When revalidating through the electronic provider enrollment chain and ownership system (PECOS), you are highly encouraged to print a paper copy of your reenrollment application for your records. However, if you tried to do this recently, you may have noticed that not all of the information you entered into PECOS successfully printed. In fact, the form that prints may look somewhat different than the CMS-855S you are accustomed to seeing.

We have confirmed with CMS that there is a glitch in the PECOS system that occurs when suppliers try to print paper copies of their electronic reenrollment applications. Suppliers should note that this does NOT impact the information that is sent to the NSC. The information you enter into PECOS will still be successfully transmitted to the NSC, once your electronic application is submitted.

On one of the last screens displayed in the PECOS revalidation process, suppliers are given the opportunity to view and print a copy of the completed application. Clicking the print link should produce a prepopulated paper copy of the CMS-855S form that you may keep for your records. However, as of May 1, 2012, a glitch in the system is resulting in applications printing with incomplete fields and missing information. As previously mentioned, while this does create a bit of a headache for suppliers trying to print hard copies, if you can see the information in PECOS and everything looks correct online, it is safe to submit your electronic application to the NSC.

After a little digging, MiraVista was able to confirm that the glitch is the result of PECOS trying to print information to a new, draft version of the CMS-855S form that has not yet been released. You can identify whether PECOS incorrectly printed the draft copy of the CMS-855S by looking for an 04/12 revision date in the lower left-hand corner of each page. This version of the CMS-855S is not yet active, and it is our understanding that PECOS is not set to populate the revised fields in this form.

The active version of the CMS-855S form that should be linked to in PECOS (and that suppliers should use if they opt to submit a paper application) was last updated on July 2011 and can be identified by an 07/11 revision date in the lower left-hand corner of each page. This is the form PECOS is set to populate when printing hard copies of electronic revalidation applications.

We have informed CMS of the issue and have received confirmation that they are looking into a fix. A date has not yet been released for the implementation of the 04/12 draft version of the CMS-855S form. Look for full details on revisions made to the draft form in the June 2012 issue of Vista Notes.

CMS recently completed a series of upgrades to their website that may affect bookmarked links. If you bookmarked a sub-page on the old CMS website, you will be redirected to the new index page for that particular topic. From there, you may access a specific subtopic from a list on the left-hand side of the page and create a new bookmark. For example, if you previously bookmarked the page containing a list of annual Comprehensive Error Rate Testing Contractor (CERT) audit reports, you will now be taken to the main index page for information related to the Comprehensive Error Rate Testing Contractor and will need to click on the “CERT reports” link.

DME Center:

http://www.cms.hhs.gov/Center/Provider-Type/Durable-Medical-Equipment-DME-Center.html

We are cautiously optimistic about a new electronic clinical template CMS is developing for power mobility devices (PMDs). Per an open door forum call on March 21, 2012, the template will allow electronic health record (EHR) vendors to create a series of automated prompts to remind physicians of specific Medicare documentation requirements for PMDs. We say we are cautiously optimistic about the template, because full details on its functionality and application have not yet been provided.

At this time it is unclear whether the template will be implemented as part of the EHR mandate or if its use will be voluntary. For the full benefit to be achieved, we believe that use of the template will need to be mandatory, and that it must be considered an official part of the physician’s medical records. In addition, physicians must not be allowed to bypass the prompts. If implemented in this capacity, the series of prompts will help to ensure that relevant medical necessity information is not left out at the point chart notes are entered into the system.

As of now the template is still in the planning phase. CMS will be setting up a subpage on their website to provide more information on this initiative in the near future. The first in a series of special open door forum calls to discuss the new template will be held today, on April 10, 2012 at 2pm EST. To attend the live event dial: 1-800-837-1935, conference ID: 69286340.

If you are a regular visitor of our site, you may have noticed that we’ve recently had a minor facelift. MiraVista is proud to announce the launch of a new logo that symbolizes our commitment to keeping our clients’ businesses moving forward.

The logo is the brainchild of managing member Derrick Stark, who drafted the initial design. “We aren’t the same company we were nine years ago,” Stark said. “It was time for a change.”

Managing member and DME consultant Andrea Stark agrees. “Like many businesses, our organization has evolved and grown over the years. We needed a logo that better reflects where we are now.”

While we may have a new look, MiraVista will continue to provide suppliers with the same high caliber of educational and billing services they have come to rely on. Be sure to look for our new logo in future marketing materials and educational initiatives!

New Logo

Previous Logo

The DME MACs have released a list serve that has been picked up by several media outlets regarding the information suppliers should include in Item 29 of the claim form. The list serve indicates that: any beneficiary payment collected for the specific covered service, (i.e., coinsurance and deductible) should be reflected with the claim submission. However, we strongly recommend that suppliers refrain from following this guidance, specifically as it relates to coinsurance and deductible amounts, while we seek additional clarification from the DME MACs.

Suppliers have historically been told not to put any dollar amounts in Item 29, unless the patient has remitted payment up front for a non-assigned claim. The reason for this is that when the claims processing system sees a dollar amount in Item 29, it is generally assumed that the patient paid for a covered service and that the patient, not the supplier, should be sent a check for reimbursement.

MiraVista is actively seeking a clarification from the DME MACs regarding this guidance and will provide an update as soon additional information becomes available.

The Jurisdiction C recovery audit contractor (RAC) Connolly Healthcare has been instructed by CMS to slow down a semi-automated review for CPAP and BiPAP sleep tests. The RAC began auditing suppliers for Medicare covered sleep tests in in September 2011, targeting claims for patients who received their initial PAP devices prior to enrollment in the Medicare program (see here for full details).

It’s important to note that while no new request letters are actively going out, the audit has NOT been rescinded. Suppliers must still respond to any letters they already have in their possession and provide the RAC with a copy of the patient’s qualifying sleep test.

If you are struggling with a large volume of requests for this audit, you may contact Connolly Customer Service at 1-866-360-2507, option 4 to request an extension beyond the original response timeframe referenced in your letter.

When submitting your response, we recommend including a cover sheet that lists all service dates targeted in the audit for that patient.  For this particular audit, CMS has instructed Connolly to accept a blanket, aggregated response at the patient level (in lieu of responding to each individual service date).

In most cases where Medicare is the primary payor and the patient has a secondary insurer, the responsibility of transmitting the claim to the supplemental insurer for payment falls on the coordination of benefits contractor (COBC). For claims submitted in the new HIPAA Version 5010 format, once Medicare adjudicates the claim and payment has been finalized, the COBC then translates the claim (if necessary) into the claim format accepted by the secondary payor and runs a series of HIPAA compliance validations prior to transmission. If a compliance issue is identified, the COBC notifies the DME MAC that crossover to the secondary payor could not be completed and the submitting supplier is mailed a letter that indicates “The claim(s) could not be crossed over due to claim data errors…” with a specific error code. The supplier then becomes responsible for resolving the issue and taking the additional steps to bill the supplemental payor.

CMS recently identified flaws in the COBC’s system that resulted in incorrect rejections for crossover claims submitted in the new HIPAA Version 5010 format. If you received a letter stating that your claim could not be crossed over due to one of the following errors, it was likely rejected as result of a defect in the COBC’s compliance validation process:

According a release published by all four DME MACs, effective Monday, February 27, the MACs began resending claims affected by error code H20203 to the COBC for crossover. In addition, CMS has asked contractors to hold letters for claims rejecting due to error code H45255. Once the issue is resolved, the DME MACs will be instructed to resend the affected claims to the COBC so they may be successfully crossed over.

After placing a call to the Jurisdiction C DME MAC, we were able to verify that the DME MACs did NOT receive instruction to resubmit claims rejected for reason code H51108. If you received a crossover rejection for H51108 prior to January 16, 2012, you will need to manually submit this claim to the secondary insurer for payment.

Did you know that if you hire any employee or contract with an entity that has been excluded from participating in a Federal healthcare program, that it could cost you tens of thousands of dollars in fines?

In addition to imposing civil money penalties (CMPs), the Office of Inspector General (OIG) has the authority to exclude any individuals and entities who have engaged in fraud or abuse from participation in Medicare, Medicaid and other Federal healthcare programs. Per the OIG:

• The practical effect of an exclusion is to preclude employment of an excluded individual in any capacity by a health care provider that receives reimbursement, indirectly or directly, from any Federal health care program.
• No Federal payment may be made for any items or services furnished by the excluded individual or entity, even if the payment is being made to another non-excluded provider or supplier.
• In addition, payment may not be made for items and services prescribed by an excluded physician.

Also per the OIG, if you employ an excluded individual while providing services to patients under a Federal healthcare program, you could face:

• A civil money penalty of up to $10,000 for each item or service furnished by the excluded individual or entity and listed on a claim,
• An assessment of up to three times the amount claimed, and
• A possible exclusion from program participation (i.e. Medicare).

For liability to be imposed, current statute requires that the supplier knew or should have known that the employee or entity was excluded. But, it is the OIG’s stance is that suppliers have a duty to check the exclusion status of an employee or contractor before entering into a relationship, or else run the risk of CMP liability.

With fines and revocation of billing privileges at stake, it is not worth the risk to hire someone without performing a check. Additionally, we recommend a retroactive check on existing employees if you have not screened them previously. To protect yourself against entering into a relationship with an excluded individual or entity, take a moment to search the OIG’s Exclusion Database, also known as the List of Excluded Individuals/Entities (LEIE). In addition to potential employees and vendors, be sure to screen each of your current employees for possible exclusions. The database is free, easy to use and is available here: http://exclusions.oig.hhs.gov/.

Below are some tips to keep in mind when searching the OIG’s Exclusion Database:

• You can search for up to 5 names at one time.
• Remember to screen all owners, managers and officers within the company.
• In addition to the employee’s current name, be sure to screen for aliases (i.e. nicknames like Charlie instead of Charles), hyphenated names and maiden names.
• For a broader search, type in the first few letters of the last name, with no first name.
• Don’t rely solely on the address or occupation listed to verify a match. The person may have moved and obtained a different position.
• If you locate someone you believe may be an employee, you can verify if they are the same person by clicking on the name and entering the employee’s social security number.

For more information on OIG exclusions see:

http://oig.hhs.gov/exclusions/effects_of_exclusion.asp.

As discussed in yesterday’s blog, the Jurisdiction A DME MAC, NHIC, will no longer be issuing paper Acknowledgement Letters for redetermination requests effective April 1, 2012 – a trend that seems to be catching on. In another list serve released by the Jurisdiction D DME MAC, NAS announced that it too plans to eventually eliminate mailing paper Acknowledgement Letters as suppliers begin to utilize its Endeavor (a web-based alternative to calling the Jurisdiction D IVR) and IVR systems to verify the receipt and status of appeals.

Note: This change does not impact decision letters, only the acknowledgement letters sent to confirm your appeal was received.

Beginning yesterday, February 29^th, suppliers in Jurisdiction D may obtain the status of an appeal by calling the MAC’s IVR and selecting the appeals menu option. You must wait at least 10 days from date your appeal is received for it to be uploaded into the IVR system and will need the following information to access the status of your appeal:

1. Your National Provider Identifier (NPI)
2. Your Provider Transaction Access Number (PTAN)
3. The last five digits of your Tax Identification Number (TIN)
4. The patient’s Medicare number
5. The patient’s name as it appears on their Medicare card
6. The 14-digit claim control number (CCN). This can be found on your remittance advice in the Internal Control Number (ICN) field.

NAS has not specified the exact date it plans to discontinue mailing Acknowledgement Letters; however, we don’t expect it to be too far down the road. Information on how to use the IVR to check on the status of an appeal is available on the NAS website here.

As technology improves and the push towards electronic health records progresses, we will likely see a reduction in the number of paper statements/letters mailed by contractors and a shift towards electronic communications. The latest example of this comes from the Jurisdiction A DME MAC, NHIC, which recently announced that they will no longer issue hard-copy Acknowledgement Letters when redetermination requests are received.

Effective April 1, 2012, suppliers in Jurisdiction A will need to call the MAC’s IVR system to check on the status of a redetermination request. According to the MAC, suppliers should wait at least 10 days after submitting their request for it to be received and uploaded into the IVR system. If you call the IVR 10 days after submission and are unable to locate your request, you should call NHIC’s customer service line at: 1-866-590-6731. Per NHIC, if a redetermination request is determined to be a reopening issue, it will be reassigned in the system as a pending reopening case.

Instructions on how to use the IVR to check on a redetermination request are available in the DME MAC A IVR User Guide at:

http://www.medicarenhic.com/dme/contacts/DME_MAC_A_IVR_User_Guide.pdf.