Medicare Telehealth Update
CMS issued an update related to billing Medicare for telehealth services in 2022 after the public health emergency ends. CMS has updated the Telehealth Services List to reflect minor regulatory changes.
Mental Health Booklet Update
CMS has updated its Mental Health Booklet with new requirements effective January 1, 2022, including the following notable changes:
•Interactive telecommunications systems can include inter-active, real-time, 2-way audio-only diagnosis, evaluation, or mental health or substance use disorder telehealth services treatment technology when the patient is in their home (page 6).
•Revised regulations require an in-person visit within 6 months before furnishing telehealth mental health services, and every 12 months while the patient gets telehealth services, unless physician and patient agree risks and burdens outweigh an in-person visit benefits and it’s documented in the medical record (page 24).
Billing for Medicare Psychotherapy Services
A Novitas reminder on billing psychotherapy services is available here.
2022 Physician Fee Schedule Lookup
2022 Medicare Part B rates are available by procedure code and locality or complete fee schedule download.
MIPS Performance Feedback and 2022 Payments
Performance in 2020 will be reflected in MIPS payment adjustments applied to Medicare payments for services furnished in 2022. View your MIPS performance feedback, final score, and payment adjustment on the Quality Payment Program (QPP) website. 2020 MIPS final scores reflect COVID-19 flexibilities, including automatic extreme and uncontrollable circumstances policy applied to all individual MIPS eligible clinicians, as well as CMS corrections to its scoring.
2022 MIPS Eligibility
The Quality Payment Program (QPP) Participation Status Tool will confirm your initial 2022 eligibility for the Merit-based Incentive Payment System (MIPS). Enter your NPI to find out whether you need to participate in 2022. To be eligible, you must:
- Bill over $90,000 in Medicare Part B allowed charges for covered professional services per year; AND
- Furnish covered professional services to over 200 Part B beneficiaries; AND
- Provide over 200 covered professional services under Part B.
Call 1-866-288-8292 (M-F 8AM – 8PM) or email QPP@cms.hhs.gov with questions.
2022 MIPS Resources
2021 E/M Coding Changes
Revised evaluation and management (E/M) office-visit codes that took effect on January 1 are specific for office and other outpatient visits and apply to codes 99201–99205 and 99211–99215. Practitioners can choose to document office/outpatient evaluation and management (E/M) visits via medical decision making or time. Please refer to the APA Coding and Reimbursement site for the most up-to-date information regarding coding and documentation changes, including a Quick Guide that is available with member credentials.
Check Your MIPS Status
Use the Quality Payment Program (QPP) Participation Status Tool to find your participation status for the Merit-based Incentive Payment System (MIPS). Your status may change from year to year. For more information, visit the MIPS Participation page or contact the Quality Payment Program at QPP@cms.hhs.gov or 1-866-288-8292 (TTY: 1-877-715-6222).
Exemption from MIPS Reporting
Use the Quality Payment Program (QPP) Participation Status Tool to find your final 2020 eligibility status for the Merit-based Incentive Payment System (MIPS) based on Medicare Part B claims and PECOS data, from October 1, 2019, to September 30, 2020.
Use the QPP Participation Status Tool to find your initial 2021 MIPS eligibility. Participation now could earn a payment increase in 2023 based on 2021 performance. Enter your NPI, to determine whether you need to participate in MIPS in 2021. To be eligible, you must:
- Bill more than $90,000 a year in allowed charges for covered professional services under the Medicare Physician Fee Schedule (PFS); AND
- Furnish covered professional services to more than 200 Medicare Part B beneficiaries; AND
- Provide more than 200 covered professional services under the PFS.
- If you do not exceed all 3 of the above criteria, you are excluded from MIPS. However, you can opt-in to MIPS and receive a payment adjustment if you meet or exceed 1 or 2, but not all, of the low-volume threshold criteria.
Assistance with Medicare Appeals, Denials and Grievances
The State Health Insurance Assistance Program (SHIP) meets the most universal needs of Medicare beneficiaries, such as understanding their health insurance benefits, bills, and rights. Trained staff and volunteer counselors in all 23 counties and Baltimore City provide in-person and telephone assistance. Topics covered include:
- Medicare Part A: Hospital Insurance
- Medicare Part B: Medical Insurance
- Medicare Part C: Advantage Plans
- Medicare Part D: Prescription Drug Plans
- Financial Assistance for Low-Income Beneficiaries
- Billing Issues, Appeals, Denials, and Grievances
- Medicare Fraud and Abuse
Click here to contact the closest SHIP office.
Qualified Registries for MIPS Data Submission
Under the Medicare Quality Payment Program option, MIPS, there are several data submission methods, one of which is Qualified Registries. A qualified registry is a CMS-approved entity that collects clinical data from MIPS eligible clinicians (both individual and groups) and submits it to CMS on their behalf for purposes of MIPS. CMS has designated the qualified registries that can report data (measures and/or activities) for the Quality, Advancing Care Information, and Improvement Activities performance categories, on behalf of individual MIPS eligible clinicians and groups. The APA’s PsychPRO registry is approved by CMS.
Medicare Quality Payment Program
Resources on the Quality Payment Program (QPP) website help eligible clinicians prepare to participate:
- Quality Payment Program: Key Objectives
- Advancing Care Information Fact Sheet
- Alternative Payment Models (APMs) in the Quality Payment Program
- Improvement Activities in MIPS APMs
- APMs: Medicaid and All-Payer Models Fact Sheet
Download the APA’s fact sheet about the MIPS Quality Performance Category for help deciphering your MIPS composite score and its impact on Medicare Part B payments. It also includes a Mental/Behavioral Health specialty measure set as well as a list of measures pertinent to psychiatrists. Visit the APA website for more Medicare payment reform resources, including a MACRA toolkit.
CMS educational videos are available on YouTube at http://Go.cms.gov/QPPvideos.
MACRA Assistance from the APA
The Medicare Access & CHIP Reauthorization Act (MACRA) completely transforms Medicare payment and quality reporting, though the Merit-Based Incentive Payment System (MIPS) and new incentives for “advanced” alternative payment models (APMs). To help members understand the new regulations, APA has relaunched its Payment Reform webpage and prepared free educational materials and a webinar series. Download the MACRA 101 Primer For Psychiatrists. The recorded presentation “Quality Reporting 101: A How-to Guide for Psychiatrists” is available through the APA Learning Center.
The APA Practice Management Helpline at 1-800-343-4671 is available for coding, reimbursement and practice management questions.
E&M Interactive Score Sheet
Novitas posted the E/M Interactive Score Sheet to assist with coding Evaluation and Management services.
Medicare Revalidation Reminder
The Affordable Care Act requires all currently and actively enrolled providers to revalidate their enrollment information every three or five years. CMS sets every provider’s revalidation due-date at the end of a month, and posts the upcoming six months online. A due date of “TBD” means that CMS has not set the date yet. Go to the revalidation dates page to search for your due date by name or browse the entire list to find the information needed. For more information, see the revalidation webpage and the FAQs.
If a provider fails to submit the revalidation application by the due date, the provider enrollment record will be deactivated. Deactivated providers must submit a full and complete application to reestablish their provider enrollment record and Medicare billing privileges. An interruption in billing will occur during the period of deactivation, resulting in a gap in coverage. Retroactive billing privileges back to the period of deactivation will not be granted. Services provided to Medicare beneficiaries during the period between deactivation and reactivation are the provider’s liability.
Please review the CMS revalidation document for more information. Any questions or concerns should be directed to Andrea King, Novitas Provider Outreach and Education, at: firstname.lastname@example.org or 717-526-6392.
Medicare Provider Data Published
CMS is making publicly available a subset of PECOS data to allow providers, suppliers, state Medicaid programs, private payers, etc. to leverage Medicare provider enrollment data. Click here for more information. The Public Provider Enrollment files are published at https://data.cms.gov/public-provider-enrollment and will be updated on a quarterly basis. Opt-out providers will not be included. Elements include:
- Enrollment ID and PECOS Unique IDs
- Provider Enrollment Type and State
- Provider’s First and Last Name/ Legal Business Name
- Provider or Supplier Specialty
- Limited address information (City, State, ZIP code)
Psychiatry and Psychotherapy Documentation
Proper payment and sufficient documentation go hand in hand. CMS has created a video series to help providers improve in areas identified with a high degree of noncompliance. The CMS Provider Minute: Psychiatry and Psychotherapy video includes pointers to properly submit documentation for these services. In about three minutes, the video explains:
- Use of add-on codes when billing for same day evaluation and management and psychotherapy services
- Three factors needed for sufficient documentation
Small Practices and Health Professional Shortage Areas & Medically Underserved Populations
CMS launched a new section of the Medicare Quality Payment Program (QPP) dedicated to clinicians working in small or rural practices as well as those treating patients in underserved areas. This page is a single point of reference for the QPP, especially, for those participating under the Merit-based Incentive Payment System (MIPS) track. Quickly locate contact information for organizations that assist practices through the Small, Underserved, and Rural Support initiative using an interactive map. Review the flexibilities to help reduce the participation and reporting burden on small practices for 2017. More features and information will be added, so submit your feedback to CMS.
MACRA provides direct technical assistance for small practices to participate in the QPP through an organization called IPRO, which serves Maryland, DC and Virginia.
Health Professional Shortage Areas (HPSAs) are designated as having shortages of primary care, dental care, or mental health providers and may be geographic (a county or service area), population (e.g., low income or Medicaid eligible) or facilities (e.g., federally qualified health centers, or state or federal prisons). Providers who serve these areas are eligible for bonus payments under Medicare. A search tool is available to check an address for bonus eligibility. Use another online tool to find HPSAs by state, country and discipline.
Changes to the Medicare Opt-Out Law
Prior to enactment of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), physician opt-out affidavits were only effective for 2 years. As a result of changes made by MACRA, valid opt-out affidavits signed on or after June 16, 2015 will automatically renew every 2 years. If physicians who file affidavits effective on or after June 16, 2015 do not want their opt-out to automatically renew, they may cancel the renewal by notifying all Medicare Administrative Contractors (MACs) with which they filed an affidavit in writing at least 30 days prior to the start of the next opt-out period. Valid opt-out affidavits signed before June 16, 2015 will expire 2 years after the effective date of the opt out. If physicians who filed affidavits effective before June 16, 2015 want to extend their opt out, they must submit a renewal affidavit within 30 days after the current opt-out period expires to all MACs with which they would have filed claims absent the opt-out. Check this CMS publication for more details.
Medicare Private Contracting Change
Physicians who opt-out of Medicare should be aware that CMS has changed its definition of emergency care services to encompass urgent care services, which are furnished within 12 hours to avoid the likely onset of an emergency medical condition. It has also specified that the enrollment appeals process should be used to appeal Medicare opt-out determinations, such as whether a physician or practitioner has failed to properly opt-out, failed to maintain opt-out, failed to timely renew opt-out, failed to privately contract, or failed to properly terminate opt-out. These changes are effective July 13, 2015. For details, click here.
Opting Out of Medicare
Since 1998, physicians have been permitted to opt out of Medicare and enter into private contracts with Medicare patients that allow them to set their own fees. A physician who opts out of Medicare agrees not to see any Medicare patients for two years (barring emergencies or urgent services), except for those with whom s/he has entered into private contracts. The opt-out applies for every Medicare patient a physician sees in clinics or elsewhere, not just those seen in private practice. If there is any possibility of having to see Medicare patients as part of a new contract or employment, a physician should not consider opting out of Medicare. The rules for opting out are very specific. Please continue reading at the APA website.
To search for providers who have opted out of the Medicare program, see the CMS Opt-Out Affidavit listing, which is updated on a quarterly basis. If you opted out of Medicare and cannot locate your information, please call 1-877-235-8073.
A new Behavioral Health Integration Services fact sheet explains psychiatric collaborative care services and how to bill for this model of care.
A new Care Management page is available with fact sheets, FAQs, etc. Those who provide patients with chronic care management, non-face-to-face services such as reviewing test results or coordinating with other providers, may not be aware of the separate payments under the Medicare Physician Fee Schedule and may not be receiving the full separate payments that are now available. The Chronic Care Management Services Changes for 2017 fact sheet has information about 2017 coding changes, included services and reduced requirements for initiating care. The existing Chronic Care Management Services fact sheet has been revised, and addresses separately payable services for patients with multiple chronic conditions, codes and billing requirements, etc.
Novitas Behavioral Health Page – up-to-date topics, resources, training and coverage information.
Substance Abuse Services – Describes the levels of services and authorized suppliers that are covered under Medicare, as well as Part D drugs for opioid dependence.
Guidance on dually eligible individuals enrolled in the Qualified Medicare Beneficiary (QMB) Program was updated February 1, 2016. QMB is a Medicaid program for Medicare beneficiaries that exempts them from liability for Medicare cost-sharing. State Medicaid programs may pay providers for Medicare deductibles, coinsurance and copayments. Medicare providers must accept the Medicare payment and Medicaid payment (if any) as payment in full for services rendered to a QMB beneficiary.
Transitional Care Management Services can be billed by one clinician for services during the 30 days after discharge from an inpatient setting that include three TCM components: an interactive contact, certain non-face-to-face services, and a face-to-face visit.
HIPAA Privacy and Security Basics for Providers – Information on covered entities, business associates, and resources.
HIPAA Basics for Providers: Privacy, Security, and Breach Notification Rules – HIPAA basics, such as privacy, security, breach notification rules, covered entities, business associates, and disposal of private health information.
Medical Privacy of Protected Health Information addresses how the privacy rule applies to customary health care practices, tips for securing health information on a mobile device, and HIPAA resources.
Telehealth Services describes services that can be furnished to Medicare beneficiaries via a telecommunications system, including information about originating sites, distant site practitioners, telehealth services, billing and payment for services and facility fees, etc. Several psychiatric services became eligible for telehealth coverage in 2015.
PECOS Fact Sheet includes Medicare enrollment application submission options, how to complete an enrollment application using PECOS, and PECOS user ID and password helpful hints.
Medicare Appeals Process fact sheet explains the five levels of claim appeals in Original Medicare (Parts A and B).
Medicare Secondary Payer fact sheet explains situations when Medicare may pay first or second, coordination of benefits, etc.