Table of Contents Title Slides Title Page Disclaimer Disclaimer Continued Introduction Webinar Outline Webinar Requirements Webinar Protocol Webinar Objective Sample CBR CBR Purpose Focus Demographics Webinar Materials Acronyms Coverage and Documentation Overview Topic Selection Other Investigations False Claims Act What is a Modifier Modifier 25 Surgical Package 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 1 Minor Procedures Major Procedure Medicare Physician Fee Schedule Database (MPFSDB) Determine the Global Period Global Periods Correct Use of Modifier 25 Incorrect Use of Modifier 25 Documentation American Academy of Family Physicians (AAFP) IPPE or AWV on Same Day as an E/M Service Allowed Time for E/M Services Use of Time to Determine the Level of E/M Service References Evaluation and Management Services Surgeons and Global Surgery NCCI Policy Manual Office of Inspector General Methods and Results Report Data Peer Groups Data Source Table 1 Understanding Table 1 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 2 Comparison Outcomes Percentage of Claim Lines with Modifier 25 Table 2 Calculating Percentage of Claim Lines with Modifier 25 Average Allowed Minutes per Visit Average Allowed Minutes per Visit with Modifier 25 and without Modifier 25 Table 3 Average Allowed Charges per Beneficiary Table 4 Calculating Average Allowed Charges per Beneficiary Resources CBR Webinar FAQs Additional Resources Next Steps Provider Self‐audit Contact Information CBR Support Help Desk Questions and Answers Contacting MACs NPPES 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 3 CBR201409 Modifier 25: Family Practice 4 The CBR project has made every reasonable effort to ensure the accuracy of the information and web links provided in the CBR materials at the time of publication; however, Medicare policy changes frequently, so the information and links within the material may change without further notice. It is the responsibility of the provider to remain up-to-date with Medicare Program requirements. 5 CBR materials are prepared as a service to the public and are not intended to grant rights or impose obligations. The information provided in the CBR material is only intended to be a general summary. It does not supersede or alter the coverage and documentation policies outlined in the local coverage determinations (LCD) and policy articles for the A/B Medicare Administrative Contractors (MAC) or DME Medicare Administrative Contractors (DME MAC). Please refer any specific questions you may have to the A/B or DME MAC for your region. We encourage providers to review the specific statutes, regulations, and other interpretive material for a full and accurate statement of their contents. 6 Webinar Outline 1. Introduction 2. Coverage & Documentation Overview 3. References 4. Methods & Results 5. Resources 6. Next Steps 7. Contact Information 8. Q&A 9. Survey 7 Webinar Requirements Landline for conference call (cell phones are not recommended) Wired (not wireless) broadband internet connection PC computer using Windows or Mac operating system Android or iPad tablets Latest version of Adobe Flash installed 8 Webinar Protocol All attendee lines are muted Submit questions via chat when prompted by speaker Submit questions during the Q&A session at the end of webinar Ask questions pertinent to webinar Contact MAC for specific claims questions 9 Webinar Objective Upon completion of this webinar the participant should be able to: Demonstrate a general understanding of the CBR for modifier 25 Comprehend the report methods used to develop the report Locate policy references and resources for modifier 25 10 Sample CBR Provided for each topic http://www.cbrinfo.net/ 11 CBR Purpose Designed to: Provide education to the provider community Compare billing practices among Medicare providers and their peer groups The CBR does not: Imply any assumption of wrong-doing Serve as a pre-cursor to an audit 12 Focus This CBR examines: Percentage of claim lines with modifier 25 appended Average allowed minutes per visit for claim lines with modifier 25 and without modifier 25 Average allowed charges per beneficiary 13 Demographics 10,000 providers Data from claims paid by traditional Fee For Service (FFS) Medicare Billing patterns different from their peers 14 Webinar Materials References and Resources Webinar slides MP4 of webinar Webinar Handout Webinar Q&A Handout Recommended Links: http://www.cbrinfo.net/cbr201409-recommended-links.html Resources from event: http://www.cbrinfo.net/cbr201409-webinar.html 15 Acronyms AAFP: American Academy of Family Physicians AWV: Annual Wellness Visit CBR: Comparative Billing Report CPT: Current Procedural Terminology E/M: Evaluation and Management IPPE: Initial Preventive Physical Exam NCCI: National Correct Coding Initiative OEI: Office of Evaluation and Inspections OIG: Office of Inspector General 16 Coverage & Documentation Overview 17 Topic Selection Office of Inspector General (OIG) http://oig.hhs.gov Use of Modifier 25, November 2005, OEI–07–03– 00470 Medicare requirements not met: 35% of services Improper payments: Estimated at $538 million In 2002, Medicare allowed $1.96 billion for approximately 29 million claims billed http://oig.hhs.gov/oei/reports/oei-07-03-00470.pdf 18 Other Investigations New York State, Office of the State Comptroller United HealthCare: Certain Claim Payments for Evaluation and Management Services, April 2012, Report 2010–S–67 Audited: Results: New York State Health Insurance Program claims 12.6% did not meet requirements for appending the 25 modifier http://osc.state.ny.us/audits/allaudits/093012/10s67.pdf 19 False Claims Act The United States Attorney’s Office, Northern District of Georgia Leading Oncology Practice to Pay $4.1 Million to Settle False Claims Act Investigation, Press Release: September 19, 2012 Settlement with Georgia Cancer Specialists I, PC 27 offices in Atlanta metro area $4.1 million for violations of the False Claims Act http://www.justice.gov/usao/gan/press/2012/09-19-12b.html 20 What is a Modifier? CPT® modifiers: Provide the means to report or indicate that a service or procedure that has been performed has been altered by some specific circumstance but not changed in its definition or code Append CPT® and HCPCS codes to add specificity Two types: Level I (CPT®) and Level II (HCPCS) 21 Modifier 25 Used to support a “significant, separately identifiable evaluation and management service by the same physician or other qualified health care professional on the same day of the procedure or other service” American Medical Association: http://www.ama-assn.org/ama/pub/physician resources/solutions-managing-your-practice/ coding-billing-insurance/cpt.page 22 Surgical Package Always includes: Local infiltration, metacarpal/metatarsal/digital block or topical anesthesia Subsequent to the decision for surgery, one related E/M encounter on the date immediately prior to or on the date of procedure (including history and physical) Immediate post-operative care, writing orders, post anesthesia care and routine follow up CPT® Assistant Articles: http://www.findacode.com/cpt/cpt-assistant/index.html 23 Minor Procedures Global period of 000 or 010 days: a minor surgical procedure In general, E/M services on the same date of service as the minor surgical procedure are included in the payment for the procedure Example: removal of a foreign body from the hip 24 Major Procedure Global period of 090 days: defined as a major surgical procedure Evaluation and management services performed on the same day as the procedure are payable, when reported with modifier 57, if the E/M was done in order to determine the need for the surgery Example: total hip replacement 25 Medicare Physician Fee Schedule Database (MPFSDB) Instructions: http://www.cms.gov/a pps/physician-fee schedule/help/Medicar e-Physician-Fee Schedule-Search Help.pdf 26 Determine the Global Period Medicare Physician Fee Schedule Database: http://www.cms.gov/apps/physician-fee-schedule/overview.aspx 1. Select “Physician Fee Schedule Search” Screen defaults to current year 2. Under “Type of Information,” select “Payment Policy Indicators” 3. Choose a single code/multiple codes/code range Then enter the appropriate code(s) 4. Select a modifier or “All Modifiers” 5. Refer to the column heading “Global” 27 Global Periods 000: Zero global days 010: Ten global days 090: Ninety global days XXX: Global concept does not apply YYY: Defined by A/B MAC ZZZ: Related to another procedure MMM: Maternity codes, usual global period does not apply 28 Correct Use of Modifier 25 The patient was evaluated for treatment of neck pain and insomnia: Trigger point injections were administered to three muscles for neck pain CPT® code 20553: trigger point injections (000 global days) The patient was also evaluated for new onset of insomnia and meds were prescribed CPT® code 99213–25: evaluation and treatment of insomnia 29 Incorrect Use of Modifier 25 The patient was seen for a second appointment for a non-healing wound: Physician debrided the skin and subcutaneous tissue CPT® code 11042 only No other conditions were addressed Documentation reflected only the physician’s time, examination and medical decision making to determine the need for the debridement Do not submit CPT® code 99213–25 30 Documentation Auditors should be able to see the additional work that was involved Documentation must support: History Exam Knowledge Work time Risk Above and beyond what is usually required for the surgery or procedure 31 American Academy of Family Physicians (AAFP) The key components of a problem-oriented E/M service for the complaint or problem must be documented The problem/complaint must stand alone in order to be a billable service A different diagnosis is not required If same diagnosis, documentation must support extra work above and beyond pre- or post-operative work associated with the procedure Understanding When to Use Modifier-25: http://www.aafp.org/fpm/2004/1000/p21.html 32 IPPE or AWV on Same Day as an E/M Service IPPE (“Welcome to Medicare” visit) or AWV: Modifier 25 is not appended No part of the IPPE or AWV documentation can be used toward the medically necessary E/M Additional E/M service: Modifier 25 is appended to the additional E/M service 33 Allowed Time for E/M Services CPT® Code Allowed Time E/M Level 99211 5 minutes Minimal problem 99212 10 minutes Self-limited or minor 99213 15 minutes Low to moderate severity 99214 25 minutes Moderate to high severity 99215 40 minutes Moderate to high severity 34 Use of Time to Determine the Level of E/M Service “When counseling and/or coordination of care dominate (more than 50%) of the time a physician spends with a patient during an evaluation and management (E/M) service then time may be considered as the controlling factor to qualify the E/M service for a particular level of care.” Proper documentation must be in the patient’s medical record American Medical Association, CPT® 2013 Professional Edition http://www.amazon.com/2013-Standard-Current-Procedural Terminology/dp/1603596836/ref=sr_1_6?s=books&ie =UTF8&qid=1412807444&sr=1-6 35 References 36 Evaluation & Management Services Medicare Claims Processing Manual, Chapter 12— Physician/Non-physician Practitioners http://www.cms.gov/Regulations-and Guidance/Guidance/Manuals/Downloads/clm104c12.pdf Section 30.6.1—Selection of Level of Evaluation and Management Service Section 30.6.1.1—Initial Preventive Physical Examination (IPPE) and Annual Wellness Visit (AWV) Section 30.6.6—Payment for Evaluation and Management Services Provided During Global Period of Surgery 37 Surgeons and Global Surgery Medicare Claims Processing Manual, Chapter 12— Physician/Non-physician Practitioners http://www.cms.gov/Regulations-and Guidance/Guidance/Manuals/Downloads/clm104c12.pdf Section 40.1—Definition of a Global Surgical Package Section 40.2—Billing Requirements for Global Surgeries 38 NCCI Policy Manual National Correct Coding Initiative (NCCI) Policy Manual for Medicare Services, Revision Date: January 01, 2014 http://www.cms.gov/Medicare/Coding/NationalCorrectCodInitEd/Downloads/NCCI_ Policy_Manual.zip Chapter I—General Correct Coding Policies Section D—Evaluation and Management (E&M) Services Section E—Modifiers and Modifier Indicators 39 Office of Inspector General Use of Modifier 25, November 2005, OEI–07– 03–00470 http://oig.hhs.gov/oei/reports/oei-07-03-00470.pdf Improper Payments for Evaluation and Management Services Cost Medicare Billions in 2010, May 2014, OEI–04–10–00181 http://oig.hhs.gov/oei/reports/oei-04-10-00181.pdf 40 Methods and Results 41 Report Data Medicare Part B Rendering Provider By National Provider Identifier (NPI) Specialty 08 (Family Practice) CPT® codes 99211–99215 Peer groups Used for comparison with the individual providers 42 Peer Groups State Medicare providers in the provider’s state E/M codes Specialty of 08 National All Medicare providers in the Nation E/M codes Specialty of 08 43 Data Source CMS Integrated Data Repository Extracted: October 14, 2014 Dates of Service: July 1, 2013 – June 30,2014 44 Table 1 Summary of Your Utilization for E/M Codes and Modifier 25 July 1, 2013 – June 30, 2014 45 Understanding Table 1 Summary of Your Utilization for E/M Codes and Modifier 25 July 1, 2013 – June 30, 3014 46 Comparison Outcomes Three possible outcomes 1. Significantly Higher 2. Higher 3. Does Not Exceed 47 Percentage of Claim Lines with Modifier 25 Calculated as follows: 48 Table 2 Percentage of Claim Lines with Modifier 25 July 1, 2013 – June 30, 2014 49 Calculating Percentage of Claim Lines with Modifier 25 Table 1: Summary of Your Utilization for E/M Codes and Modifier 25 July 1, 2013 –June 30, 2014 0 6 90 863 105 ݔ100 ൎ 85 1247 50 Average Allowed Minutes per Visit Calculate total weighted value for each visit and modifier designation: 1. Separate claim lines by modifier designation With modifier 25 Without modifier 25 2. Assign value to each CPT® code by typical minutes 3. Multiply assigned value by number of services 4. Visits with multiple claims are combined 51 Average Allowed Minutes per Visit with Modifier 25 and without Modifier 25 Calculated as follows: 52 Table 3 Average Allowed Minutes per Visit with Modifier 25 and without Modifier 25 July 1, 2013 – June 30, 2014 53 Average Allowed Charges per Beneficiary Calculated as follows: 54 Table 4 Average Allowed Charges per Beneficiary July 1, 2013 – June 30, 2014 55 Calculating Average Allowed Charges per Beneficiary Table 1: Summary of Your Utilization for E/M Codes and Modifier 25 July 1, 2013 –June 30, 2014 121,492.42 ൎ 113.12 1,074 56 Resources 57 CBR Website About Us CBR Releases CBR Support Education Recommended Links FAQs Contact Us http://www.cbrinfo.net/ 58 FAQs General FAQs CBR Specific FAQs CBR201409 Modifier 25: Family Practice http://www.cbrinfo.net/cbr201409-faqs.html 59 Additional Resources Medicare Learning Network®. Global Surgery Fact Sheet, August 2013. ICN 907166 http://www.cms.gov/Outreach-and-Education/Medicare-Learning Network-MLN/MLNProducts/downloads/GloballSurgery-ICN907166.pdf Felger, Thomas A., MD and Marie Felger. Understanding When to Use Modifier-25. Family Practice Management, October 2004. http://www.aafp.org/fpm/2004/1000/p21.html Lansey, Debra. Learn Proper Coding for Modifier 59 and 25. ACP Internist, July/August 2012. http://www.acpinternist.org/archives/2012/07/coding.htm 60 Next Steps 61 Provider Self-audit Providers and suppliers have an obligation to ensure claims are submitted to Medicare correctly Self-audits allow providers and suppliers to identify coverage and coding errors Refer to the following CBR sections for assistance Documentation and Billing References 62 Contact Information 63 CBR Support Help Desk Monday–Friday: 9:00 a.m. to 5:00 p.m. ET Toll Free 1–800–771–4430 Email: [email protected] 64 Contacting MACs Providers should contact the Medicare Administrative Contractor (MAC) for assistance with: Claim Information Documentation Requirements Billing and Coding Locate Your MAC: http://www.cms.gov/Research-Statistics-Data-and Systems/Monitoring-Programs/Medicare-FFS-Compliance Programs/Review-Contractor-Directory-Interactive-Map/ 65 NPPES National Plan and Provider Enumeration System Source for mailing address used for the CBR Correct your mailing information at https://nppes.cms.hhs.gov/NPPES 66 Questions & Answers 67
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