Medicare Updates of Interest to Anesthesiologists and Pain Physicians
Please take a moment to participate in the second annual ASA nationwide survey on anesthesia drug shortages. This brief survey will help ASA continue to work with legislative and regulatory policymakers to develop policies that help to avert drug shortages, provide advanced notification and mitigate the effects of drug shortages. Data from last year's survey was instrumental to ASA in demonstrating the urgency of addressing drug shortages.
For this survey to be successful, ASA will again need a high participation rate of members. Please complete this survey and encourage other ASA members to do so as well. http://www.surveymonkey.com/s/asadrugshortagesurvey
I. Revised Anesthesia Conversion Factors
CMS has just updated the Medicare conversion factors (CFs) for anesthesia services. The new national, unadjusted CF is $21.52, up from $21.41 for the first two months of 2012. Download the list of locality-adjusted CFs here.
As noted on the CMS website, “Medicare payment rates under the Medicare Physician Fee Schedule (MPFS) are set according to statutory criteria. The following 2012 MPFS payment rates are reflective of the CY 2012 Medicare Physician Fee Schedule Final Rule, which was published in the Federal Register on November 28, 2011, and the CY 2012 Medicare Physician Fee Schedule Final Rule Correction Notice, which was published in the Federal Register on January 4, 2012. These payment rates are based on current law, including the Middle Class Tax Relief and Job Creation Act of 2012 (MCTRJCA), which provides for a zero percent update through December 31, 2012.”
II. Deadline for Compliance with 5010 Standard Delayed until July 1, 2012
On Thursday, March 15, 2012, CMS’ Office of E-Health Standards and Services announced that it would again delay enforcement of the HIPAA Version 5010 transaction standards for three months. Anesthesia and pain medicine practices may therefore continue to submit electronic claims using Version 4010 through June 30, 2012, without penalty.
Although CMS will not enforce compliance until July 1st, the implementation date for Version 5010 is still January 1, 2012, and all covered entities should continue to make every effort to comply with the new standards.
Last November, CMS advised that it would not initiate enforcement action against covered entities, including medical practices, that were not compliant with the updated versions of the standards for 90 days following the January 1, 2012 compliance date. This was called a period of “enforcement discretion,” during which CMS encouraged covered entities to complete outstanding implementation activities including software installation, testing and training. The 90 days are up on March 31st.
According to CMS’ press release, “Health plans, clearinghouses, providers and software vendors have been making steady progress: the Medicare Fee-for-Service (FFS) program is currently reporting successful receipt and processing of over 70 percent of all Part A claims and over 90 percent of all Part B claims in the Version 5010 format. Commercial plans are reporting similar numbers.” Only “some” Medicaid agencies appear to have made a full transition to Version 5010, however. Still, CMS expects a compliance rate of 98 percent by July.
The AMA and MGMA-ACMPE (formerly the Medical Group Management Association) had both written letters urging CMS to extend the current enforcement delay by a minimum of 90 days. In support of its request, MGMA-ACMPE stated that the migration to Version 5010 has caused significant delays in claims payment. Recognizing that CMS has limited authority with respect to non-Medicare, non-Medicaid transactions, MGMA-ACMPE asked CMS to “strongly encourage health plans and clearinghouses to provide appropriate and timely feedback to submitters of Version 4010 or non-compliant Version 5010 claims that identify content errors.” It also suggested that a further enforcement delay might be necessary.
The AMA also advised CMS that some physicians were experiencing “serious claims processing and cash flow interruptions” and requested a delay in enforcement of 90 days. The Association encourages physicians who are experiencing such interruptions with either their Medicare Administrative Contractors or with private payers to seek the AMA’s assistance by using the appropriate form found at www.ama-assn.org/go/5010.
As we previously explained in our Alert dated November 28, 2011, the most significant changes in Version 5010 are the following:
- The 5010 requires a physical street address in the billing provider address field and not a P.O. box or lock box number.
- Surgical codes for anesthesia services are optional unless required in a participation agreement with the payer.
- Anesthesia time must be reported in total minutes, not units.
- Anesthesia codes 00100 – 01996 are exempt from the edit that will trigger an edit requiring additional information if the words “not otherwise specified” are in the code descriptor. See ASA’s Washington Alert dated January 18, 2012, noting that “CMS representatives advised us that any data submitted in Loop 2400 SV101-7 would satisfy the edit for Medicare claims until revisions have been made.”
As of November 28, 2011, ABC had successfully tested Version 5010 transactions with all Medicare carriers. We completed testing with all the private payers with whom our clients do business by the beginning of 2012. If any of our readers have not completed their testing, we hope that the new enforcement delay will permit them to avoid disruptions.