Category: Technology

In effect since January 1 of this year, recent studies are showing low compliance with meeting all aspects of the Health Care Price Transparency Act. JAMA Internal Medicine published an article in June that showed 75 percent of the 100 top-grossing hospitals didn’t comply with at least one of the rule’s requirements while 86 percent had a price estimator tool. Fifty percent of 100 randomly sampled hospitals had a price estimator tool and of those 100 hospitals, 83 percent failed to comply with at least one of the rule’s requirements.[1] In another study of 5,288 hospitals, it was found that only 48.5 percent had chargemaster data on their websites with only 138 hospitals having an online price estimator.[2] A study based on bed count and published in HealthAffairs, found 65 percent of the 100 largest hospitals in the U.S. were not in compliance and 12 of the noncompliant hospitals had no files or links to searchable databases.[3]

CMS implements civil monetary penalties for noncompliance

As a result of this widespread noncompliance, the American Hospital Association (AHA) released a Member Advisory regarding noncompliance with the Centers for Medicare & Medicaid Services (CMS) Hospital Price Transparency requirements. In it, they noted that CMS has launched proactive audits of hospital websites and have evaluated complaints presented to CMS by consumers. According to the publication, CMS started with auditing larger acute care hospitals and have now expanded their examination of random hospitals. The first set of warning letters were issued the week of April 19th. However, CMS has indicated that they will not announce the list of hospitals that have received warning letters but will publish the identities of the hospitals that remain non-compliant and receive a monetary penalty if they have not addressed the issues within 90 days.

Number of Hospital Beds	Maximum Annual Civil Monetary Penalty
<30	$109,500
50	$182,500
100	$365,000
200	$730,000
300	$1,095,000
400	$1,460,000
500	$1,825,000
500+	$2,007,500

A Special Edition from the Medicare Learning Network states that CMS is updating the civil monetary penalty amount. The current minimum civil monetary penalty of $300/day would apply to smaller hospitals with less than 30 patient beds. However, for hospitals with more than 30 beds, the penalty will be $10/bed/day, not to exceed a maximum daily dollar amount of $5,500. “Under this proposed approach, for a full calendar year of noncompliance, the minimum total penalty amount would be $109,500 per hospital, and the maximum total penalty amount would be $2,007,500 per hospital.”[4]

Patients and hospitals can submit a complaint to CMS if they believe a hospital doesn’t have the appropriate information posted online. For more information on Hospital Price Transparency, click here. If you have any other questions regarding Hospital Price Transparency, email the hospital price transparency team.

Hospital price transparency requirements

As a reminder, the CMS Hospital Price Transparency rule requires that hospitals publish detailed pricing information online to help consumers make accurate cost comparisons for a range of treatments and procedures. The rule contains two types of price transparency requirements:

1. Hospitals must post their entire array of standard charges online in a machine-readable file that is easily accessible from their public website
2. Hospitals must publish a document listing pricing for 300 specific shoppable healthcare services. Of these 300 items, 70 have been pre-defined by CMS, while the remaining 230 can be selected at the discretion of the hospital.

For both requirements, a range of different price categories must be shown, including gross charges, payer-specific negotiated rates, self-pay discounted rates, and de-identified minimum and maximum negotiated charges. The files also must contain any ancillary charges that are customarily included for the specific shoppable service, such as the costs associated with additional related procedures, tasks, allied services, supplies, or drugs, as well as any professional fees billed separately from the facility bill.

These requirements present challenges when it comes the sheer data mining and payer contract analytics required to deliver on the mandates. A hospital’s payer contract modeling system must be able to accommodate a variety of settlement methodologies by patient type including MS-DRG, APR-DRG, EAPG, ASC Levels, APC packaging, and percent of charge, among others. This means that for a typical hospital with a 10,000-line chargemaster, seven patient types, and 20 payer contracts, over 1.4M calculations are needed to fulfill the mandate. Meeting the regulatory requirements of the Health Care Price Transparency Act could require a hospital to spend an extraordinary amount of time and resources that they might not have. An alternative would be to contract with a partner that could provide the expertise with a cost-effective solution.

PARA HealthCare Analytics can help

PARA HealthCare Analytics, an ParaRev Company, is among the leaders in supporting hospitals in achieving readiness for CMS Price Transparency regulations, which will help consumers make more informed healthcare purchasing decisions. To ensure consumers will be able to browse for healthcare services in the same way they shop for other goods and services online, PARA has developed robust and accurate pricing capabilities for area healthcare consumers. The PARA solution includes a patient-facing estimator that delivers user-friendly, procedure-level estimates reflecting patients’ specific coverage limits and is updated quarterly for the facility with a payer contract system that can accommodate a variety of settlement methodologies.

PARA’s Price Transparency Tool, which uses the actual payer contract language as outlined in the CMS requirements to make those millions of calculations, is the most cost-effective and comprehensive solution on the market today.

To see how this solution would work for your hospital, click here to view a short demo.
And for more detail on the CMS requirements 1 and 2, watch our Becker’s Webinar: Price transparency – clarifying the unknown.

We can help you refine your pricing to improve revenue capture and strengthen margins while remaining competitive in your market. Contact us today to learn more about how we can help your organization prepare for the transparency transformation ahead.

1. Suhas Gondi, BA1,2; Adam L. Beckman, BS1,2; Avery A. Ofoje, BA3; et al., “Early Hospital Compliance With Federal Requirements for Price Transparency,” JAMA Internal Medicine, June 14, 2021.
2. Waqas Haque, MPH, MPhil1; Muzzammil Ahmadzada2; Hassan Allahrakha, BS3; et al, Eman Haque4; David Hsiehchen, MD, “Transparency, Accessibility, and Variability of US Hospital Price Data.,” JAMA Network, May 14, 2021.
3. Morgan Henderson, Morgane C. Mouslim, “Low Compliance from Big Hospitals on CMS’s Hospital Price Transparency Rule” HealthAffairs, March 16, 2021.
4. “CMS Proposes Rule to Increase Price Transparency, Access to Care, Safety & Health Equity” mlnconnects, July 19, 2021.

Related Posts

None found

Background: Federal law is required to prevent “surprise” billing

In 2020, Congress held meetings to determine whether laws should be enacted to prevent the devastating financial obligations imposed on a patient with healthcare insurance who is treated by an out-of-network provider, particularly when the patient did not know or expect that insurance coverage would be limited for that care.

During Congressional hearings, citizens recounted unexpected, and devastating, financial obligations incurred by patients who were transported by out-of-network air ambulance services. According to the Nebraska Department of Insurance, the average air ambulance trip is 52 miles and costs between $12,000 to $25,000 per flight. Since most air ambulance services do not participate as “network” providers with insurers, that portion of the bill that the insurer will not cover becomes a patient liability. The plight of these patients and others convinced Congress that federal law should prevent a “surprise” bill resulting from an uninformed patient owing large sums of money to an out-of-network provider.

“No Surprises Act” is added to the Consolidated Appropriations Act of 2021

The resulting legislation, the “No Surprises Act”, was incorporated into the Consolidated Appropriations Act of 2021, which was signed into law by then-President Trump in late December 2020. The new Federal law limits the ability of both insurers and out-of-network providers to shift a significant financial obligation to the patient/beneficiary, unless that patient is provided with advance written notice of the anticipated amount that the patient will owe, along with information about the patient’s alternatives to out-of-network care. If there is a State law that addresses the same concern, State law takes precedence.

Interim Final Rule recently released

The new law becomes effective on January 1, 2022, and the Office of Personnel Management, along with the Department of Health and Human Services, Labor, and Treasury developed implementing regulations. The first regulations, dubbed “Part 1”, were released on July 1, 2021 in an “Interim Final Rule with Comment Period” (CMS-9909-IFC.)
Stakeholders should pay particular attention to provider obligations arising from the law, including:

• Distributing standard information about patient rights under the No Surprises Act Information must be posted on the provider website, in signage in public areas of the facility, and in a written one-page, double-sided document distributed to insured patients prior to collecting payment from the patient or submitting a claim to the patient’s group health insurer. (A model notice is under development.)
• The “Notice and Consent” requirements of No Surprises Act Out-of-network providers and facilities must obtain the patient’s informed consent to collect out-of-network costs from the patient. The notice requirements include an estimate of the costs the patient will be liable to pay and information about in-network service alternatives. Notices must be available in the 15 most common languages spoken in the provider’s region. (It is not clear whether a provider may simply opt-out of the notice requirement and accept whatever the insurer’s discounted payment rate may be.)
• The method insurer must use to calculate the “Qualifying Payment Amount” for out-of-network services The payment the insurer is obligated to use in calculating provider reimbursement and patient liability for services at an out-of-network provider could be based on that insurer’s median in-network contracted rates with other like providers within the same region, depending on specific circumstances

The second set of implementing regulations, “Part 2”, are expected to be published in coming months relating to dispute resolution and other provisions of the new law.

Additional Resources

To learn more about the No Surprises Act and the regulations implementing the new law, visit the following websites:

• Interim Final Rule, CMS-9909-IFC, published on7-13-21 in the Federal Register
  • Subpart E – Health Care Provider, Health Care Facility, and Air Ambulance Service Provider Requirements
    • 149.410 Balance billing in cases of emergency services.
    • 149.420 Balance billing in cases of non-emergency services performed by nonparticipating providers at certain participating health care facilities.
    • 149.430 Provider and facility disclosure requirements regarding patient protections against balance billing.
    • 149.440 Balance billing in cases of air ambulance services.
    • 149.450 Complaints process for balance billing regarding providers and facilities.
• CMS: “Fact Sheet” on the interim final rule
• The American Hospital Association: concise summary and analysis
• The American Medical Association: high-level summary
• United Healthcare: convenient FAQ-style resource on its website
• No Surprises Campaign (People against Unfair Medical Bills): consumer stories and letters from diverse interests participating in the development of the No Surprises Act

ParaRev can help

An essential component of the “No Surprises Act” is the ability for the provider to deliver pricing transparency to the consumer. Meeting the challenges of pricing transparency demands a systematic approach grounded in empirical evidence and a capable staff implementing proven solutions. ParaRev, a leader in accounts receivable recovery and resolution, can help you execute all steps necessary to comply with the transparency rule and improve patient satisfaction. To see how this solution would work for your hospital, click here to view a short demo.

Contact us today to learn more about how we can help your organization prepare for the pricing transparency requirement that is a critical component of the “No Surprises Act”.

Related Posts

None found

The COVID-19 pandemic continues to cause extreme financial hardship for hospitals, health systems and all providers. Hospital operating margins through October 2020 fell 18.7%[1] while claim denials increased on average by 23 percent in 2020 compared to 2016[2]. These market dynamics make it even more important to stay abreast of regulatory changes regarding COVID-19.
With the pandemic has come increased and frequently changing COVID-19 regulations and guidelines. To help you stay on top of these changes, PARA HealthCare Analytics, a division of Healthcare Financial Resources, continues to update COVID-19 coding and billing information from the Centers for Medicare and Medicaid (CMS) and payers.

What you will find in this important update

• Link to the CDC ICD-10 tool
• Updated information on Remdesivir
• FDA-approved COVID-19 treatment for most adults
• New Medicare Administrative Contractor (MAC) payment link and table for pricing of COVID-19 lab tests
• Updated language for Rural Health Clinics (RHC) and Federally Qualified Health Centers (FQHC) regarding billing of monoclonal antibodies (MAB) and vaccines
• Easier to read sections for condition codes and modifiers
• New information on controlled release and controlled delivery
• Additional coding information related to COVID-19

To read the full Covid-19 coding document, click here.

Keeping it all straight

Staying abreast of the latest COVID-19 coding regulations can be a challenge, and it can be doubly so during the pandemic when resources may be tight. That’s why ParaRev keeps you updated on all the latest COVID-19 coding initiatives. Together, PARA and ParaRev deliver comprehensive revenue cycle services to support accurate coding, clean claims, accounts receivable recovery and resolution services, and timely and appropriate reimbursement. Contact us today to learn more about the many ways we can help your organization.

1. Robert King, “Hospital operating margins down nearly 20% since start of year due to COVID-19, report says,” Fierce Healthcare, Nov, 30, 2020.
2. Jacqueline LaPointe, “Hospital Claim Denials Steadily Rising, Increasing 23% in 2020,” Revenue Cycle Intelligence, Feb 4, 2021.

Related Posts

None found

A health insurance company as prominent as Blue Cross Blue Shield (BCBS), having over 62 million members across all 50 states, provides high potential for revenue generating opportunities for any hospital Central Billing Office (CBO). According to the 2020 census, there are 12.8 million people living in the state of Illinois with 80 percent of that population enrolled with BCBS of Illinois. Based on these statistics, that would suggest that 10.2 million residents in Illinois are enrolled for healthcare coverage through BCBS. In terms of a business perspective on a revenue standpoint, BCBS of Illinois coverage should always be a high focus for any facility solely for the revenue aspect when patients are seen.

Tip 1: Understanding your EDI clearinghouse

All hospitals throughout Illinois should have an intimate understanding of what is required from front-end registration to denial management to streamline revenue as best as possible for this large number of insured individuals with one carrier. BCBS of Illinois requires the use of an insurance web portal or clearinghouse, so it is important to understand the range of products that portal provides. This will help maximize efficiency and avoid unnecessary denials to keep aging clean and healthy for this large volume carrier.

Tip 2: Checking eligibility – the key to clean claims

On a front-end/registration point of view, utilizing running eligibility is a simple starting point to ensure your claims are being sent to the appropriate address. Whether a patient’s coverage is through an Independent Practice Association (IPA), Managed Care Organization (MCO), Labor Fund, Federal or traditional BCBS, checking eligibility is the first step to avoid any unnecessary submissions or claim status inquiry attempts.

Tip 3: Utilizing AIM to help decrease denials

After eligibility is confirmed and the patient’s benefits based on the services have been provided, utilizing the AIM portal within the insurance web portal is another excellent tool for preauthorization purposes. The AIM portal allows you to look up the services a patient is scheduled to receive and verify if that specific CPT® code requires a preauthorization. As a vendor, the most common denials we see with our hospitals are specifically from the clinical denial aspect. This denial category would pertain to no authorization, medical necessity, level of care, and length of stay. With utilizing the AIM portal, this will provide an opportunity to minimize no authorization denials with a simple check if the scheduled services require an authorization or not. If your facility is not aware of this, please reach out to your provider representative to provide you this information. On a medical necessity standpoint, you may also utilize the AIM portal to initiate a peer-to-peer review for level of care or length of stay denials in efforts to overturn these denials received.

Tip 4: Improving follow-up efficiency and accuracy

Follow-up efficiency and accuracy is also important when dealing with this high-volume carrier. With roughly 10.2 million members, traditional BCBS of Illinois receives enormous amounts of calls a day regarding claim status inquires. Using an insurance web portal’s claim status tool for all claim status inquires prior to calling can help reduce unnecessary calls. This tool provides the opportunity to capture all key and necessary information needed to grasp a rough understanding of all claim status inquires. There may be times that the information captured may not be sufficient in terms of a progressive standpoint to verify if recent submitted disputes or documents are under review. Utilizing the CIR, or Claim Inquiry Resolution tool, is another effective way to verify an updated status of documents or disputes submitted, which is provided with a reference number for tracking purposes to ensure all inquiries are answered in a timely manner. Utilizing this tool helps reduce call volumes along with decreased hold times. Not only will this tool assist the efficiency of any CBO staff member but will also help vendors as well.

Tip 5: Understanding contractual reimbursement agreements

Some believe that BCBS pays at 100% of billed charges when in fact that is not the case. Typically, what happens is that it appears payments are paid in full within an Electronic Medical Records (EMR) system but in reality, the contractual adjustment is applied on the back end through the UPP Program. The Uniform Payment Program (UPP) in a sense is the contractual reimbursement solely for BCBS and individual facilities. The UPP discount can range from 25 percent to 70 percent based on services provided or the facility in general. It is encouraged to speak to your provider representative or your internal contract management department if you do not have a clear understanding of the discount BCBS of Illinois has with your facility.

Streamlining BCBS accounts

In conclusion, BCBS of Illinois provides countless opportunities to streamline this book of business with your CBOs and your vendors to help improve efficiencies which in turn will increase your revenue. Accurately utilizing all tools that BCBS and an insurance web portal provide is another opportunity to decrease denial volumes thus reduce aging. Any specific questions you may have, it is highly encouraged to reach out to your provider representative that will allow you to make your CBO and vendors more successful.

ParaRev can help

ParaRev has the expertise in working with BCBS not only in Illinois but across the country.
Our experts have a thorough knowledge of each state’s requirements and can help you with comprehensive revenue cycle services to support accurate coding, clean claims, and timely and appropriate reimbursement. Contact us today to learn more about the many ways we can help your organization.

Related Posts

None found

From flu to tetanus and now COVID-19, vaccines are among the most common outpatient procedures providers administer on a day-to-day basis. But they can also be complex to code and bill, and undetected mistakes can result in continual underpayment for services rendered.

What makes vaccines so tricky? In most instances, coders must consider a range of factors to ensure the procedure is properly coded, and it can be easy to overlook specific details or nuances. This is especially true if multiple injections are given to a single patient during one encounter.

Some of the key variables associated with vaccine coding include:

• Patient age
• Insurance
• Route of administration
• Total number of vaccines given in the same encounter
• Physician counseling
• State vaccines programs

General Vaccine Information

Q-Codes

Vaccine codes are published on a semi-annual basis, typically July 1 and January 1, by the American Medical Association (AMA). Current Procedural Terminology (CPT®) vaccine codes range from 90476 through 90749 with the additional range 91300-91303 added in 2021 to cover the new COVID-19 vaccines. Q-codes are reimbursed at reasonable cost to providers, and Medicare deductible and co-insurance amounts do not apply when the Q-codes are reported to Medicare.

Age-restricted vaccines

While many vaccines don’t have specific age requirements, others can be designated pediatric, adolescent or adult. As a result, it’s important for coders to confirm that the vaccine administered is appropriate for the patient’s age.

Code set administration

In most vaccine billing scenarios, practices will bill separately for the vaccine and the vaccine administration. Administration codes encompass three general categories:

• CPT® range 90471 — 90474 identifies vaccines without Counseling (over 18 years of age)
• CPT® range 90460 — 90461 identifies vaccines with Counseling (thru age 18)
• CPT® range 91300 — 91303 identifies COVID-19 vaccines
• HCPCS Codes G0008, G0009 and G0010 are specific to Medicare beneficiaries

State programs

Some physician practices participate in state-sponsored Vaccines for Children (VFC) programs. Because the state generally provides the practice with the vaccines, physicians may not charge beneficiaries for the vaccines and physicians are not separately reimbursed by Medicaid or commercial carriers.

However, providers may charge patients for the administration fee associated with providing the vaccine. For vaccines provided as part of the VFC program, the CPT® code range is 90476 — 90749, with modifier SL appended in the first reporting modifier field.

Route of administration

Ensuring the correct route of administration allows the coder to select the appropriate administration code. Most vaccines are given as injections and are reported using administration codes 90471 and 90472. But there are a few oral and intra-nasal vaccines that are reported using administration codes 90473 and 90474.

Initial vaccines

If one or more vaccines are administered during an encounter, it is necessary to specify an initial administration code first. Initial administration codes include:

• 90471: Immunization administration for percutaneous, intra-dermal, subcutaneous or intramuscular injections, initial
• 90473: Immunization administration for intra-nasal or oral route, initial

Only one initial administration code is reported per encounter. If both injectable and oral/intra-nasal vaccines are performed during the same visit, providers should report 90471 as the initial administration code. Codes 90471 – 90472 have a slightly higher reimbursement than oral/intra-nasal administration.

Subsequent vaccines

If more than one vaccine is administered on the same day, a second or third administration code is required to document the additional vaccines. All subsequent vaccine codes (90472 and 90474) are classified as add-on codes and must be reported with an initial administration code. The definitions for subsequent administration codes are:

• 90472: Immunization administration for percutaneous, intra-dermal, subcutaneous or intramuscular injections, each additional vaccine
• 90474: Immunization administration for intra-nasal or oral route, each additional vaccine

When three or more vaccines are performed during an encounter, units should be applied to the administration code for each additional vaccine of the same type (injectable or oral).

Here are some examples:

• Five injectable vaccines: report 90471 X1 unit (initial) and 90472 X4 units (subsequent)
• One intra-nasal and two oral vaccines: 90473 X1 unit (initial) and 90474 X2 units (subsequent)
• Four injectable vaccines and one oral vaccine: 90471 X1 unit (initial) and 90472 X3 units (subsequent) and 90474 X1 unit (subsequent)

Product Vaccine Examples

CPT ®Code	Description
90714	Tetanus and diphtheria toxoids, older than 7
90715	Tetanus, diphtheria toxoids, and acellular pertussis vaccine, older than 7 [NOTE: 90715 should be used for Adacel vaccine as this code describes a tetanus and diphtheria booster vaccine for both adult and adolescent use with the age indication for Adacel being 11-64 years of age.

COVID-19 Vaccine Codes

In response to the COVID-19 pandemic, the FDA has approved vaccines by Pfizer (December 11, 2020) Moderna (December 18, 2020) and Johnson & Johnson (Janssen) (February 27, 2021) for use under an EUA. The AMA has also created CPT code set in the likelihood that the AstraZeneca and University of Oxford is granted EAU approval. The administration code will be reported based on whether it is the first or second dose.

Under the CARES Act, Medicare will provide beneficiaries COVID-19 vaccine administration with no cost-sharing to beneficiaries under Part B coverage. Initially, providers will not incur a cost for the drug because products will be distributed through government agencies. Providers should not bill for the drug when they receive it at no cost. The Centers for Medicare & Medicaid Services (CMS) states it will establish COVID-19 drug product allowances, which will be based on reasonable costs (or, for physician offices, 95% of Average Wholesale Prices), later. Per the Medicare Claims Processing Manual Chapter 32 – Billing Requirements for Special Services section 67.2, providers should not bill for drugs received at no cost.

COVID-19 vaccine product codes

Vaccine Code	CPT Long Descriptor	Mfr Vaccine/Procedure	MCR Allowed	Effective Date
91300*	Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19] vaccine, mRNA-LNP, spike protein, preservative free, 20 mcg/0.3mL dosage, diluent reconstituted, for intramuscular use (HFRI-PARA note: Report administration code 0001A or 0002A)	Pfizer-BioNtech Covid-19 Vaccine	$0.01	12/11/2020
91301*	Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-10]) vaccine, mRNA-LNP, spike protein, preservative free, 100 mcg/0.5mL dosage, for intramuscular use (HFRI-PARA note: Report administration code 0011A or 0012A)	Moderna Covid-19 Vaccine	$0.01	12/18/2020
91302*	Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-10]) vaccine, DNA, spoke protein, chimpanzee adenovirus Oxford 1 (ChAdOx1) vector, preservative free, 5×1010 viral particles/0.5mL dosage, for intramuscular use. (HFRI-PARA note: Report administration code 0021A or 0022A)	AstraZeneca Covid-19 Vaccine	$0.01	TBD
91303	Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-10]) vaccine, DNA, spoke protein, adenovirus type 26 (Ad26) vector, preservative free, 5×1010 viral particles/0.5mL dosage, for intramuscular use	Janssen Covid-19 Vaccine	$0.01	2/26/2021

* Initially, providers will not incur a cost for the drug product as they will be distributed through government agencies. Providers should not bill for the drug when they receive it at no cost. CMS will update the payment allowance later.

COVID-19 Vaccine Administration Codes

Effective immediately after the FDA approves vaccinations with an Emergency Use Authorization, providers may report the COVID-19 administration code based on the type of vaccine and which dose is provided.

All providers participating in the CDC COVID-19 Vaccine Program:

• Must provide the vaccine at no cost to the individual (may also balance bill)
• Cannot charge an office visit (or other fees or services) if the individual received only the vaccine
• May not deny vaccine based on insurance coverage or out-of-network status

The Office of the Inspector General encourages reporting potential violations through its tip line 1-800-HHS-TIPS (1-800-447-8477) or website. The following chart shows the vaccine product code with the corresponding administration code(s).

Vaccine and Administrative Codes
Service	Description	Rev Code	Condition(s) Code(s)	Dx Notes	Dosing Info
Pfizer
91300	Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 30 mcg/0.3mL dosage, diluent reconstituted, for intramuscular use (DO NOT REPORT IF PROVIDED FREE OF COST)	0636	A6 – 100% Medicare Payment For patients who have Medicare Advantage Plans, bill services to traditional Medicare and report 78 – New coverage not implemented by Medicare Advantage	Z23 – Encounter for immunization	21 Days
0001A	Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 30 mcg/0.3mL dosage, diluent reconstituted; first dose	0771
0002A	Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative-free, 30 mcg/0.3mL dosage, diluent reconstituted; second dose	0771
Moderna
91301	Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 100 mcg/0.5mL dosage, for intramuscular use (DO NOT REPORT IF PROVIDED FREE OF COST)	0636	A6 – 100% Medicare Payment For patients who have Medicare Advantage Plans, bill services to traditional Medicare and report 78 – New coverage not implemented by Medicare Advantage	Z23 – Encounter for immunization	21 Days
0011A	Immunization administration by intramuscular injection of Severe acute respiratory syndrome coronavirus 2 (SARSCoV-2) (Coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative-free, 100 mcg/0.5mL dosage; first dose	0771
0012A	Immunization administration by intramuscular injection of Severe acute respiratory syndrome coronavirus 2 (SARSCoV-2) (Coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative-free, 100 mcg/0.5mL dosage; second dose	0771
Janssen
91303	Severe acute respiratory syndrome coronavirus 2 (SARSCoV-2) (coronavirus disease [COVID-19]) vaccine, DNA, spike protein, adenovirus type 26 (Ad26) vector, preservative free, 5×1010 viral particles/0.5mL dosage, for intramuscular use (DO NOT REPORT IF PROVIDED FREE OF COST)	0636	A6 – 100% Medicare Payment For patients who have Medicare Advantage Plans, bill services to traditional Medicare and report 78 – New coverage not implemented by Medicare Advantage	Z23 – Encounter for immunization	Single Dose
0031A	Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARSCoV-2) (coronavirus disease [COVID19]) vaccine, DNA, spike protein, adenovirus type 26 (Ad26) vector, preservative free, 5×1010 viral particles/0.5mL dosage, single dose	0771
AstraZeneca (Currently not approved in the United States)
91302	Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, DNA, spike protein, chimpanzee adenovirus Oxford 1 (ChAdOx1) vector, preservative free, 5×1010 viral particles/0.5mL dosage, for intramuscular use (DO NOT REPORT IF PROVIDED FREE OF COST)	0636	A6 – 100% Medicare Payment For patients who have Medicare Advantage Plans, bill services to traditional Medicare and report 78 – New coverage not implemented by Medicare Advantage	Z23 – Encounter for immunization	28 Days
0021A	Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, DNA, spike protein, chimpanzee adenovirus Oxford 1 (ChAdOx1) vector, preservative free, 5×1010 viral particles/0.5mL dosage; first dose	0771
0022A	Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, DNA, spike protein, chimpanzee adenovirus Oxford 1 (ChAdOx1) vector, preservative free, 5×1010 viral particles/0.5mL dosage; second dose	0771
Novavax (Currently not approved in the United States)
91304	Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, recombinant spike protein nanoparticle, saponin-based adjuvant, preservative free, 5 mcg/0.5mL dosage, for intramuscular use (DO NOT REPORT IF PROVIDED FREE OF COST)	0636	A6 – 100% Medicare Payment For patients who have Medicare Advantage Plans, bill services to traditional Medicare and report 78 – New coverage not implemented by Medicare Advantage	Z23 – Encounter for immunization	21 Days
0041A	Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, recombinant spike protein nanoparticle, saponin-based adjuvant, preservative free, 5 mcg/0.5mL dosage; first dose	0771
0042A	I Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]) vaccine, recombinant spike protein nanoparticle, saponin-based adjuvant, preservative free, 5 mcg/0.5mL dosage; second dose	0771

COVID-19 Vaccine Administration Payment Rate Increase

CMS announced on March 15, 2021 that COVID-19 vaccine administration payment rates will increase to $40 each dose (geographically adjusted). The increased rates, which go into effect for dates of service on or after March 15, 2021, are expected to increase the number of vaccines administered daily by helping to establish new or expand current vaccination sites, hire additional staff, and provide community education.

Code	Mfr Vaccine/ Procedure Name	Payment Allowance	Effective Date	Payment Allowance after Date of Service 03/15/2021
0001A	Pfizer BioNtech Covid-19 Vaccine Administration – First Dose	$ 16.94	12/11/2020	$40.00*
0002A	Pfizer BioNtech Covid-19 Vaccine Administration – Second Dose	$ 28.39	12/11/2020	$40.00*
0011A	Moderna Covid-19 Vaccine Administration – First Dose	$ 16.94	12/18/2020	$40.00*
0012A	Moderna Covid-19 Vaccine Administration – Second Dose	$ 28.39	12/18/2020	$40.00*
0031A	Janssen Covid-19 Vaccine Administration	$28.39	02/26/2021	$40.00*
0021A	AstraZeneca Oxford Covid-19 Vaccine Administration – First Dose	$40.00	TBD	TBD
0022A	AstraZeneca Oxford Covid-19 Vaccine Administration – Second Dose	$ 40.00	TBD	TBD
0041A	Novavax Covid-19 Vaccine Administration – First Dose	$40.00	TBD	TBD
0042A	Novavax Covid-19 Vaccine Administration – Second Dose	$40.00	TBD	TBD

Vaccine Administration in the Home

Effective June 8, 2021, Medicare will pay providers currently eligible to bill for COVID-19 vaccine administration (i.e., physicians, pharmacies, non-physician practitioners, and hospitals) an additional $35 per COVID-19 vaccine dose when provided in the patient’s home to a Medicare beneficiary who has is hard-to-reach or has difficulty leaving home. M0201 COVID-19 vaccine home administration may be reported with the COVID-19 administration code when the sole purpose of the healthcare home visit was to administer the vaccine. This add-on payment raises the total provider reimbursement to approximately $75 (which amount includes the $40 reimbursement for the specific vaccine administration.) When a provider administers the COVID-19 vaccine to multiple people in the same home during the same visit, the provider may report M0201 (COVID-19 vaccine home admin) only once but should report all COVID-19 vaccine dose-specific administration codes.

HCPCS	Description	Vaccine/Procedure Name
M0201	COVID-19 vaccine home admin	COVID-19 vaccine administration inside a patient’s home; reported only once per individual home per date of service when only COVID19 vaccine administration is performed at the patient’s home.

RHCs and FQHCs COVID-19 Vaccine Billing

Rural Health Centers (RHCs) and Federally Qualified Health Centers (FQHCs) cannot bill COVID-19 for COVID-19 vaccines on a claim form. If the patient is there for another reason, the RHC or FQHC should exclude the cost of the vaccines. It will be settled on a cost report.

A listing of payment rates by each type of Medicare provider can be found in the Medicare FAQ link.

Medicare Provider	Vaccine Payment	Vaccine Administrative Payment
Hospitals – Outpatient Departments	Reasonable Costs*	Separately payable based on established rate for code. Not subjects to OPPS.
Hospitals – Inpatients	Reasonable Costs*	Separately payable based on established rate for code.
Critical Access Hospitals (CAHs)	101% of Reasonable Costs	101% of Reasonable Costs
Rural Health Centers (RHCs)	Paid through the cost report	Paid through the cost report

Additional Resources

• PARA Healthcare Analytics/ParaRev COVID-19 Coding Resource
• Novitas JH (Medicare MAC) provides billing information for Part B providers.
• First Coast Service Options (Medicare MAC), has a webpage devoted to billing for COVID-19 vaccines and monoclonal antibodies for Part A providers.
• CMS created a resource page to provide COVID-19 vaccine policies and guidance for providers, state programs, and beneficiaries.
• Additional information is available through the following CDC weblink.
• The AMA provides instructions for coding administration of the COVID-19 vaccines through its document.

Keeping it all straight

Staying abreast of the latest coding directives can be a challenge, and it can be doubly so when it comes to vaccines, given all the factors that need to be accounted for to code and bill correctly. That’s why Healthcare Financial Resources Inc. (HFRI) and PARA HealthCare Analytics have partnered to deliver comprehensive revenue cycle services to support accurate coding, clean claims and timely and appropriate reimbursement. Contact us today to learn more about the many ways we can help your organization.

Related Posts

None found

Working with Medi-Cal − California Medicaid − can be quite a challenge at times. Navigating their phone system, waiting on hold, utilizing their website and even manually filling out their specialized forms just to get status on a claim can be a daunting task for representatives. You are not alone! There are some challenges when it comes to Medi-Cal, however, knowing some tips and tricks may help ease your mind when you are faced with this payer.

Medi-Cal Manual Forms can be Challenging

Filling out Medi-Cal manual forms can be difficult to adapt to. There are not one, but two different forms that need to be completed at any given time, depending on the scenario and at what time the request is being submitted.

1. Claims Inquiry Form or CIF: used to request an adjustment for either an underpaid or overpaid claim, request the Share of Cost (SOC) reimbursement or request a reconsideration of a denied claim.
2. Appeal Form or 90-1: used when all other avenues have been exhausted and an attempt to overturn a denial is being filed.

How do I obtain the CIF and 90-1 forms?

To obtain the CIF and 90-1 forms contact Medi-Cal directly with the provider NPI number and the shipping address of where the forms should be sent. These forms come in boxes of 1,200 each and will also need envelopes to go with them. Once the order is placed, allow 10 days to ship. Make sure you order in plenty of time so as you do not run out!

Completing the Claims Inquiry Form

There are 17 areas on the form that needs to be completed. The form allows entering up to four patients on one form at a time. Information needed will be:

• Patient name
• Medi-Cal ID number
• Claim number
• Date of service
• Denied code
• Amount billed

Box 16 allows the break down what is needed, such as: “Line 1, Line 2, etc.”

Completing the 90-1 Appeal Form

There are 15 areas on the 90-1 form that requires completion prior to submission. This form can only be completed for one patient at a time, but for up to 14-line items that have denied or have different dates of services. Information needed will be:

• Patient name
• Medi-Cal ID number
• Claim number
• Date of service
• Remittance Advice Details (RAD) or Explanation of Benefits (EOB)/Remittance Advice (RA) Code
• Remittance Advice (RA) and Remittance Advice Details (RAD)

Another Complication

Another complication in completing CIF and 90-1 forms is they must be hand-written. This can not only be tiring for the person completing the forms, but the process takes longer and can be difficult to read depending upon the persons handwriting. But is there a better alternative?

ParaRev can Help with Completing Medi-Cal Forms

ParaRev has developed a process to eliminate the necessity of hand-writing CIF and 90-1 forms. Utilizing a mail merge process allows each individual staff member to complete an Excel sheet with the requested/required information. This Excel document is transmitted to the dedicated ParaRev mailing team who takes the provided data and transfers it onto the form. The benefit to this process is that the forms are legible, cannot be smudged, have a reduced chance for spelling errors and no one’s hand gets cramped!

Your AR specialists

ParaRev specializes in accounts receivable recovery and resolution and serves as a virtual extension of your hospital central billing office to help you quickly resolve and collect more of your insurance accounts receivable.

We utilize proprietary intelligent automation and staff specialization to efficiently process all claims regardless of size or age. In addition to our resolution capabilities, ParaRev also can provide denial management assistance by conducting root cause analysis and recommend process improvements to help decrease aged and denied claims going forward.

Contact ParaRev today to learn more about how we can help you with your hospital’s accounts receivable management.

Related Posts

None found

Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna

What is the Protecting Access to Medicare Act of 2014 (PAMA)?

The PAMA law brought a wide variety of changes to Medicare, including the method by which Medicare will calculate the rates it will pay under the Clinical Lab Fee Schedule (CLFS). It requires Medicare to pay according to the weighted median rate of payments made by private insurers for the same lab test. This means Medicare must collect data from laboratory providers every three years in order to calculate the appropriate rate of payment.

Medicare collected data for the first time in 2017 but required only large regional and national laboratories to report. The weighted median payment rates from that limited data pool resulted in dramatically lower reimbursement on the majority of lab tests. Laboratory providers complained that the rates were inaccurate and inappropriately low, in part because the data used was from less than 1% of laboratory providers nationwide. In response to those concerns, Medicare added hospitals and physician practices to the list of entities required to report (“applicable laboratories”), beginning with the data collection period January 1, 2019, through June 30, 2019.

Lab providers, including some physician clinics and certain hospital outreach laboratories that perform specimen-only lab testing on the 14x Type of Bill (TOB), must report rates and volumes of payments received from commercial payors for lab tests between January 1 and June 30, 2019. The reporting window was originally scheduled for the first quarter of 2020, but has been delayed two years to the first quarter of 2022. Failure to report could result in fines of more than $10,000 per day.

The new mandate marks the second time Medicare has collected private payor lab rate payment data, but it’s the first time the requirement has been extended to hospitals that bill Medicare and other payors on the 14x TOB. Their initial effort in 2016 required that only large national and regional lab testing firms, such as LabCorp and Quest, report. CMS must collect private payor data every three years for use in setting rates under the CLFS.

The 2019 Outpatient Prospective Payment System (OPPS) Final Rule expanded the reporting obligation to include hospital outreach laboratories that submit Medicare claims for non-patient services if the hospital met the threshold of $12,500 in revenues paid by Medicare for services on the 14x TOB during the first six months of 2019. The rate reporting is due to CMS by the end of the first quarter of 2022.

Which hospital laboratories will be required to report lab payment rates?

According to CMS, “applicable laboratories” are required to collect and report private-payor, non-patient service lab rates. An applicable laboratory is: [1]

1. A lab that bills Medicare Part B under its own National Provider Identifier (NPI); or, for hospital outreach laboratories, bills Medicare Part B on the Form CMS-1450 under type of bill (TOB) 14x; and
2. A lab that meets the “majority of Medicare revenues” threshold (that is, receives more than 50 percent of its Medicare revenues from one or a combination of the CLFS or the Physician Fee Schedule (PFS) in a data collection period; and
3. A lab that meets or exceeds the low expenditure threshold (that is, it receives at least $12,500 of its Medicare revenues from the CLFS in a data collection period).

Since test questions 1 through 3 are typically met by hospitals that perform non-patient lab testing, the main determinant of the obligation to report is the $12,500 threshold.

Medicare acknowledges that most hospital labs will meet the Majority of Medicare revenues test:
“Hospital outreach laboratories that bill Medicare Part B under the hospital’s NPI, and therefore determine applicable laboratory status based on its Medicare revenues from the 14x TOB, will most likely meet the majority of Medicare revenues threshold. They will most likely meet the majority of Medicare revenues threshold because their Medicare revenues are primarily, if not entirely, derived from the CLFS and or PFS. In other words, the revenues from the CLFS and or PFS services included in the numerator are essentially the same as the total Medicare revenues included in the denominator.”[2]

While the UB manual specifies that 14x TOB is for non-patient lab tests, California Medicaid (Medi-Cal) requires emergency department charges (ED) to be reported on the 14x type of bill. Hospitals in California, therefore, will need to report specimen-only testing claims and exclude claims for in-person medical services, such as ED charges, to ensure they’re only reporting non-patient lab charges.

Some physician offices that provide laboratory services will need to report if they have $12,500 or more in Medicare revenue for all clinical services, even though they bill on a CMS1500/837i claim form. Reporting for physician offices should nonetheless be relatively straightforward, since, unlike hospitals, they post by line-item in the patient accounting system.

What changes have been made in 2021 regarding PAMA?

The reporting timetable has been updated in response to the COVID-19 pandemic. Data collected from the period of Jan. 1, 2019-June 30, 2019, must be reported to Medicare between January 1 and March 31, 2022. This collection, validation and reporting cycle will repeat every three years to form the basis for an updated CLFS. The next data collection period will be January 1 through June 30 2025, with reporting due during the first quarter of 2026.

Figure 1: Table showing year for CDLT rates, data collection periods, data reporting periods and reduction cap by year [3]

Year for CDLT Rates	Based on Data   Collection Period	Based on Data   Reporting Period	Reduction Cap
2020	January 1, 2016 – June 30, 2016	January 1, 2017 – May 30, 2017	10%
2021	January 1, 2016 – June 30, 2016	January 1, 2017 – May 30, 2017	0.0%
2022	January 1, 2016 – June 30, 2016	January 1, 2017 – March 31, 2017	15%
2023	January 1, 2019 – June 30, 2019	January 1, 2022 – March 31, 2022	15%
2024	January 1, 2019 – June 30, 2019	January 1, 2022 – March 21, 2022	15%
2025	January 1, 2019 – June 30, 2019	January 1, 2022 – March 31, 2022	0.0%

Applicable laboratories are responsible for collecting three primary types of information, according to CMS:[4]

1. The specific HCPCS code associated with the test
2. The private payor rate for each test for which final payment has been made during the data collection period
3. The associated volume for each test

The period for which data is to be collected includes dates of service from January 1 through June 30, 2019, as well as claims from earlier dates of service that were not paid until the 1/1/19-6/30/19 timeframe. For additional details on reporting requirements, visit CMS Medicare Learning Network Matters SE19006.

What are the penalties for PAMA non-compliance?

Applicable organizations may face civil penalties of up to $10,017 per violation per day if reporting is not complete, accurate and timely, according to CMS. There is no exception for Critical Access Hospitals. In its final rule, CMS noted that in situations where its review revealed that the data submitted was incomplete or incorrect, the agency would work with the Office of Inspector General (OIG) to assess whether a civil monetary penalty should be applied, and if so, what the appropriate amount should be based on the specific circumstances.[5] CMS also stated that it does not intend to assess monetary penalties for minor errors.[6]

What are some of the challenges hospitals face in collecting the PAMA-required data?

Many hospitals view the requirement as onerous because most don’t retain detailed payment rate data at the line-item level. Hospitals are especially challenged in reporting private payer rate details, since they typically don’t retain that information in their accounting systems, even though they are provided those details on the remittance advice.

Another challenge impacting some hospitals resulted from misinterpretation of a Medicare directive in 2014 that briefly advised hospitals to bill in-person service to patients on the 14X TOB. However, about six months later, CMS ordered hospitals to stop billing for these services on the 14X TOB. Hospitals discontinued the process once they realized it was non-compliant with HIPAA requirements, which specify what may be billed on a 14X TOB. At the same time, a new modifier was introduced which was declared not applicable to the 14X TOB, thereby adding to the confusion. The takeaway is that if a hospital didn’t use the 14X TOB for non-patient lab testing, it needs to be corrected right away. It’s unlikely an overpayment has occurred, but it is non-compliant to use the wrong type of bill to represent those services as in-person.

It is especially important for critical access hospitals to make sure they use the correct type of bill, because they could be overpaid on the cost reimbursement rate for services billed on an outpatient claim form that’s not a 14X TOB.

Why haven’t Medicare Administrative Contractors been talking about PAMA?

The Medicare Administrative Contractors (MAC) have no role in this process because submitted data goes directly to the Medicare national website and therefore does not flow through the regional MACs.

How can hospitals achieve PAMA compliance?

Even if your organization hasn’t started test rate collection and validation, it’s not too late to achieve compliance with the March 31, 2022 reporting deadline. Hospitals can immediately pull both paper and electronic 835s claims to begin assessing the total dollar amount and volume of the tests in question.

Alternatively, ParaRev provides compliance assistance through our comprehensive Lab Payment Reporting Analytical Services. Using Medicare outpatient claims data, we’ll help new and existing clients determine the type and volume of payments made through the Medicare 14x TOB. This will help determine whether the hospital has exceeded either the $12,500 Medicare threshold for the January-June 2019 reporting period, and therefore will need to report.

The PARA Data Editor additionally provides the ability to analyze electronic remittance files to quickly generate a spreadsheet of the allowable rates paid by CPT® codes on the 14x TOB. PARA can configure this electronic data into the required format for Medicare reporting. However, some clients will likely have received payments that will require manual research if they were not paid on a submitted 835 file. ParaRev is unable to research payments submitted on paper remittances.

PARA has developed a 30-minute online presentation that can help keep you compliant with PAMA laboratory rate and reporting requirements. This presentation provides detailed examples of some of the compliance challenges, providing vital information for all clinical laboratories.

It’s critical that hospital labs push to meet the PAMA reporting requirements, not only to eliminate the risk of onerous monetary penalties, but to help ensure the highest possible lab reimbursements in the future. Contact HFRI to learn more about how our Lab Payment Reporting Analytical Services can help you.

For addition information:

To learn more about the list of test codes subject to PAMA data collection and data reporting requirements click here. For more information about the private payer rate-based CLFS, click here.

1. “Medicare Part B Clinical Laboratory Fee Schedule: Revised Information for Laboratories on Collecting and Reporting Data for the Private Payor Rate-Based Payment System,” MLM Matters, Centers for Medicare and Medicaid Services, Sept. 5, 2019.
2. “Medicare Part B Clinical Laboratory Fee Schedule: Revised Information for Laboratories on Collecting and Reporting Data for the Private Payor Rate-Based Payment System.” MLM Matters, Centers for Medicare and Medicaid Services, Jan. 8, 2020.
3. PAMA Regulations-Important Update. Medicare.gov
4. “Medicare Part B Clinical Laboratory Fee Schedule: Revised Information for Laboratories on Collecting and Reporting Data for the Private Payor Rate-Based Payment System,” MLM Matters, Centers for Medicare and Medicaid Services, Sept. 5, 2019.
5. “Medicare Program; Medicare Clinical Diagnostic Laboratory Tests Payment System, Final rule,” Federal Register, June 23, 2016.
6. Ibid

Related Posts

None found

As the use of telehealth skyrockets due to the COVID-19 pandemic, financially hard-hit providers must consider new revenue cycle management protocols to ensure the best chance for full reimbursement.

In March 2020, telehealth utilization exploded 4,300% from a year earlier as patients and providers sought alternatives to office visits for routine care. Yet long-term uncertainty about Medicare reimbursement and wide disparities in the way commercial payers and Medicaid programs reimburse for telehealth mean providers must be extra-vigilant to limit denials and underpayments.[1]

Key steps like ensuring complete documentation of services, including the audio and/or visual functionality used to deliver the care, as well as close scrutiny of telehealth claims, are essential to maximize reimbursement, revenue cycle experts with Healthcare Financial Resources (HFRI) say.

“With telehealth services accounting for an ever-larger percentage of care, making sure you’re collecting every telehealth dollar you’re entitled to will be critical to sustaining cash flow in the months and years to come, particularly amid the lingering downturn triggered by COVID-19,” said Dan Low, HFRI’s director of operations.

As defined by the American Medical Association, telehealth services generally fall into one of four modalities:

• Real-time, audio-visual communications that link physicians and patients
• Store-and-forward technologies that collect images and data to be transmitted and interpreted later
• Remote patient-monitoring tools such as wearable devices, blood pressure monitors and other devices that record and communicate biometric data
• Verbal and text virtual check-ins made through patient portals and messaging apps.[2]

Telehealth can be administered by a range of clinicians, including physicians, nurse practitioners, physician assistants, clinical nurse specialists and psychologists.

Economic pressure mounting

Physician offices and hospitals have been slammed economically by sharp drops in office visits and elective procedures as a result of the pandemic. Although volume has begun to recover, the American Hospital Association is predicting hospitals and health systems could still lose $120.5 billion between July 2020 and the end of the year, or about $20 billion a month.[3] Primary care doctors, meanwhile, may lose approximately $15 billion in 2020.[4]

Permanent changes sought

At the outset of the pandemic, statutes preventing expanded access to telehealth for Medicare beneficiaries were waived by Congress as part of the declaration of a public health emergency. The temporary move allowed a wider range of providers to deliver more telehealth services with a greater variety of technology and without geographic or originating site limitations. This flexibility helped accelerate the expansion of telehealth across the care continuum, with over nine million Medicare beneficiaries participating from mid-March through mid-June, according to internal Centers for Medicare and Medicaid Services (CMS) analysis.[5]

Although the initial telehealth waivers were initially set to expire on July 25, 2020, the U.S. Department of Health and Human Services (HHS) extended the federal public health emergency on July 24 through October 23, 2020, thus ensuring continued telehealth coverage through the ongoing public emergency. This waiver must be renewed every 90 days.[6]

Separately, the CMS 2021 Physician Fee Schedule Draft has proposed nine new telehealth CPT codes. The agency also has developed a new Category 3 for codes that will be covered during the COVID-19 emergency only. This category contains approximately 50 codes created during the COVID-19 pandemic, as well as 13 new codes and other changes.[7] Several telehealth bills likewise have been introduced to help expand the service and ensure telehealth regulations remain intact beyond the pandemic.[8]

Commercial, Medicaid payer confusion

The increased statutory flexibility has made it easier to be reimbursed for Medicare telehealth services. But at least for now, inconsistent and conflicting policies across the commercial landscape have created major payment hurtles for some providers. Although many insurance companies have asserted that, like Medicare, they will reimbursement at 100% of the in-person rate for a range of virtual visits, the reality is far less straightforward.

Clinicians say some insurance companies are unable to provide updated information about telehealth payment policies and much uncertainty exists about what companies will pay for and what they won’t. Medicaid reimbursement, meanwhile, varies from state to state, with telehealth payment policies clearly defined in some states but not in others.

Revenue Cycle safeguards

Regardless of the payer, providers should make a point to include all pertinent information on telehealth claims to limit the risk of denials. Specifically, claims should incorporate:

• Date, time and location of service
• Appropriate use of GT (telehealth) modifiers
• Emergency room or outpatient consultation
• Recommendations and scheduled follow-ups
• Type of technology used
• Proof of patient consent with systems that are not privacy protected (e.g. Skype)

Providers also should conduct ongoing audits to be sure telehealth claims are being coded, documented and filed accurately. Close monitoring of, and communications with, payers of all types likewise are important to maintain an up-to-date understanding of telehealth policies.

“Consistent monitoring of telehealth CARC AND RARC reason codes from the insurance carrier will help you to identify what rejections the payers are applying to your telehealth services,” Low said.

The new normal

Most observers expect the waivers granted for Medicare telehealth will be made permanent and that commercial payment policies eventually will become more coherent and consistent. Assuming providers remain vigilant about reimbursement policies, the telehealth wave unleashed by COVID-19 ultimately could support a new paradigm for providing health-quality, cost-efficient care, not only for outpatient services but inpatient and remote patient monitoring as well.

ParaRev can help

Staying abreast of the latest coding directives regarding telehealth reimbursement and denials can be a challenge. This is especially true when coverage varies between government and commercial payers and from state to state. ParaRev has a large footprint across the U.S. Our experts have a thorough knowledge of each state’s requirements and can help you with comprehensive revenue cycle services to support accurate coding, clean claims and timely and appropriate reimbursement. Contact us today to learn more about the many ways we can help your organization.

1. Heather Landi, “More than 300 organization, physician groups push Congress to take action on telehealth policies,” Fierce Healthcare, June, 30, 2020.
2. “AMA Telehealth quick guide,” American Medical Association, updated July 6, 2020.
3. Robert King, “AHA: Hospitals could lose $20B a month for the rest of 2020 due to COVID-19 impact,” Fierce Healthcare, June 30, 2020.
4. Robert King, “Study: Primary care practices could lose $15B in 2020 due to COVID-19,” Fierce Healthcare, June 26, 2020.
5. Seema Verma, “Early Impact of CMS Expansion of Medicare Telehealth During COVID-19,” Health Affairs, July 15, 2020.
6. “Renewal of Determination that a Public Health Emergency Exists,” Kaiser Family Foundation, July 1, 2017.
7. Eric Wicklund, “How CMS Changes, Trump’s Executive Order Affect Telehealth Coverage,” mHEALTH INTELLIGENCE, August 6, 2020.
8. Eric Wicklund, “The COVID-19 Telehealth Expansion Bills Are Starting to Pile Up,,” mHEALTH INTELLIGENCE, July 31, 2020.

Related Posts

None found

Hospitals can quickly and dramatically improve collections by reducing Claim Adjustment Reason Code (CARC) 24 denials, or claims rejected due to incorrect Medicare and Medicaid submissions.

CARCs are used by payers on electronic and paper remittance advice and coordination of benefit (COB) claim transactions to categorize payment adjustments and denials.

CARC 24 denials are defined as “Charges covered under a capitation agreement or managed care plan.” These denials represent claims mistakenly billed to original Medicare or Medicaid in cases wherein the beneficiary is actually enrolled in a Medicare Advantage (MA), Medicaid Advantage or a similar managed care replacement policy. The denials most frequently originate in the emergency department or with outpatient surgical procedures.

Medicare Advantage and Medicaid managed care growth

Nationwide, the volume of CARC 24 denials has increased as government-payer managed care enrollment has continued to grow. Total MA enrollment of 22 million in 2019 represented an 8 percent increase, or about 1.6 million people, over 2018 levels, and was more than twice as high as MA enrollment 10 years ago (about 10.5 million).[1] MA enrollment is expected to continue expanding, with managed care plans projected to cover 60-to-70 percent of all Medicare beneficiaries within the next two decades.[2]

Medicaid managed care coverage has also risen. From 2003 to 2017, Medicaid managed care enrollment increased by approximately 229 percent nationwide to over 54 million,[3] with “more than two-thirds of all Medicaid beneficiaries nationally receive most or all of their care from risk-based managed care organizations (MCOs) that contract with state Medicaid programs to deliver comprehensive Medicaid services to enrollees.”[4]

In total, over 76 million individuals are currently covered by Medicare Advantage or Medicaid managed care organizations. That means incorrect Medicare or Medicaid managed care submissions can be an issue for any hospital or health system.

From our experience with clients nationwide, Healthcare Financial Resources’ (HFRI) has found that CARC 24 denials generally account for about 5% of all hospital denials. The good news is that unlike CARC 22 order-of-insurance denials, eliminating CARC 24s can be relatively simple.

And because replacement plans typically pay more than original Medicare or Medicaid, projected reimbursements, or expected cash, can be improved along with outright collections. ParaRev has seen 100% increase in expected reimbursements after correcting CARC 24 denials.

Accessing common working files

To cut CARC 24 denials, hospitals should implement more rigorous registration policies to help ensure that staff verifies the beneficiary’s type of coverage when the patient presents for care. This can be as simple as developing a list of increasingly specific questions for patients who state they are covered by Medicare or Medicaid.

Equally important is providing staff with access to common working files that contain details of beneficiaries’ Medicare or Medicaid coverage. The files are generally available through state or regional Medicare and Medicaid websites. Because access is restricted to approved applicants, providers should engage with their local Medicare and Medicaid authorities to submit appropriate applications for relevant staff members and to ensure website availability is maintained.

Partnering with a vendor

ParaRev is able to identify both CARC 24 denials and underlying root causes with our advanced technology, which relies on robotic process automation, or bots, to identify potential claim rejections and flag them in the workflow. By helping ensure that any denial issues will to be worked quickly, hospitals can receive faster reimbursement and, when necessary, generate the patient bill sooner. That means improved cash collections.

HFRI has focused exclusively on the challenges associated with hospital payment delay and denials for nearly 20 years. From this effort, we’ve perfected a system that relies on advanced technology and staff specialization to identify denial root causes while streamlining and accelerating the resolution process. Contact us today to learn more.

1. Gretchen Jacobson, et al., “A Dozen Facts About Medicare Advantage in 2019,” Kaiser Family Foundation, June 6, 2019.
2. “A Simple Guide to Medicare Advantage and Why It’s Taking Off Now,” CB Insights, Jan. 3, 2019.
3. “Total Medicaid MCO Enrollment – 2003-2017,” Kaiser Family Foundation, July 1, 2017.
4. “Medicaid Managed Care Market Tracker,” Kaiser Family Foundation, 2020.

Related Posts

None found

When it comes to payment denials, some of the most common and potentially damaging involve Claim Adjustment Reason Code (CARC) 22, or order-of-insurance coverage problems.

Not only do CARC 22 denials reduce cash flow, they can also trigger unnecessary patient invoicing. This, in turn, may undermine customer goodwill and harm the hospital’s overall patient experience and brand.

To maximize collections and avoid antagonizing patients, organizations should develop procedures for addressing the root causes that lead to CARC 22s. The good news is that once the core issues are identified, avoiding the denials isn’t difficult.

Increasing cash flow

Claim Adjustment Reason Codes are used by all payers on electronic and paper remittance advice and coordination of benefit (COB) claim transactions to categorize payment adjustments and denials.

CARC-22 states: “This care may be covered by another payer per coordination of benefits.” In essence, a CARC-22 is generated when a COB-related problem occurs. A common example involves instances in which the patient’s secondary insurance coverage is being billed as the primary coverage. This can occur with Medicare, Medicare Advantage, Medicaid or a commercial payer as the primary insurer. Typically, the patient is automatically balance-billed following a CARC-22 denial.

From our experience with clients nationwide, Healthcare Financial Resources’ (HFRI) has found that CARC 22 order-of-insurance denials typically account for about 7-8% of all hospital denials. With average balances generally of between $500 and $1,500 per claim, preventing CARC-22s could mean an additional $100,000 to $1 million in monthly collections, depending on the hospital’s size

Denial triggers

While CARC-22s occur in both inpatient and outpatient settings, the denials are most frequently associated with emergency department services. This is largely due to the fact that staff may not have the time or the systems in place to positively identify the patient’s primary insurance, or the patient may not be in a condition to provide the required information.

Specific CARC-22 triggers can include:

• Incorrect plan codes loaded for primary insurance
• Failed transfer in the attachment of the primary EOB to the bill

Medicare CARC-22s may also result from situations in which the beneficiary’s spouse has an employer-based health plan. For example, if the spouse’s employer has 20 or more employees, the group health plan pays first. However, if the employer has less than 20 employees, Medicare is the primary coverage. Rules regarding other primary payer scenarios involving Medicare and Medicaid, Tricare and workers compensation claims vary. Detailed information about Medicare and coordination of benefits can be found here.

Reducing denials

Registration staff represents the first line of defense when it comes to reducing and eliminating CARC-22s, particularly in the emergency department. Organizations should ensure that systems are in place to verify the correct order of insurance and plan code prior to billing. Staff should also have direct access to state-based websites in order to effectively validate Medicare and Medicaid order of coverage.

Creating an aftercare department to double-check the billing information provides an important second line of defense. Additionally, third-party robotic process automation systems can be deployed to identify registration issues that could trigger a CARC-22.

Partnering with a vendor

Because CARC 22 denials typically involve low-value, high-volume claims, many hospitals ignore them to focus limited resources on other, higher-value denial areas. However, ParaRev is equipped to handle these kinds of claims using our advanced technology, which relies on robotic process automation or bots and intelligent automation to identify potential CARC denials and flag them in the workflow.

This helps ensure that any denial issues will to be worked quickly. That means hospitals can receive faster reimbursement and, when necessary, generate the patient bill sooner. Our approach not only improves hospital margins, it helps ensure patient satisfaction doesn’t suffer due to unnecessary, surprise bills.

ParaRev has focused exclusively on the challenges associated with hospital payment delay and denials for nearly 20 years. From this effort, we’ve perfected a system that relies on advanced technology and staff specialization to identify denial root causes while streamlining and accelerating the resolution process. Contact us today to learn more.

Related Posts

None found