January 24, 2014

CGS Administrators, LLC
Provider Outreach and Education
Part A Advisory Group Meeting Minutes
The minutes below are a summary of the advisory group meeting topics, group discussion, actions, and
outcomes as a result of this meeting.
Meeting Details
Date: January 24, 2014
Facilitator: Judy Thomas, Senior Provider Relations Representative, J15 A/B MAC
Attendees:
CGS
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Annie Scriven, Carol Walter, LJ Smith, Nancy Turner, Gloria Lucas, Judy Thomas
Members
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Mary Alexander, Ohio Health Corporation
Connie Aylward, TriHealth
Jane Arnold, Firelands Regional Medical Ctr.
Sandra Barnes, Baptist Healthcare Systems
Charles Cataline, Ohio Hospital Assoc.
Chris Davis, Mount Carmel Health
Irene Hesseling, Kidney Services of West Central Ohio
Elizabeth Johnson, The Christ Hospital Network
Laura Martucci, Summa Health System
Ilah Naudasher, Kettering Health Network
Angela D. Scott, Russell County Hospital
Fran Savard, Leading Age, Ohio
Rob Sikorski, Davita
Shawn Stack, Wexner Medical Ctr.
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Agenda Items
Welcome: Judy Thomas
New Members and Attendance: Judy Thomas
Purpose and Goals: Judy Thomas
Welcomed everyone to the first meeting of 2014 and added that we have new members as a result of
the membership drive in late 2013. Thanked everyone for their attendance and took roll. Reminded
members of the purpose and goals of the J15 Part A POE-AG.
Hot Topics
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A/B Rebilling: Annie Scriven
o MLN Matters® article MM8185: http://www.cms.gov/outreach-and-education/medicarelearning-network-mln/mlnmattersarticles/downloads/MM8185.pdf
o MLN Matters® article SE1333: http://www.cms.gov/Outreach-and-Education/MedicareLearning-Network-MLN/MLNMattersArticles/downloads/SE1333.pdf
o Reviewed references to the most recent articles applicable to A/B rebilling, and
explained that the ruling applied to inpatient hospital claims that were denied due to
medical review, as well as self-audit claims, mentioned in SE1333. In the Inpatient Final
Rule 1599-F, there was discussion regarding the use of occurrence span code 72. The
NUBC changed the definition for occurrence span code 72, effective 12/1/13. It is
effective and although guidance comes in the final rule, CMS and CGS are required to
comply with the change request, which is in draft form now. Any new or additional
information that can be shared will be posted on our website and sent via listserv.
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FY 2014 IPPS Final Rule and the 2-Midnight Provision: Annie Scriven
o CMS website: http://www.cms.gov/Center/Provider-Type/Hospital-Center.html
o CMS continues to issue guidance via Special Open Door Forum calls. The short
inpatient hospital stay reviews conducted by the Recovery Auditor and CGS resulted in
numerous denials and backlogs in the appeals process. Therefore, the intent of the
ruling was to clarify the guidelines on when to admit a patient as an inpatient. The most
recent information is available on the CMS Hospital Center website, which includes
links to FAQs, the Final Rule, and the physician certification information. CGS was in
the process of scheduling events at facilities who requested additional guidance about
the 2-Midnight Rule; however, CMS conducted a call with all contractor medical review
departments, and indicated they would be issuing additional guidance regarding the rule
and A/B rebilling. Therefore, all events are currently on hold. Chris Davis questioned if
anyone else was experiencing issues when billing 121 and 131 types of bills on the
same date of service. Annie asked Chris to send examples for research. Other issues
regarding the instructions for timely filing of A/B rebill claims were also discussed. CGS’
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interpretation is that the last adjudication date should be used as reference for timely
filing.
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Incarcerated Beneficiaries: Annie Scriven
o CMS FAQs: http://www.cms.gov/Medicare/MedicareContracting/FFSProvCustSvcGen/Downloads/Incarcerated-Bene-FAQS.pdf
o Claim recoupments occurred in summer of last year due to an OIG finding. A system to
prevent incorrect payment to incarcerated beneficiaries was made, but incorrect data was
used which resulted in incorrect claim recoupments. CMS has been working with
contractors on the issue. The database was corrected in October 2013. In December,
CGS issued checks and provided a spreadsheet that lists the claims recouped in error to
assist in the reconciliation of the payments. Unfortunately, the spreadsheet only includes
a total check amount that could also reflect offsets other than the incorrectly denied
claims. Although claim adjustments will not occur until April, the individual claim amounts
can be obtained from the denied claim in Direct Data Entry (DDE). If you have
researched and still have a question, you may contact the PCC. Rob Sikorski mentioned
that he had contacted the PCC and was told return calls would be made within 10 days.
Charles Cataline asked if we could outline the process on the CGS website.
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Jimmo vs. Sebelius: Carol Walter
MLN Matters® article MM8458 http://www.cms.gov/Outreach-and-Education/MedicareLearning-Network-MLN/MLNMattersArticles/Downloads/MM8458.pdf
o The terms of the settlement do not include an explicit reference to documentation
requirements as such; but CMS has decided to use this opportunity to introduce
additional guidance regarding documentation, both generally and as it relates to
particular clinical scenarios. An example of this material appears in a new Section
30.2.2.1 of the MBPM’s revised Chapter 8, in the guidelines for SNF coverage under Part
A.
Justification for treatment would include, for example, objective evidence or a clinically
supportable statement of expectation that:
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With rehabilitative therapy, the patient’s condition has the potential to improve or is
improving in response to therapy; maximum improvement is yet to be attained;
and, there is an expectation that the anticipated improvement is attainable in a
reasonable and generally predictable period of time.
With maintenance therapy, the skills of a therapist are necessary to maintain,
prevent, or slow further deterioration of the patient’s functional status, and the
services cannot be safely and effectively carried out by the beneficiary personally
or with the assistance of non-therapists, including unskilled caregivers.
OLD BUSINESS
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Clinical Trial Numbers: Judy Thomas
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MLN Matters® article SE1344: http://www.cms.gov/Outreach-and-Education/MedicareLearning-Network-MLN/MLNMattersArticles/Downloads/SE1344.pdf
Stated this was suggested as a PCC training topic in the last POE-AG meeting and that
POE has verified with PCC that training was received. Since then, an updated Special
Edition article has been produced with information on where the information should be
placed and a placeholder to use if information is not available. This placeholder is only
valid until December 31, 2014.
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POE-AG Meeting Locations: LJ Smith
o Face-to-face meetings are scheduled on May 9, 2014 and November 7, 2014.
Previously proposed locations were Cleveland, Columbus, Lexington, and Louisville.
Proposed locations were discussed again to come to a consensus as to which cities to
hold the meetings in and allow for other suggestions. Charles Cataline mentioned that it
is difficult for folks in Kentucky to join Columbus, but his location is always available.
Sandy Barnes mentioned that she would like to have one in Kentucky and other
members offered venues. She indicated that she would look into the Lexington location.
A decision will be made and sent out to everyone when it is finalized.
New Business
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ICD-10 Testing: Carol Walter
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Registration Site:
http://www.cgsmedicare.com/medicare dynamic/edi/IDC10 testing registration.asp
Provided the link and announced that CEM will take place. The registration site should
be completed with the use of the radio button. Once completed and submitted,
notification will be sent if accepted. There is a check list for testing and should be
received within the week. Rob Sikorski suggested adding a link on the ICD-10 web
page.
EDI department representatives participated in the POE-AG call to help answer the
following questions:
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Q. Will CGS be testing with Trading Partners?
A. Yes. Anyone can test with CGS.
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Q. Will there be end-to-end testing for ICD-10 with CGS?
A. None is scheduled at this time. We are only scheduled for CEM testing in
March.
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Q. If it’s only CEM testing, is the CEM module the same that all MACs use?
A. Yes. The CEM module is the same one used by all MACs. If you’ve tested
with one, you’ve tested with all. All you will receive with CEM testing is a 999
or 277CA response only. There will be no remits. This is only for front end
testing.
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Q. Does DDE pass through CEM?
A. No. DDE claims are treated like paper claims.
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FAQs Update: LJ Smith
o CGS FAQ website: http://www.cgsmedicare.com/parta/help/faqs/index.html
o FAQs are reviewed quarterly and were last updated December 13, 2013. The FAQs are
based on PCC, Correspondence, Appeal inquiries and common questions asked during
POE events. Urged members to review and note what has been updated and the new
FAQs on the website (i.e., A/B Rebilling). Invited suggestions for new FAQs.
Charles Cataline asked about OPPS lab bundling in relation to MM8572. This topic will be
included in the OPPS ACT scheduled for January 29, 2014 (update: included in the subject
matter during the call.). Charles indicated he would send an email with FAQs to LJ and she
would forward. Shawn Stack inquired about submitting on a 14X type of bill. Some members
expressed that there were issues, but it was mentioned that they had rebilled and had
received payment on the 14X type of bills.
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Website Enhancements: Carol Walter
o myCGS: http://www.cgsmedicare.com/parta/myCGS/PartA RedeterReq myCGS.pdf
o eOffsets are in the testing phase for myCGS, and redeterminations are already
functional. A job aid has been linked. The ability to appeal is important to consistency of
offices and the best way to do this is through myCGS. There will be a Part A/Part B POE
Redetermination ACT on February 20.
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Calendar of Events: LJ Smith
o Part A Calendar of events link:
http://www.cgsmedicare.com/parta/education/oh/index.html
o A list of 2014 educational venues is published on the CGS website. Providers can click
on the event and the registration page will appear. Members were asked for suggestions
on new training tops. No new topics were suggested. Members are always welcome to
send suggestions at a later date. Discussion about available lines arose. Situations
have been encountered to where no lines were available. CGS can always add lines, but
can’t decrease lines once they have been reserved. Encouraged members to share with
others that one line be used in group settings. POE will stress this option in future
announcements. POE will also address this internally with our vendor. Announced a
POE planning meeting in March. If members have suggestions about topics, email the
POE team.
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Training Needs (Provider and PCC): LJ Smith
o Asked members for input on provider or PCC training needs. Charles Cataline indicated
that he isn’t hearing about any issues lately, and no news is good news. He wanted to
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congratulate CGS. POE is traveling to Columbia on February 17 to train the PCC and
his comments will be shared with the PCC. Members are encouraged to send topics to
the POE team if there are ideas.
Open Discussion: Judy Thomas
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Charles Cataline mentioned the CGS audit on physician claims and asked for any suggestions
on how to work with them. Annie suggested a Part B counterpart, and Charles stated he would
contact Deanna Cruser.
The MSP issue of U6805 was corrected and removed from the CPIL. Providers indicated that
they were having success with claims being processed. One member mentioned they were
finding an issue of claims not being released if the spelling on the claim isn’t exactly as what is
in the CWF. Judy asked the member to send examples and she would review the issue.
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Q. Is the FB modifier still valid for replaced devices or any devices at no cost?
A. The FB and FC modifiers are no longer recognized by the OPPS as of January 1,
2014. CMS MLN Matters® article MM8572 includes instructions for use of the new
value code FD.
http://cms.gov/Outreach-and-Education/Medicare-Learning-NetworkMLN/MLNMattersArticles/Downloads/MM8572.pdf
Next Meeting: Judy Thomas
The next meeting will be a face-to-face, Friday, May 9, 2014 from 10 a.m. – 3 p.m. ET. The venue will
be communicated via email.
Adjourn: Judy Thomas
Everyone was thanked again for their participation and input. Advised members that 2013 was a very
successful year and POE was looking forward to another successful year in 2014.
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