT:

  • CERT Provider Website
  • NGS website
    • CERT Alerts:Resources > Medicare Compliance > Comprehensive Error Rate Testing > CERT Alerts
    • CERT Task Force: Resources > Medicare Compliance > Comprehensive Error Rate Testing > (Under Helpful Resources) CERT Task Force
  • Related Links: CMS View all Fast Facts

Provider Enrollment Update

Laura stated that 42 Code of Federal Regulations Section 424.515(b) requires that a provider/supplier must submit a CMS-855 application with complete information for revalidation by the due date. Upon receipt of the application, the requirement of submission is met by an acknowledgement email to the contact identified on the application with the case number. The provider/supplier shall follow the status of the application to respond to additional information requested, if needed. When processing is complete, the contact will receive an approval or approval recommendation letter via mail, fax or email.

Several common provider enrollment issues resulting in the need for an additional development letter include:

Part A Paper Application

  • License/certifications – missing or section not completed
  • Application Fee – the PHE wavier has been lifted and fee is now required for Part A providers on Initial enrollment, a new location and revalidation
  • Completed signature – each new authorized/delegated official must sign and date – If responsible to submit the applications, once submitted via PECOS log back into PECOS within 24 hours and verify signatures are complete
  • Required supporting documents based on application type (Exhibit 177, sales agreement, capitalization, bill of sale) – verify all supporting documents are submitted
  • Required information and/or roles for AO/DO, verify you select the correct role and all relationships that individual has with the group – Page 47 on the CMS-855A has the description of who can be an AO or DO

Part A Web Application

  • Completed Signature
  • Application Fee
  • License/certifications
  • Required information and/or roles for AO/DO
  • Required supporting documents based on application type

Laura provided several Provider Enrollment resources that are available on the NGS website on the Enrollment tab. She also noted a new NGS resource “Medicare Provider Enrollment Application Fee Decision Tree Tool” that will assist you in determining whether you need to pay an application fee, as well as how to pay the application fee, how to submit a hardship request, and how to obtain a refund if you paid an application fee in error. Laura also discussed a separate handout on the CMS Provider Enrollment Systems.

One member questioned whether the CMS Provider Enrollment Systems handout is available the website. Laura responded that it was included in an NGS webinar entitled “Maintaining Your Provider Files” therefore it is available on the past events tab for that session.

NGSConnex Portal Updates

Charity Bright, Program Operations

Charity noted that it has been three months since we transitioned to the new NGSConnex portal and things are going well! We were able to migrate more than 80,000 users to the new portal and we saw approximately 3 million portal transactions in the first 4 weeks. We continue to see increased provider adoption and use of the new portal with lots of positive feedback regarding the ease of use. We have also received some constructive feedback and she thanked the POE AG members as they have been instrumental in our success. She added that if you have feedback or ideas for things you would like to see added please complete the survey available on our site when prompted or you can always use the Feedback button that is available all the time. She noted that prior to the portal cutover on 2/28/22 we had some financials functionality available that was not part of the initial transition to the new portal. Over the last few months we have been updating NGSConnex to add that functionality back as follows:

Part A, FQHC and HHH providers now have the following available:

  • View Outstanding Overpayments and associated demand letters
  • Submitting Credit Balance Reports
  • Added the ability to View Checks and the associated Remittance under Financials

Part B providers now have the following available:

  • View Outstanding Overpayments and associated demand letters
  • We recently added the following:
    • View Checks and the associated Remittance advice
    • View FCN Details and Beneficiary Details

Charity encouraged members to watch for listserv messages as we continue to add new and exciting functionality to the portal. One member inquired as to whether functionality will be added to allow providers to submit credit balance reports in bulk. Charity responded that current you can either enter one credit balance report manually or upload your file into NGSConnex but this is per PTAN. We currently do not has functionality to allow credit balance reporting for more than one PTAN at a time but we can check to determine if this is possible in the future. Another member questioned whether there is any update concerning the ability to complete RTPs in NGSConnex? Charity responded that currently you cannot submit or adjust Part A 1450 claims in NGSConnex; the only claims functionality is a manual process for Part B 1500 claims. That said, NGS is currently working on the ability to respond to claims ADRs as we have received many requests to add that functionality.

Suggestions for the NGSConnex Portal and the NGS website

Michael Davis stated that we are always looking for suggestions for both the website and the portal. If you have any ideas at any time, please do not wait for the POE AG meeting. Simply send an email to Jean and she will get the suggestion to Mike, Charity, and our developers so that we can constantly keep the cycle of innovation working through communication.

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IV. Review of Educational Materials and Suggestions for Additional Education

Jean Roberts, J6 POE Consultant, NGS

POE AG Education Tracking

Jean reviewed the “J6 Part A and FQHC POE AG Education Tracking” document for the 6/7//2022 meeting.

  • Pending: Telehealth post COVID-19 PHE will remain pending until the PHE ends and we have post-PHE telehealth information to share. Jean reminded members that the current Telehealth Services Manual on the Part A section of our website contains only pre-COVID-19 PHE information and will be updated after the end of the PHE once we have any permanent changes to Part A telehealth services.
    • Jean noted that since most PHE updates impact Part B, an excellent Part B update by NGS was conducted on 5/24/2022 via a webinar entitled “The Public Health Emergency and COVID-19 Telehealth Services.”
  • Completed: Information on DOS for clinical laboratory and pathology specimens that is sometimes referred to as the 14 day rule. The CMS website contains this information; therefore, NGS added a hyperlink to the CMS policy on the NGS website > Education > Specialties > Laboratory/Pathology > Laboratory Date of Service Policy
  • Completed: Request for education on the Medicare cost report for FQHCs – both current and future periods. The member was referred to the applicable information.
  • Completed: The article “MSP: Identify the Proper Order of Payers for a Beneficiary's Services” is being revised based one comments after the previous meeting and will be posted to the NGS website.
  • Completed: Education on where Part A and Part B intertwine. NGS conducted “The World of Medicare” during the May 2022 Virtual Conferences

Christine Janiszcak reviewed the current article “Prepare and Submit an MSP Conditional Claim” and noted that a webinar on Conditional Billing will be held in early July 2022. She requested members to provide any comments and suggestions for improving the article.

  • Part A MSP articles are posted on the NGS website > select Part A > Resources > Claims and Appeals > Medicare Secondary Payer (MSP)
  • One member inquired as to whether the same information applies to Part B 1500 claims? Christine noted that we are reviewing a Part A article; however, there is information under Part B for 1500 claims and the article for Part B is similarly titled. The member thanked Christine for this information and will review to confirm they are billing correctly. (For Part B, go to the NGS website > select Part B > Resources > Claims and Appeals > Medicare Secondary Payer (MSP)

Jean discussed the following draft education documents:

  • FQHC Draft article: “Reporting Multiple Qualifying Visits on the Same Date of Service for FQHC Reimbursement” was discussed; however, there were no comments or suggestions.
  • Draft article: “Repetitive Outpatient Services” was discussed; however, there were no comments or suggestions during the meeting.
  • Draft PowerPoint: “Requirements of the SNF ABN CMS-10055 Form” was also discussed; however, no comments or suggestions were received during the meeting.

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V. Open Forum and Suggestions for Education

Jean Roberts, J6 POE Consultant, NGS and ALL

Jean reminded members that a major focus of the POE AG meeting is to gain members feedback and suggestion on educational needs and requested that members provide feedback on anything discussed today as well as any education, topics and/or suggestions that you may have. A member requested information on taxonomy codes for the facility? We are struggling with how to select them. Jean will research this and contact the member later.

Jean noted that the recent Virtual Conference session focused on the basics. NGS will be conducting another Virtual Conference in the fall and we would love to get your suggestions on any topics to be addressed during the fall Virtual Conference. One member requested that the fall session be more advanced than the spring session was and Jean will send that request to the planners. Jean encouraged members to send any additional comments and suggestions to her at any time.

Post Meeting Follow-up:

  1. One member requested information on taxonomy coding. Jean responded that the NUCC maintains the taxonomy code set and that the most current NUCC Health Care Provider Taxonomy Code Set is available. The member previously reviewed that site; however, she needs specific information that explains how an entity chooses a taxonomy code as the primary and in turn how the sub-specialties are determined. For example, a medical group has an NPI and Tax ID with a taxonomy code. Under that lies an NPI and taxonomy code for each address of each clinic. Jean added that there is also the “Medicare Provider and Supplier Taxonomy Crosswalk Data Dictionary” on the CMS website; however, the CMS IOM 100-04, Chapter 1, Section 160.1 - Reporting of Taxonomy Codes (Institutional Providers) seemingly would be the most helpful since it pairs the PTAN/Oscar with the associated taxonomy. Do note that a taxonomy code only designates your classification and specialization; it does not go to the address/location level. The provider found this information helpful.
  2. Another member provided feedback on NGSConnex after the meeting: His staff like the formatting of the old version better with the boxes around sections. When printing the reports in the portrait layout, some of the information gets cut off, such as a termination date in the Crossover Information section. Also, for SNF Days, the report shows 0 for Full and Copay days when there has been no billing for the beneficiary.  Is it possible to have it show 20 Full and 80 Copay days in that situation? Staff members are interpreting the 0 to mean they have no SNF days remaining.
  • NGSConnex staff responded that they will look into updating the print format for eligibility. As far as the SNF copay days, the information displayed in NGSConnex is what is returned from HETS. However, NGS is requesting examples.
  • Please send the MBI, Patient First Name, Last Name and DOB so that research can be completed.

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VI. Upcoming Events and Additional Information

Jean Roberts, J6 POE Consultant, NGS

Jean provided several updates:

  • The CMS Regional Office 5 is conducting "Real Time" with CMS with Chicago and Regional Updates” sessions on the 2nd and 4th Wednesday of every Month at 9 a.m. CT.
  • There will be a CMS National Provider Enrollment Conference in Boston on August 16 and 17. You can register for the conference at the Boston Convention and Exhibition Center and you are encouraged to take advantage of this opportunity to meet with CMS and Medicare Administrative Contractor provider enrollment experts. For additional information and registration visit the CMS website: CMS National Provider Enrollment Conference
  • The 2022 HH+H MAC Collaborative Summit: One Program, One Voice is now available for early bird registration. This huge event is being held live, in-person at the Rio All-Suite Hotel in Las Vegas, Nevada, September 13-15, 2022’
  • Members were reminded of the self-service options available, as well as various manuals and guides that are on the NGS website, as well as the monthly update of the top ten claim errors (RTPs, rejects and denials) that are available on the NGS website.

  • Medicare Covers Over-the-Counter COVID-19 Tests: Medicare has a new initiative that will cover up to eight over-the-counter COVID-19 tests each calendar month, at no cost, until the PHE ends. The Fact Sheet contains a list of questions to help you talk to your Medicare patients. Medicare enrolled providers and suppliers, excluding DME suppliers, may participate in the OTC test demonstration.

Jean discussed several upcoming NGS educational events, and provided additional resources. She encouraged all members to obtain the most current list of education being offered by going to the NGS website > Events and to help promote upcoming educational events.

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VII. 2022 Meeting Schedule

Jean thanked everyone for attending today and noted the next J6 part A POE AG meeting will be on 9/6/2022.

Part A Time
Tuesday, 9/6/2022 10:00 a.m. to 12:00 p.m. CT
11:00 a.m. to 1:00 p.m. ET
Tuesday, 12/6/2022 10:00 a.m. to 12:00 p.m. CT
11:00 a.m. to 1:00 p.m. ET


Note: All meetings are via webinar.

Meeting adjourned

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