CMS is hosting a call on November 5, 2014 to discuss implementation issues associated with the transition to ICD-10 on October 1, 2015. The call will cover the following topics: final rule and national implementation; Medicare Fee-For-Service testing; the Medicare Severity Diagnosis Related Grouper (MS-DRG) Conversion Project; partial code freeze and annual code updates; plans for national coverage determinations and local coverage determinations; home health conversions; and claims that span the implementation date.
CMS is hosting ICD-10-CM/PCS Coordination and Maintenance Committee meetings in September to provide a public forum to discuss proposed code changes to the ICD-10-CM and ICD-10-PCS. The meeting scheduled for September 23 will address procedure code issues, while the September 24 meeting is devoted to diagnosis code issues.
HHS has published a final rule that makes official the October 1, 2015 compliance date for the International Classification of Diseases, 10th Revision, Clinical Modification (ICD-10-CM) and the International Classification of Diseases, 10th Revision, Procedure Coding System (ICD-10-PCS). HHS had previously intended to transition from ICD-9 to ICD-10 on October 1, 2014, but the Protecting Access to Medicare Act of 2014 prevents HHS from adopting ICD-10 prior to October 1, 2015.
As recently announced, CMS is conducting what it describes as a “limited demonstration” of an internet-based notice and comment mechanism on internally-generated requests to discontinue Level II HCPCS codes. CMS has just released details regarding the first two HCPCS codes it is proposing to remove under this process:
- A7042 Implanted Pleural Catheter, Each. CMS rationale: the catheter is included in the procedure and therefore a separate code is unnecessary.
- A9586 Florbetapir f18, diagnostic, per study dose, up to 10 millicuries. CMS rationale: HCPCS code A9599 “Radiopharmaceutical, Diagnostic, for beta-amyloid positron emission tomography (pet) imaging, per study dose” adequately describes this product.
CMS will accept public comments on the proposed HCPCS discontinuations until July 21, 2014. Comments should be submitted to email@example.com, and include the following text in the subject line: “COMMENT RE: DISCONTINUATION OF CODE _____.”
CMS has announced what it is describing as a “limited demonstration” of an internet-based notice and comment mechanism on requests to discontinue Level II HCPCS codes. The internet-based process would apply to HCPCS discontinuation requests that are generated by CMS based on national program operating needs, and that are not the subject of other notice and comment mechanisms and that are not replaced by other or new codes. CMS contends that this “demonstration” will enhance transparency by providing the public with advance notice and comment opportunity regarding internal decisions to discontinue HCPCS codes. CMS reserves the right to make immediate changes without notice (and take comments afterwards) if it believes there is a national program operating need to do so. The first year of the demonstration will be conducted in the current 2014/2015 HCPCS coding cycle. CMS will publish summaries of internal requests to discontinue permanent level II HCPCS codes by July 1, 2014, and CMS will accept public comments until July 21, 2014.
CMS has announced that it is extending its partial ICD-9-CM and ICD-10 code freeze to reflect enactment of legislation (the Protecting Access to Medicare Act of 2014) that prevents the agency from adopting ICD-10 prior to October 1, 2015. Under the new schedule, on October 1, 2014 there will be only limited code updates to both the ICD-9-CM and ICD-10 code sets to capture new technologies and diseases. On October 1, 2015 (the new compliance date for ICD-10 reporting), there will be only limited updates to ICD-10 code sets to capture new technologies and diagnoses; there will be no updates to ICD-9-CM since it will no longer be used for reporting. On October 1, 2016, regular updates to ICD-10 will begin.
CMS is holding a public meeting on July 14, 2014 to receive comments on the appropriate basis for establishing payment amounts for new or substantially revised HCPCS codes being considered for Medicare payment under the clinical laboratory fee schedule for 2015. The meeting also provides a forum for those who submitted reconsideration requests regarding final determinations made last year on new test codes.
CMS has announced that it is holding series of meetings in May and June to discuss pending application for the 2015 Healthcare Common Procedure Coding System (HCPCS) update. The dates are as follows:
- May 20 & 21, 2014 -- Drugs/Biologicals/Radiopharmaceuticals/Radiologic Imaging Agents
- May 28, 2014 -- Supplies and Other
- June 3, 2014 -- Durable Medical Equipment (DME) and Accessories; and Orthotics and Prosthetics (O&P).
Additional information, include preliminary coding determinations, will be posted in advance of each meeting.
CMS has released the 2014 update to the Healthcare Common Procedure Coding System (HCPCS) files, which include the Level II alphanumeric HCPCS procedures and modifiers, long and short descriptions, and applicable Medicare administrative, coverage, and pricing data.
The deadline for applications for new Healthcare Common Procedure Coding System (HCPCS) codes to be considered for the 2015 update is January 3, 2014. A copy of the application and other details about the process are available here.
In addition to delaying the CY 2014 Medicare payment update final rules, CMS has announced that the partial government shutdown is expected to impact completion of the CY 2014 HCPCS coding update. CMS intends to publish the 2014 HCPCS Annual Update file by November 27, 2013 (based on the timing of the final rules), with new HCPCS codes effective January 1, 2014 unless otherwise specified. Final decisions on HCPCS coding applications will be mailed to individual applicants to coincide with the publication of the HCPCS annual update.
CMS published a final rule on August 7, 2013 that updates Medicare hospice reimbursement and related policies for FY 2014, which begins on October 1, 2013. The final rule increases Medicare hospice payments by 1.0% compared to FY 2013 rates, but down slightly from the 1.1% increase anticipated in the proposed rule. Specifically, CMS is increasing hospice per diem rates by 1.7% (reflecting a 2.5% market basket increase that is reduced by 0.8 percentage points due to ACA adjustments), but this update is partially offset by a 0.7 percentage point cut resulting from the use of updated wage data and continued phase-out of the wage index budget neutrality adjustment factor (as set forth in prior rulemaking). CMS is also finalizing its clarification of ICD–9–CM coding guidelines and CMS’s expectations for diagnosis reporting on hospice claims, especially regarding the use of nonspecific symptom diagnoses. CMS instructs hospice providers to use the most definitive, contributory terminal illness as the principal diagnosis, with additional diagnoses included on the claim. CMS provides that “debility” and “adult failure to thrive” may not be used as principal hospice diagnoses on the claim; such claims will be returned to the provider for more definitive coding. However, in response to comments regarding the need for additional time to implement these coding clarification changes within provider software systems, CMS will delay returning claims to providers until October 1, 2014 (which coincides with the transition to ICD-10-CM).
CMS also adopted revisions to its hospice quality reporting requirements. By way of background, under the ACA, hospices that fail to meet quality reporting requirements will receive a 2 percentage point reduction to their market basket update beginning in FY 2014. In 2013, hospices began reporting data on two quality measures (a pain management measure and a structural measure on participation in a Quality Assessment and Performance Improvement Program) for the FY 2014 payment determination. Beginning with the 2016 payment determination, CMS is eliminating these two measures and replacing them with a standardized patient-level data collection instrument called the Hospice Item Set (HIS). Hospices must complete the HIS at admission and discharge on all patients admitted to hospice effective July 1, 2014. The final rule also discusses, among other things, CMS’s plans to require the use of a Hospice Experience of Care Survey beginning in 2015 for the FY 2017 payment determination, and CMS’s efforts to reform the hospice payment framework. Further, the rule provides that CMS will update future hospice per diem rates through an annual rule or notice, rather than solely through a subregulatory Change Request, as CMS has previously done.
CMS has announced that it is hosting a July 10, 2013 public meeting to receive comments and recommendations on the appropriate basis for establishing payment amounts for new or substantially revised HCPCS codes being considered for Medicare payment under the clinical laboratory fee schedule for calendar year 2014. The deadline for registration of presenters and submission of presentations is June 28, 2013. CMS intends to publish its proposed determinations for new and reconsidered codes for CY 2014 by early September; comments on those proposed determinations will be accepted until September 27, 2013.
On May 3, 2013, CMS and the Office of the National Coordinator for Health Information Technology (ONC) are hosting a meeting to discuss electronic health records, the increase in code levels billed for some Medicare services, and appropriate coding in an increasingly-electronic environment. The meeting, which is aimed at providers, health information technology vendors, and other interested stakeholders, will address issues such as the impact of EHRs on high quality clinical care, provider efficiency and coding, and coding challenges and opportunities facing various groups, including hospitals and clinicians. Attendees may participate in person, via telephone, or web streaming. Registration is required.
An April 18, 2013 CMS provider call will focus on the transition to the ICD-10 code set, including implementation planning and preparation strategies.
The GAO has issued a report on the methodology CMS uses to calculate a risk adjustment for Medicare Advantage (MA) plans, updating an analysis in provided in January 2012. The GAO previously reported that differences in diagnostic coding between MA plans and Medicare FFS resulted in inaccurately-high MA risk scores and excessive payments to MA plans. While CMS made an adjustment for coding differences in 2010, the GAO concluded that the adjustments were insufficient. Based on an analysis of two years of data available since the GAO completed its analysis for the January 2012 report, the GAO found that the cumulative impact of coding differences on risk scores increased from 2010 through 2012, and that CMS's adjustment to risk scores to account for diagnostic coding differences was too low. The GAO estimates that as a result, at least $3.2 billion in excess payments were made to MA plans over three years. The GAO continues to recommend that CMS update its methodology to more accurately account for differences in diagnostic coding between MA plans and Medicare FFS.
In preparation for the October 1, 2014, ICD-10 code set implementation date, CMS has posted a variety of ICD-10 checklists and planning timelines for provider practices, hospitals, and payers. CMS also has outlined suggested steps for ensuring a smooth transition to ICD-10 and preparing for potential cash-flow disruptions from claims processing delays. For instance, CMS encourages providers to process ICD-9 transactions before the October 1, 2014 deadline “to avoid facing a major backlog.”
CMS is holding series of meetings in May and June 2013 to discuss preliminary determinations for applications for new Healthcare Common Procedure Coding System (HCPCS) codes for the 2014 update. The following are the 2013 public meeting dates:
- May 8 and 9, 2013 -- Drugs/Biologicals/Radiopharmaceuticals/Radiologic Imaging Agents
- May 29, 2013 -- Supplies and Other
- June 4, 2013 -- Durable Medical Equipment and Accessories & Orthotics and Prosthetics
Draft agendas, including a summary of each request and CMS’s preliminary decision, are expected to be posted on the HCPCS web site at least 4 weeks before each meeting.