SAVE THE DATE April 7-8, 2016 DECEMBER ISSUE OF THE POHMS NEWSLETTER – ISSUE 23 POHMS Spring Conference Sheraton Valley Forge; King of Prussia, PA POHMS – Premier Oncology Hematology Management Society 1802 Route 31 North #312 Clinton, NJ 08809 Phone: (908) 537-6880| Fax: (866) 631-3299 Editor: Michelle Weiss, Weiss Oncology Consulting - Michelle@WeissConsulting.org This newsletter is intended for informational purposes only. Information is provided for reference only and is not intended to provide reimbursement or legal advice. Laws, regulations, and policies concerning reimbursement are complex and are updated frequently and should be verified by the user. Please consult your legal counsel or reimbursement specialist for any reimbursement or billing questions. CPT codes are owned and trademarked by the American Medical Association. All Rights Reserved. No portion of this publication may be copied without the express written permission of POHMS. In no event may any portion of this publication be copied or reprinted and used for commercial purposes by any party other than POHMS. INSIDE THIS ISSUE….TABLE OF CONTENTS NATIONAL NEWS To View This Newsletter Simply select a link from the topics listed on the right or just scroll through the entire issue. CMS MEDICARE OTHER PAYER UPDATES FAQ’S NOTIVAS SOLUTIONS INC OTHER NEWS POHMS PAGES THE POHMS NEWSLETTER - DEC 2015 - Issue 23 Page 2 CORPORATE ALLIES ATTENTION CORPORATE SPONSORS Advertising Opportunity!! We are looking for supporters of the POHMS Newsletter. Interested parties contact one of our Board Members… CLICK HERE HOME NATIONAL NEWS Aetna expert explores new cancer payment methodology November 29, 2015 by Tracey Walker New payment models that were initially developed for primary care or common surgical procedures are now being developed and used for patients with blood diseases. Michael A. Kolodziej, MD, national medical director, oncology solutions, office of the chief medical officer, Aetna, will address some of the challenges of creating payment models for hematologic conditions, review data on hematologic services utilization, and evaluate how insurers are implementing these models, at the American Society of Hematology (ASH) meeting in Orlando, Florida. READ MORE Budget deal cuts pay to hospital-owned practices December 1, 2015 by Bob Gatty Washington—There was generally positive news for Medicare providers in the new 2-year budget agreement signed into law by President Obama Nov. 2 as well as the 2016 physician fee schedule just released by the Centers for Medicare & Medicaid Services (CMS). READ MORE OIG Releases 2016 Work Plan The Office of the Inspector General (OIG) has released its 2016 work plan, detailing more than 40 new investigations it plans to undertake in the coming year. According to the report, the new inquiries cover CMS's management of the ICD-10 implementation, Medicare Part D beneficiaries' exposure to inappropriate drug pairs, CMS's ability to oversee Part D pharmacies, and increases in brand-name drug prices under Part D. In addition, OIG plans to review specialty drug pricing and reimbursement in Medicaid, tobacco establishment compliance with the Family Smoking Prevention and Tobacco Control Act, among other topics. View the Work Plan Here OIG Releases Study on Growth and Profitability of 340B Program Wednesday, November 25, 2015 The HHS Office of the Inspector General finds that the 340B drug discount program produced profit margins of 58% on covered drugs. READ MORE New OIG Report Shows Hospitals’ Huge 340B Profits from Medicare-Paid Cancer Drugs The Office of Inspector General (OIG) has just released another eye-opening report on the 340B drug discount program: Part B Payments For 340BPurchased Drugs. (Free download) READ MORE THE POHMS NEWSLETTER - DEC 2015 - Issue 23 Page 3 The following JL ICD-10 Oncology Related Local Coverage Determinations have been revised: NOVITAS SOLUTIONS HOME Important reminder on how to correctly submit documentation for ADRs (Additional Documentation Requests) Biomarkers for Oncology (L35396) Implantable Infusion Pump (L35112) Services That Are Not Reasonable and Necessary (L35094) Thrombolytic Agents (L35428) Providers Not Required to Revise Physician Orders Written Before October 1, 2015 Novitas Solutions’ Medical Review Department continues to experience improper submission of documentation in response to an ADR. Please take a moment to review the information provided in How to Correctly Submit Documentation for Additional Documentation Requests (ADRs). CMS (Centers for Medicare & Medicaid Services) posted a new FAQ about physician orders written before the October 1 ICD-10 compliance date. FAQ 12625 explains that CMS is not requiring the ordering provider to translate ICD-9 diagnosis codes to ICD-10 on orders written before October 1 for lab, radiology, or any other services. For more guidance on claims processing and billing, please visit the CMS ICD-10 FAQ webpage. New CERT A/B MAC Outreach & Education Task Force Publication on Lab Documentation The CERT A/B MAC Outreach & Education Task Force posted a new publication titled Complying with Documentation Requirements for Laboratory Services. If you order lab services for Medicare patients, please read this important publication. Learn about how you can properly document orders and reduce the CERT error rate. THE POHMS NEWSLETTER - DEC 2015 - Issue 23 Page 4 Correction to Telephone Number in 2016 Participation Post Card Mailing An incorrect telephone number was printed in a recent post card mailing you may have received on the 2016 Medicare Participation Process. The correct phone number to call if you do not have internet access and require a hardcopy of the 2016 Participation Enrollment and Information Package is 1-877-235-8073. We apologize for any inconvenience. HOME NOVITAS SOLUTIONS The Holiday Season is Here! Listed are Novitas training events an oncology practice should consider! The holiday season is upon us and while we are happy to work with you, your written and/or verbal feedback is the only gift that we need! Please note that Novitas employees are prohibited from accepting any gifts from providers at any time and not just during the holiday season. CLICK HERE to access the educational area of the Novitas website! DATE TIME EVENT LOCATION 12/8/15 10:00a-11:00a Via Webinar 12/8/15 2:00p-3:00p 12/9/15 10:00a-11:00a Understanding the Enrollment of Clinics/Group Practices and Certain Other Suppliers (CMS855B and CMS-855R) Novitasphere Provider Portal Enrollment Overview Subsequent Hospital Care Rules and Coding 12/10/15 2:00p-3:00p Via Webinar 12/11/15 10:00a-11:00a Save Time and Money with Electronic Remittance Advice Novitasphere Claim Correction Overview 12/15/15 11:00a-12:00p New Patient Guidelines and Coding Via Webinar 12/18/15 11:00a-12:00p Via Webinar 12/12/15 11:00a-12:00p The Established Patient: Billing and Coding Office Visits Novitasphere Claim Submission Overview THE POHMS NEWSLETTER - DEC 2015 - Issue 23 Page 5 Via Webinar Via Webinar Via Webinar Via Webinar Thank you! NOVITAS SOLUTIONS 2016 Medicare Part A and B Deductibles and Coinsurances are Now Available The 2016 Medicare Part A and B Deductibles and Coinsurances are now available. Please take a moment to review. READ MORE CMS Education Novitas Solutions e-News Electronic Billing Quarterly Newsletter Articles of note: HOME Weekly Audio Podcasts Training Modules Medicare Reference Manual Specialty Guides Acronyms & Abbreviations Frequently Asked Questions Quick Ref. Guides & Claims Errors/Issues Evaluation & Management (E/M) Center Comprehensive Error Rate Testing (CERT) Center Open Payments (Physician Payments Sunshine Act) * Medicare Learning Network * National Provider Training Program * Internet-Only Manual * Provider Specialty Links Reducing Medicare and Medicaid Fraud and Abuse: Protecting Practices and Patients * How CMS Is Fighting Fraud: Major Program Integrity Initiatives * Safeguarding Your Medical Identity * Frustrated When a Medicare Secondary Payer (MSP) Claim Rejects? How to Review Pending End User Requests for Novitasphere in CMS Enterprise Portal (EIDM) And More… NOVEMBER Issue Available CLICK HERE On-Demand Education Medicare Part B - H O T L I N K S ! 2016 Medicare JL Part B Fee Schedule Current Active Part B LCD Policies Current Average Sales Price (ASP) Files Quarterly Update to CCI Edits 2016 Physician Fee Schedule Final Rule 2016 CMS Physician Fee Schedule Final Rule Fact Sheet THE POHMS NEWSLETTER - DEC 2015 - Issue 23 Page 6 HOME CMS MEDICARE What's New! Performant Recovery Providers: The discussion period offers the opportunity for the provider to submit additional information to the RAC to indicate why recoupment should not be initiated. Discussions may be processed entirely in writing or may require a teleconference with the provider. To request a discussion, please download the Discussion Request Form that can be found HERE. This form, along with any additional documentation should be submitted. To get to the Performant Recovery website CLICK HERE OIG Work Plan: Fair Warning By Chuck Buck The U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) 2016 Work Plan comes with a warning: the OIG continues to be relentless in detecting and pursuing waste, fraud, and abuse. In the 75-page plan, posted to the OIG's website on Monday, the agency reported that in the most recent fiscal year it had recoveries of more than $3 billion. The OIG indicated that it also had excluded 4,112 individuals and entities from participating in HHS programs during that time. Moreover, the OIG noted that it had brought 925 criminal actions against individuals or entities that engaged in crimes against HHS programs, as well as 682 civil actions, which the OIG includes as false claims and "unjust-enrichment lawsuits filed in federal district court, CMP settlements, and administrative recoveries related to provider self-disclosure matters." READ MORE New Claim Filing Requirements for Hospital-Based Off Campus Clinics By Duane Abbey, PhD, CFP Starting Jan. 1, 2016, hospitals will need to alter the way in which they bill for both professional and facility component claims for off-campus, hospital-based (or, more accurately, provider-based) clinics. The Centers for Medicare & Medicaid Services (CMS) has decided to start collecting data relative to these clinics, and presumably, other off-campus provider-based operations as well. READ MORE THE POHMS NEWSLETTER - DEC 2015 - Issue 23 Page 7 RAC Monitor continued on next page… The Corporate Integrity Agreement: Avoiding Audits CMS MEDICARE HOME By Edward Roche, MA, M. Phil, PhD. JD November 18, 2015 Some audits end badly. The provider must pay back all that was received for improper claims, for example. But it might not end there. There remains the possibility of civil money penalties under 42 U.S. Code § 1320a–7a, and complete exclusion from any healthcare program that gets even part of its funding from the federal government. READ MORE Pushed and Pulled RA Contracts Emerge from Scuffling By Emily Evans November 18, 2015 On Friday evening the Centers for Medicare & Medicaid Services (CMS) released its long-awaited request for proposals for the Medicare Recovery Auditors (RAs). As this program has been the subject of much political, regulatory, and judicial meddling, there are no surprises. The basic contours of the program are the following: There will be five RAC regions instead of the current four. Four of the five regions will be dedicated to audits of inpatient stays (except shortstay inpatient services, which will be subject to a different process), outpatient stays, physicians, inpatient rehabilitation facilities (IRFs), longterm care hospitals (LTCHs), and skilled nursing facilities (SNFs). The fifth RAC will be dedicated to audits of home health, hospice, and durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) claims. This structure is bad news for home health, hospice, and DMEPOS, which have been given little attention to date, their improper payment rates notwithstanding. READ MORE Smoking Cessation Claims Editing Incorrectly A system error caused claims for smoking cessation with dates of service on or after October 1, 2015, to edit incorrectly. Your Medicare Administrative Contractor (MAC) will correct all affected claims. No provider action is required. THE POHMS NEWSLETTER - DEC 2015 - Issue 23 Page 8 Predicting the Future of Meaningful Use 3 To get a sense of where the Meaningful Use program may be headed, and why so few physicians have participated beyond Stage 1, Medical Economics conducted a Q&A with John Halamka, MD, MS. Find out what you need to know HOME CMS MEDICARE New Educational Web Guides Fast Fact A new fast fact is available on the Educational Web Guides webpage. Visit the webpage for resources on CMS initiatives, including: Evaluation and Management services Guided Pathways resource booklets Health care management, billing, and coding products ICD-10 Transition: Clarifications about NCDs and LCDs All Medicare national and local coverage policies are translated for ICD-10, and to receive payment, providers must bill using ICD-10 codes for services rendered on or after October 1, 2015. Check the National Coverage Determination (NCD) and Local Coverage Determination (LCD) policies in the Medicare Coverage Database to find out which ICD-10 codes support medical necessity. See the announcement for more information. THE POHMS NEWSLETTER - DEC 2015 - Issue 23 Page 9 New FAQs on Participation in EHR Incentive Programs HOME On October 6, CMS released the final rule with comment for the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs. CMS also released three new FAQs, providing clarification on how to attest to certain measures for health information exchange, patient electronic access, and other objectives that require patient action. CMS MEDICARE For the Health Information Exchange objective for meaningful use in 2015 through 2017, may an Eligible Professional (EP), eligible hospital, or critical access hospital count a transition of care or referral in its numerator for the measure if they electronically create and send a summary of care document using their Certified EHR Technology (CEHRT) to a third party organization that plays a role in determining the next provider of care and ultimately delivers the summary of care document? See FAQ 12817. If multiple EPs or eligible hospitals contribute information to a shared portal or to a patient's online Personal Health Record (PHR), how is it counted for meaningful use when the patient accesses the information on the portal or PHR? See FAQ 12821. In calculating the meaningful use objectives requiring patient action, if a patient sends a message or accesses his/her health information made available by their EP, can the other EPs in the practice get credit for the patient’s action in meeting the objectives? See FAQ 12825. Medicare Quality Reporting Programs: 2016 Physician Fee Schedule Call — Register Now Tuesday, December 8 from 1:30-3pm ET To Register: Visit MLN Connects Event Registration. Space may be limited, register early. During this call, find out how the 2016 Medicare Physician Fee Schedule final rule impacts Medicare Quality Reporting Programs. A question and answer session will follow the presentation. READ MORE EHR Incentive Programs: Recording from Final Rule Webinar Available The presentation and webinar recording from the Electronic Health Record (EHR) Incentive Programs webinar on the final rule are available on the 2015 Program Requirements web page. The October 8 webinar covered: THE POHMS NEWSLETTER - DEC 2015 - Issue 23 Page 10 Overview of the final rule Requirements for 2015 through 2017 (Modified Stage 2) Stage 3 requirements for 2018 and beyond What you need to know to participate in 2015 New CMS resources HOME CMS MEDICARE Recent LearnResource & MedLearn Matters Articles Notice POHMS Members… If there is a specific Payer you would like included in this newsletter, please email the editor, Michelle Weiss at Michelle@weissconsulting.org OPEN ENROLLMENT REMINDER Medicare Advantage Plan - October 15 – December 7 o Changes from Medicare to MR Advantage o From Advantage to a different Advantage o Join a Medicare Prescription Drug Plan o Switch or cancel Prescription Drug Plans Medicare Advantage Disenrollment Period - January 1 – February 14 o Leave MA plan and switch to original Medicare Health Insurance Marketplace - November 1 – January 31, 2016 o Join or switch plans THE POHMS NEWSLETTER - DEC 2015 - Issue 23 Page 11 2016 Value Modifier Informal Review Deadline Extended to December 16 2016 PQRS Payment Adjustment: Informal Review Deadline Extended to December 16 Medicare Coverage of Screening for Lung Cancer with Low Dose Computed Tomography (LDCT) Update to the List of Compendia as Authoritative Sources for Use in the Determination of a "Medically-Accepted Indication" of Drugs and Biologicals Used Off-label in an Anti-Cancer Chemotherapeutic Regimen Claim Status Category and Claim Status Code Update Implement Operating Rules - Phase III ERA EFT: CORE 360 Uniform Use of Claim Adjustment Reason Codes (CARC) and Remittance Advice Remark Codes (RARC) Rule - Update from CAQH CORE New Influenza Virus Vaccine Code Quarterly Update in the Medicare Physician Fee Schedule Database (MPFSDB) - October CY 2015 Update Changes to the Laboratory National Coverage Determination (NCD) Edit Software for January 2016 Medicare Remit Easy Print (MREP) Upgrade Internet Only Manual Updates to Pub. 100-01, 100-02 and 10004 to Correct Errors and Omissions (2015) Reporting Principal and Interest Amounts When Refunding Previously Recouped Money on the Remittance Advice (RA) HOME OTHER PAYER UPDATES Independence medical record requests and ePASS® submissions now using EFT for payments PARTNERS IN HEALTH UPDATE December 2015 Posted December 1, 2015 - Payments issued on or after November 1, 2015, for medical record requests and SOAP Progress Note submissions through ePASS, will be processed and distributed through electronic funds transfer (EFT). We will continue to send paper checks for those providers who are not EFT-enabled; however, we encourage all providers to sign up for EFT. If you are interested in receiving payment via EFT, please follow the instructions in our EFT Attestation and Registration Guide, which is available in the NaviNet® Resources section of the Provider News Center. If you have any questions on the EFT registration process, contact the eBusiness hotline at 215-640-7410. Reminder: Upcoming changes to drug precertification requirements for 2016 Posted October 30, 2015 Effective January 1, 2016, new precertification requirements will apply to our commercial and Medicare Advantage HMO and PPO members for the seven medical benefit drugs listed below: READ MORE Notification - IV Bortezomib (Velcade) Updated policy effective 1/5/2016 This policy was updated to be consistent with US Food and Drug Administration (FDA) Labeling and Drug Compendia. New/Updated Policies that may affect oncology practices.... 08.00.83e, Pralatrexate (Folotyn®) for Injection Effective: 11/04/2015 | Posted: 11/04/2015 08.00.99b, Belimumab (Benlysta®) Effective: 11/04/2015 | Posted: 11/04/2015 Type of policy change: Medical Necessity Criteria; Medical Coding; General Description, Guidelines, or Informational Update Current Issue Available HERE 06.02.10n, Genetic Testing for Inherited Susceptibility to Colon Cancer and Microsatellite Instability Testing (Familial Adenomatous Polyposis and Lynch Syndrome) Effective: | Posted: 11/06/2015 Type of policy change: General Description, Guidelines, or Informational Update 08.00.88c, Ofatumumab (Arzerra™) Notification: 10/30/2015 | Effective: 11/30/2015 | Posted: 11/30/2015 Type of policy change: Medical Necessity Criteria; Medical Coding; General Description, Guidelines, or Informational Update READ MORE THE POHMS NEWSLETTER - DEC 2015 - Issue 23 Page 12 READ MORE Current Issue Available HERE HOME FOUR CODES TO BE ADDED TO LIST OF PROCEDURES REQUIRING AUTHORIZATION, EFFECTIVE 1/1/16 OTHER PAYER UPDATES Effective with dates of service of Jan. 1, 2016, and beyond, we will revise our list of outpatient procedures/services requiring authorization to add four procedure codes. The procedure codes are listed in the chart below. (Please note: The codes will not require authorization and will not appear on the all-inclusive authorization list on the Provider Resource Center until the effect. date, 1-1-2016 CODE DESCRIPTION J0894 J9025 63005 J7327 INJECTION, DECITABINE, 1 MG INJECTION, AZACITIDINE, 1 MG LAMINECTOMY WITH EXPLORATION AND/OR DECOMPRESSION OF SPINAL CORD AND/OR CAUDA EQUINA, WITHOUT FACETECTOMY, FORAMINOTOMY OR DISCECTOMY, (E.G., SPINAL STENOSIS), ONE OR TWO VERTEBRAL SEGMENTS; LUMBAR, EXCEPT FOR SPONDYLOLISTHESIS HYALURONAN OR DERIVATIVE, MONOVISC, FOR INTRA-ARTICULAR INJECTION, PER DOSE UPMC, Highmark divorce ends with key ruling November 30, 2015 11:33 PM By Kris Mamula / Pittsburgh Post-Gazette Seniors with Highmark’s Medicare Advantage plan coverage will continue to have in-network access to UPMC hospitals and doctors, the state Supreme Court ruled Monday, marking the final break in relations between the two health care giants. READ MORE Arbitrators side with UPMC; Highmark must pay $188 million for cancer care By Wes Venteicher Tuesday, Nov. 10, 2015, 3:54 p.m. An arbitration panel sided with UPMC over rival Highmark Inc. in a $188 million contract dispute related to cancer care payments, according to documents UPMC filed Tuesday with a municipal regulator. READ MORE CLICK HERE CLICK HERE THE POHMS NEWSLETTER - DEC 2015 - Issue 23 Page 13 CLICK HERE HOME Provider Resource Center Update Highmark continues to bring innovative products to the marketplace, with a strong brand and strong networks. We've created this page to give you, our network providers, convenient access to summary information on our product lines for 2016, for both Commercial and Medicare Advantage. See links below, and please share this information with your administrative, billing and clinical staff. Thank you, as always, for your ongoing support and commitment to serving our members. OTHER PAYER UPDATES Most Recent Issue …CLICK HERE 2016 Commercial Products Summary- Coming Soon! 2016 Medicare Advantage Products Summary NEW! NEW! A Few Articles You Won’t Want to Miss: A Few Articles You Won’t Want to Miss: UnitedHealthcareOnline.com Claim Reconsideration to be Retired Reminder: Genetic Counseling Requirement Effective Jan. 1, 2016 Revision to Place of Service 22 and New POS 19 UnitedHealthcare Oxford Medical and Administrative Policy Updates o Drug Coverage Guidelines o Injectable Chemotherapy Drugs: Application Of NCCN Clinical Practice Guidelines o And more…… Reminder: Chemotherapy Prior Authorization Requirement Effective for UnitedHealthcare Oxford And Much More… DECEMBER Monthly Issue Available HERE THE POHMS NEWSLETTER - DEC 2015 - Issue 23 Page 14 Updates to our National Precertification List…pg 1 o Effective 1/1/2016 - Includes: Temodar, Xeloda, Cyramza, and Granulocyte Precertification required for Medicare Part B immunologic drugs…pg 2 Get precert forms on our website…pg 3 2015 Centers for Medicare & Medicaid Services compliance requirements… pg 6 And Much More…. DECEMBER Northeast Region Qtly Issue Available HERE DRUG SHORTAGES – HOME If you are looking for a complete list of Drug Shortages from the FDA CLICK HERE. OTHER NEWS RECENT FDA ONCOLOGY RELATED APPROVALS/CHANGES FDA approved elotuzumab (EMPLICITI, Bristol-Myers Squibb Company) in combination with lenalidomide and dexamethasone for the treatment of patients with multiple myeloma who have received one to three prior therapies. More Information. November 30, 2015 FDA granted approval to necitumumab (PORTRAZZA, Eli Lilly and Company) in combination with gemcitabine and cisplatin for first-line treatment of patients with metastatic squamous non-small cell lung cancer (NSCLC). Necitumumab is not indicated for treatment of non-squamous NSCLC. More Information. November 24, 2015 FDA approved nivolumab (Opdivo Injection, Bristol-Myers Squibb Company) for the treatment of advanced renal cell carcinoma in patients who have received prior anti-angiogenic therapy. More Information. November 23, 2015 FDA approved ixazomib (NINLARO, Millennium Pharmaceuticals, Inc., a wholly owned subsidiary of Takeda Pharmaceutical Company Limited) in combination with lenalidomide and dexamethasone for the treatment of patients with multiple myeloma who have received at least one prior therapy. Ixazomib is the first approved oral proteasome inibitor. More Information. November 20, 2015 FDA granted accelerated approval to daratumumab injection (DARZALEX, Janssen Biotech, Inc.), administered as a single agent for the treatment of patients with multiple myeloma who have received at least three prior lines of therapy, including a proteasome inhibitor (PI) and an immunomodulatory agent, or who are double-refractory to a PI and an immunomodulatory agent. More Information. November 16, 2015 FDA granted accelerated approval to osimertinib (TAGRISSO) once daily tablets, AstraZeneca Pharmaceuticals LP, for the treatment of patients with metastatic epidermal growth factor receptor (EGFR) T790M mutation-positive non-small cell lung cancer (NSCLC), as detected by an FDA-approved test, who have progressed on or after EGFR tyrosine kinase inhibitor (TKI) therapy. More Information. November 13, 2015 Continued on next page… THE POHMS NEWSLETTER - DEC 2015 - Issue 23 Page 15 FDA approved cobimetinib (COTELLIC Tablets, Genentech, Inc.) for the treatment of patients with unresectable or metastatic melanoma with BRAF V600E or V600K mutation, in combination with vemurafenib. Cobimetinib is not indicated for treatment of patients with wild-type BRAF melanoma. More Information. November 10, 2015 OTHER NEWS HOME Express Scripts to Calculate 'Blended' Drug Prices (BioCentury) Nov 20, 2015 - Express Scripts Holding Co. CMO Steve Miller said the company will create a "blended price" for drugs as part of its new indication-based pricing scheme. READ ARTICLE » Helping Patients Battle the Financial Toxicity of Cancer Treatments (Medscape Oncology) Nov 20, 2015 - In recent years, the financial toxicity associated with cancer treatments has stepped out of the shadows and into the spotlight. READ ARTICLE (free registration required) » Ready for 2016 Medicare Reimbursement Changes? Changes under the 2016 Outpatient Prospective Payment System (OPPS) and the 2016 Physician Fee Schedule (PFS) final rules go into effect Jan. 1, 2016—just six weeks away. Is your program or practice ready? ACCC has tools to help. Read in-depth analyses of both rules and listen to a recording of the Nov. 19 ACCC conference call with legal experts Beth Roberts, Partner, and Beth Halpern, Partner, Hogan Lovells, US LLP. CLICK HERE (login required). Payer and Policy Maker Steps to Support Value-Based Pricing for Drugs FREE Peter B. Bach, MD1; Steven D. Pearson, MD JAMA. Published online November 30, 2015 Prescription drugs is the only major category of health care services for which the producer is able to exercise relatively unrestrained pricing power. By law, drug manufacturers can set the price that Medicare and Medicaid programs pay for new drugs….READ MORE Read the Oncology Issues' detailed 2016 Oncology Coding & Reimbursement Update from Cindy Parman, CPC, CPC-H, RCC — available here online ahead of print. ASCO in Action Brief: MACRA How to decipher confusing ICD-10 codes CLICK HERE TO READ ARTICLE (ASCO in Action) Nov 13, 2015 - The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) passed earlier this year, effectively repealing the sustainable growth rate (SGR) and introducing comprehensive changes in how Medicare pays physicians for services. THE POHMS NEWSLETTER - DEC 2015 - Issue 23 Page 16 READ PRESS RELEASE Reimbursement Questions & Answers HOME If you have reimbursement questions you need answers to, please submit them to pohmsbilling@gmail.com FAQ’S QUESTION: We are a private practice that was purchased by the hospital. I am not sure if we need to use the new place of service codes for our claims. How do I know? ANSWER: This is challenging to answer without knowing more about your practice. You will also need to check with your legal counsel. Generally, if you are currently billing ALL your services on the CMS1500 form, including drugs and administration codes, then you are most likely a true private practice. If you are billing the E & M services on the CMS1500 form and your administration codes and drugs on the UB04 claim form, they you are most likely a “Provider Office Department” of the outpatient hospital and therefore would need to begin billing your CMS1500 E & M claims as a position “19”, Off-Campus Outpatient Hospital. You do not use this place of service code on the non-E & M services, but you will need to append a PO modifier on each and every line of service billed on the UB04 claim form. CLICK HERE for a reference to the Place of Service codes, CLICK HERE for a reference to the PO Modifier. ******************************* QUESTION: We’ve certainly heard the buzz about the off campus payments from Medicare going down. When is this going to happen? Does it begin in 2016? How do we know if this affects us? Where can I find more information? ANSWER: This change will be effective for Medicare payments beginning January 1, 2017. It will apply to hospital-owned physician practices acquired or opened since the signing of the Bipartisan Budget Act of 2015 on November 2, 2015 AND farther than 250 yards from a hospital’s main campus. If your hospital/practice arrangement was prior to the enactment of this law, then you will be grandfathered and this change will not affect you. CLICK HERE for a good reference article on this subject. ******************************* QUESTION: How do I go about getting a regimen added to NCCN Guidelines or Compendia so we can be reimbursed by Medicare for the service? I can’t remember the process. Thanks so much. ANSWER: Below you will find information on how to submit a request to have consideration of something added to NCCN; THE POHMS NEWSLETTER - DEC 2015 - Issue 23 Page 17 Continued on next page… Reimbursement Questions & Answers HOME FAQ’S Submission Requests External parties are invited to submit requests for specific issues or topics to be discussed by the NCCN Guidelines Panel. Examples of such parties include industry, clinicians outside the Member Institutions, patient advocates, and/or payers. Requests must be submitted at least 3 weeks prior to the scheduled Panel meeting for the specific NCCN Guidelines to allow for the Panel Chair to review the content of the requests and for the submission materials to be distributed to the Panel Members, as needed. Information on the Submission Requests process for external parties is available on the NCCN website. As part of the NCCN practices to ensure transparency, the changes to recommendations for use of drugs and biologics requested in the Submission Request are listed in the transparency document along with the actions taken by the Guidelines Panel. Additionally, the original Submission Request materials are posted to the NCCN website at the time of posting of the transparency document. CLICK HERE to link to that page of NCCN and the explanation about the panel, etc. ******************************* QUESTION: Where do we find the guidelines for Locum Tenens? ANSWER: The guidelines are found in the CMS Medicare Claims - Processing Manual (Pub. 100-04), chapter 1, section 30.2.11 ******************************* QUESTION: We are VERY nervous billing for any visit on the same day as chemotherapy because of the modifier 25 abuse issue. What is the safest way to document the “separately identifiable” visit and be able to bill? ANSWER: My recommendation would be to CLEARLY document the reason you would charge for a visit above what is already paid for when billing for a chemotherapy administration. The initial infusion code includes a minimal exam to evaluate the patient to make sure they are clinically able to receive chemotherapy, “affirmation of care”. For example the minimal exam could include; a minimal exam, review of labs, decision to proceed with treatment, etc. Having a physician face to face with the patient vs a nurse doesn’t make it ok to bill for this service. If the patient is being evaluated for something unrelated to the infusion, then the “chief complaint” or reason for visit should clearly reflect that and the “Medical Decision Making” portion THE POHMS NEWSLETTER - DEC 2015 - Issue 23 Page 18 Continued on next page… Reimbursement Questions & Answers HOME FAQ’S of the note should be related to that unrelated condition. Additionally, the level of service billed should ONLY be related to the “additional” work performed. ******************************* QUESTION: If a patient comes to the office and just talks with the doctor to decide what they are going to do next, can we bill for the visit? ANSWER: Yes you can, you would score this visit based on the time the physician spent face to face with the patient counseling and coordination of care. You will use the E & M codes, (99212 – 99215) and choose the code that coordinates the amount of time spent. The physician MUST document 1) total amount of time spent counseling and coordinating care face to face with the patient 2) that more than 50% of the visit was spent counseling and coordinating the care 3) a summary of what was reviewed/discussed. If any of the 3 are missing in the documentation, the note cannot be scored based on time. Below is a reference from a CMS Transmittal #178: “A cancer patient has had all preliminary studies completed and a medical decision to implement chemotherapy. At an office visit the physician discusses the treatment options and subsequent lifestyle effects of treatment the patient may encounter or is experiencing. The physician need not complete a history and physical examination in order to select the level of service. The time spent in counseling/coordination of care and medical decision- making will determine the level of service billed. The code selection is based on the total time of the face-to-face encounter or floor time, not just the counseling time. The medical record must be documented in sufficient detail to justify the selection of the specific code if time is the basis for selection of the code.” ******************************* QUESTION: Can a midlevel provider (NP OR PA) bill Medicare using their own NPI when they supervise chemotherapy as long as they are acting within their “scope of care”. Are they allowed to bill for the work the nurses do – “incident to” a midlevel provider? ANSWER: Thank you for your patience while I researched this matter. I also consulted with our Policy staff before sending this response. The licensed/enrolled midlevel provider, acting within his/her state scope of practice, may act as the supervising physician when ancillary staff is administering chemotherapy based on the initial physician's order/plan of care. Of course, all incident to criteria would need be met and the midlevel provider must be working with their legal scope of care. The service would be billed by the midlevel provider. ******************************* QUESTION: We have a patient who is in hospice. The patient (and the family) now want to continue chemotherapy treatment. Will Medicare still reimburse us for the chemo? THE POHMS NEWSLETTER - DEC 2015 - Issue 23 Page 19 DIAMOND LEVEL CORPORATE ALLIES GOLD LEVEL SILVER LEVEL THE POHMS NEWSLETTER - DEC 2015 - Issue 23 Page 20 HOME HOME We hope you enjoyed this month’s issue!! POHMS PAGES Our Mission POHMS strives to bring best practices to oncology hematology members through professional education, network development and availability of accessing the benefits of volume drug purchasing through CHOC, POHMS GPO. POHMS Committees Programs Committee CHAIR: Roxanne Alessandroni Reimbursement & Coding Committee CHAIR: Maryann Wingate Legislative Committee CHAIR: Diane Carter Membership/Membership Development Committee CHAIR: Diane Minter CO-CHAIR: Ellen Bauer Vision Statement The Premier Oncology Hematology Management Society (POHMS) aspires to be the leader of educational resources and a valued partner among oncology healthcare professionals. POHMS Board of Directors Executive Committee Maryann Wingate President Mary Lois Moss Vice President Diane Carter Secretary/Treasurer Values Statement At POHMS, we are committed to the highest standards of ethics and integrity and strongly believe that we are responsible to our members, stakeholders, and to the communities we serve. As a part of our responsibility, we strive to create an environment of continuous learning and improvement in the oncology hematology industry. We are passionate about the success of our members. Our driving innovation and commitment to personal and professional development makes an invaluable resource. Educational programs and professional meetings help foster a network of growth, support, and collaboration. The sharing of ideas and trends enable POHMS to continue to build upon our tradition of innovation. THE POHMS NEWSLETTER - DEC 2015 - Issue 23 Page 21 Board Members Roxanne Alessandroni Kim DiStasio Ellen Bauer Lorey P. Keeney Diane Minter Naren Srivastava