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CMS Transmittal - AUC HCPCS modifiers and G codes

  • 1.  CMS Transmittal - AUC HCPCS modifiers and G codes

    Posted 07-26-2019 08:22
      |   view attached

    CMS released a transmittal this morning to inform Medicare Administrative Contractors (MACs) that effective January 1, 2020, MACs should accept Appropriate Use Criteria (AUC) related HCPCS modifiers on Medicare claims for outpatient advanced diagnostic imaging procedures. The transmittal has an attachment with the relevant CPT codes, modifiers, and G codes to be used by suppliers of advanced imaging services. Because 2020 is an educational and operations testing period, claims will not be denied for failing to include AUC-related information. The transmittal is uploaded to this post. It is also available via this link:

    https://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/2019-Transmittals-Items/R2323OTN.html?DLPage=1&DLEntries=10&DLSort=1&DLSortDir=descending



    ------------------------------
    Thomas Greeson JD, FRBMA
    Partner
    Reed Smith LLP
    Mc Lean VA
    (703) 641-4242
    ------------------------------

    Attachment(s)



  • 2.  RE: CMS Transmittal - AUC HCPCS modifiers and G codes

    Posted 07-26-2019 09:32

     

     

    Good pickup Tom, what the industry has been waiting for.  Let the software re-engineering begin. 

     

    On another CMS front we understand the 2020 Medicare Physician Fee Schedule is continually being tied up between OMB and CMS.  We expected a release on 7/25/19 but now we here the release will be either today or early the week of 7/29/19.  Either way, the RBMA Federal Affairs Committee is prepared to begin review and comment on behalf of radiology business professionals. 

     

    Robert T. Still, FRBMA

    Executive Director

    M:  717.475.6079

    bob.still@rbma.org

     

    RBMA50_Logo_FN_eSig (002)

    9990 Fairfax Blvd., Suite 430 | Fairfax, VA 22030

    Direct: 703-621-3363 | Main: 888-224-7262 | Fax: 703-621-3356 | www.rbma.org

     

    Register to attend RBMA's LEARN, Sept. 17-18, 2019, in Washington, D.C. Now is the time to make a difference with your presence and your voice!

     

    Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s) and may containconfidential and privileged information. Any unauthorized review, use, disclosure, or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message.

     

     

     

     






  • 3.  RE: CMS Transmittal - AUC HCPCS modifiers and G codes

    Posted 07-26-2019 09:36

    Thanks Tom!

     

    Disappointing that there isn't a modifier related to services where the TC is rendered in a Critical Access Hospital...

     

    Looks like we still have some work to do on that issue...

     

    Dave

     

           David Smith, FACMPE  |  Executive Director  |  785.393.8387

    5800 Foxridge Dr.  Ste 240  |  Mission, KS  66202  |  www.uickc.com

    p-uic-horizontal-03a

     

    Member of

     

     






  • 4.  RE: CMS Transmittal - AUC HCPCS modifiers and G codes

    Posted 07-26-2019 15:30

    Good Afternoon,

     

    Is it your understanding that the ordering providers have no claim responsibilities, and therefore no penalties if they do not cooperate and consult with the CDSM for these referrals?  What is the incentive for them to help providers accomplish this mandate? Some questions are coming my way about if their claim will get denied associated with our referral. Is this part of the process and if so how is that tracked since the CDSM has no PHI or claim specific data except by the rendering? After a provider sends enough claims with MH, does that create a required workflow for the referring office?

     

    Thanks in advance for your time,

     

    Mindy Smith

    Billing Manager

    Management Data Systems

    3114 Lake St

    Lake Charles, LA 70601

    337-437-7681

    866-437-7681

     

    NOTICE: This email may contain PRIVILEGED and CONFIDENTIAL information and is intended only for the use of the specific individual(s) to which it is addressed. If you are not the intended recipient of this email, you are hereby notified that any unauthorized use, dissemination or copying of this email or the information contained in it or attached to it is strictly prohibited. You may be subject to penalties under law for any improper use or further disclosure of any Protected Health Information in this email. If you have received this email in error, please delete it and immediately notify the sender of this email by reply mail. Thank you.

     

     

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  • 5.  RE: CMS Transmittal - AUC HCPCS modifiers and G codes

    Posted 07-26-2019 15:43

    Mindy,

     

    I have not had to deal with AUC/CDS for a couple of years, so I apologize if this has changed.  At the time we were working on this, the penalty for the referring was a couple of years down the road.  If a referring did not comply and use the CDS, they would have to obtain authorizations from CMS directly.  These authorizations cannot be obtained by another party; the referring provider's staff must obtain the authorization.

     

    As far as I can tell, this is still the case.

     

    Thanks,

     

    Brian Williams

    Co-Administrator

    Operations

     

    Diagnostic Imaging Associates, Inc.

     

     

     






  • 6.  RE: CMS Transmittal - AUC HCPCS modifiers and G codes

    Posted 07-26-2019 15:49

    Sorry to double post, but here is a reference.

     

    https://www.acr.org/Clinical-Resources/Clinical-Decision-Support/Dec-11-2018-PAMA-AUC-Deadline-Webinar-Q-and-A-Sheet

     

    Thanks,

     

    Brian Williams

    Co-Administrator

    Operations

     

    Diagnostic Imaging Associates, Inc.

    698 12th St SE

    Suite 145

    Salem, OR 97301

     

    503-588-2674 - Office

    503-586-1301 – Fax

    541-301-9056 - Mobile

     

    Upcoming PTO:

     August 8th – August 16th 

     

     

     






  • 7.  RE: CMS Transmittal - AUC HCPCS modifiers and G codes

    Posted 07-26-2019 16:06
    Hi Mindy

    You are correct that there is no penalty for ordering clinicians who don't consult CDS.  However, it's hard to imagine that many imaging providers will be willing to work for free in 2021, so it's likely that no one would accept their orders at that time.

    The line we are taking is that CMS requires consultation with AUC effective January 1, 2020.  I figure that by 2021 when the payment penalties for furnishing providers start, we will have worked through any non-compliance issues, and had adequate time to warn that their orders won't be accepted without the codes and modifiers.

    ------------------------------
    David Smith FACMPE
    Executive Director
    United Imaging Consultants
    Mission KS
    (785) 393-8387
    ------------------------------



  • 8.  RE: CMS Transmittal - AUC HCPCS modifiers and G codes

    Posted 07-27-2019 05:55
    Mindy,

    Currently, up to 5% of ordering physicians will be identified as outliers in 2023 and will be subject to prior authorization protocols.  CMS is soliciting feedback about the methodology to identify outlier ordering professionals and has identified 8 priority clinical areas to guide identification of outlier ordering professionals which they say represents 40% of the total volume of advanced diagnostic imaging studies. The priority clinical areas are Coronary artery disease (suspected or diagnosed), Suspected pulmonary embolism, Headache (traumatic and non-traumatic), Hip pain, Low back pain, Shoulder pain (to include suspected rotator cuff injury), Cancer of the lung (primary or metastatic, ,suspected or diagnosed),and Cervical or neck pain.



    ------------------------------
    Barbara Rubel, MBA, FRBMA
    Senior Vice President, Marketing & Client Services
    MSN Healthcare Solutions
    President, FRBMA
    Past President RBMA
    Green Cove Springs FL
    (904) 657-2038 (O)
    (770) 823-3597 (Cell)
    ------------------------------



  • 9.  RE: CMS Transmittal - AUC HCPCS modifiers and G codes

    Posted 07-26-2019 16:44
    Mindy. There is no immediate impact to a referring provider that does not access AUC/CDS. The financial impact will be to the technical and professional component providers. CMS has stated that once AUC has been fully implemented that those either not using the system or those abusing the system by constantly ordering marginal or inappropriate advanced imaging studies will be require to seek actual pre-authorization from CMS for the delivery of advanced imaging studies. CMS has not lost stated as part of AUC but the information is delineated in the QPP concerning the calculation of the cost of care component, that the continued ordering of marginal or inappropriate advanced imaging studies will negatively impact the order providers QPP score thus decreasing any possible incentive added to their CMS reimbursements or increasing any possible reduction in reimbursements..... Hope this helps...



    Sent from my Verizon, Samsung Galaxy smartphone





  • 10.  RE: CMS Transmittal - AUC HCPCS modifiers and G codes

    Posted 07-27-2019 08:16

    A couple comments

     

    As others have pointed out, I too am very concerned about the lack of a modifier for PC claims when the underlying TC was performed at either a Critical Access Hospital or Federally Qualified Health Center.  Maybe we'll learn more when the Proposed Rule is released. 

     

     

    On another interesting aside, many physicians are simply refusing to use CDS.  That's all well and good for now, but eventually, they'll have to use it.  Here is a question for you:  Will your practice append the MH modifier to claims when you are not provided the AUC criteria beginning January 1, 2020 if you don't get the consult information?    

     

     

    Michael Bohl, Chief Strategic Advisor

    Radiology Group, PC, SC

    563.421.5656

    mbohl@rgimaging.com

     

     






  • 11.  RE: CMS Transmittal - AUC HCPCS modifiers and G codes

    Posted 07-29-2019 09:08

    Mike,

     

    CMS has clarified that the PC of CAH's do not fall under the CDS/AUC policy.  I posted something recently that also stated that FAHQs do not either.  We are not concerned or seeking further clarification on this.

     

    Pam

     

    Pam Kassing, MPA, FRBMA, RCC

    Senior Economic Advisor

    Economics and Health Policy

    American College of Radiology

    1819 Preston White Drive

    Reston, VA 20191

    (800) 227-5463 x4544

     


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  • 12.  RE: CMS Transmittal - AUC HCPCS modifiers and G codes

    Posted 07-29-2019 09:18

    Hi Pam

     

    Has that been published somewhere?  If there is no modifier, how would CMS know whether the TC was performed in a critical access hospital?  There isn't a POS code for CAH.  It would look just like any other ED or OP claim.

     

    Thanks

     

    Dave

     

    David Smith, FACMPE  |  Executive Director  |  785.393.8387

    5800 Foxridge Dr.  Ste. 240 |  Mission, KS  66202  |  www.uickc.com

    p-uic-horizontal-03a

     






  • 13.  RE: CMS Transmittal - AUC HCPCS modifiers and G codes

    Posted 07-29-2019 09:21

    Hi Pam –

    Unless the physician is reading in the CAH, the PC claim will not indicate the exam was performed in a CAH. Do you know how else this may be communicated to CMS, if not on the claim?

    Thanks

    t

     

    Theresa King, CPC, CPPM

    Business Process Improvement Manager

    Huron Valley Radiology, P.C.

    5333 McAuley Drive, Suite 6016

    P.O. Box 992

    Ann Arbor, MI 48106

    734.712.8359

    Theresa.king@hvrrad.net

     

    image001.jpg@01D1DB5A.5A848970

     

     

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  • 14.  RE: CMS Transmittal - AUC HCPCS modifiers and G codes

    Posted 07-29-2019 09:26
    The address on the claim wouldn't be reliable either.  We have radiologists sitting at a CAH reading for non-CAH locations.

    Dave

    ------------------------------
    David Smith FACMPE
    Executive Director
    United Imaging Consultants
    Mission KS
    (785) 393-8387
    ------------------------------



  • 15.  RE: CMS Transmittal - AUC HCPCS modifiers and G codes

    Posted 07-29-2019 09:30

    Theresa and David,

     

    We received clarification via email from CMS staff who said that the PC readings for studies done in CAH's are exempt.  I do not know the answer of how to report that but will submit it to our staff what handle the CDS/AUC issue for ACR and have them work on this.

     

    Pam

     

    Pam Kassing, MPA, FRBMA, RCC

    Senior Economic Advisor

    Economics and Health Policy

    American College of Radiology

    1819 Preston White Drive

    Reston, VA 20191

    (800) 227-5463 x4544

     


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  • 16.  RE: CMS Transmittal - AUC HCPCS modifiers and G codes

    Posted 07-29-2019 09:31

    Perfect, thank you!

     

    Theresa King, CPC, CPPM

    Business Process Improvement Manager

    Huron Valley Radiology, P.C.

    5333 McAuley Drive, Suite 6016

    P.O. Box 992

    Ann Arbor, MI 48106

    734.712.8359

    Theresa.king@hvrrad.net

     

    image001.jpg@01D1DB5A.5A848970

     

     

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  • 17.  RE: CMS Transmittal - AUC HCPCS modifiers and G codes

    Posted 07-30-2019 06:41
    Hi Pam,

    While you are seeking clarification, could you also submit the following: 

    What if the technologist changes the scan? For example, adding a pelvis to an abdominal CT. Our orders give radiology authority to modify the protocol, but we are trying to determine whether the order has to be placed again through the CDSM or if the CMS requirement has been met.

    Thank you!



    ------------------------------
    Barbara Rubel, MBA, FRBMA
    Senior Vice President, Marketing & Client Services
    MSN Healthcare Solutions
    President, FRBMA
    Past President RBMA
    Green Cove Springs FL
    (904) 657-2038 (O)
    (770) 823-3597 (Cell)
    ------------------------------



  • 18.  RE: CMS Transmittal - AUC HCPCS modifiers and G codes

    Posted 07-30-2019 10:41

    Barbara,

     

    I am happy to have our staff ask this question of CMS but I wonder......if they consulted the CDS, would it minimize the need for techs to change or add on to orders?  Should techs be changing orders or should it be the consulting radiologist?

     

    Pam

     

    Pam Kassing, MPA, FRBMA, RCC

    Senior Economic Advisor

    Economics and Health Policy

    American College of Radiology

    1819 Preston White Drive

    Reston, VA 20191

    (800) 227-5463 x4544

     


    This message (including any attachments) is intended only for the use of the individual or entity to which it is addressed. It may contain information that is non-public, proprietary, privileged, confidential, and exempt from disclosure under applicable law and/or may constitute attorney work product. If you are not the intended recipient, do not use, disseminate, distribute, or copy this communication. If you have received this communication in error, please notify us immediately by telephone and destroy this message if this is a facsimile or (ii) delete this message immediately if this is an electronic communication.


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  • 19.  RE: CMS Transmittal - AUC HCPCS modifiers and G codes

    Posted 07-30-2019 10:44
    Hi Pam,

    I am sure the phrasing from the physician is not completely accurate and believe she means the tech is changing the exam at the direction of the consulting radiologist.

    ------------------------------
    Barbara Rubel, MBA, FRBMA
    Senior Vice President, Marketing & Client Services
    MSN Healthcare Solutions
    President, FRBMA
    Past President RBMA
    Green Cove Springs FL
    (904) 657-2038 (O)
    (770) 823-3597 (Cell)
    ------------------------------



  • 20.  RE: CMS Transmittal - AUC HCPCS modifiers and G codes

    Posted 07-30-2019 10:49

    Okay, thanks for the clarification.  I will look into it.

     

    Pam

     






  • 21.  RE: CMS Transmittal - AUC HCPCS modifiers and G codes

    Posted 07-30-2019 16:02
    ��

    Stan





  • 22.  RE: CMS Transmittal - AUC HCPCS modifiers and G codes

    Posted 07-31-2019 08:17

    In the Federal Register I believe the same question you are asking was asked and was responded to.

    It can be found in  https://www.govinfo.gov/content/pkg/FR-2017-11-15/pdf/2017-23953.pdf page 53190 near the bottom of the first column.  The way I read it is that it doesn't need to be done again.

     

    I have copied it directly below so you don't have to read it unless you want.

    Comment: Some commenters requested that we clarify how imaging replacement orders, where the furnishing professional or radiology technician updates or modifies an order based on new information at the time of imaging, are handled under the AUC program. Commenters questioned whether the furnishing professional can update the order as necessary or if they need to consult with the ordering professional or AUC again to generate a new determination of appropriateness. One commenter requested that CMS provide guidance for situations where the furnishing professional performs different or additional tests than ordered in accordance with guidance in Medicare publication 100–02, Chapter 15, sections 80.6.2–4. Some commenters recommended that furnishing professionals have the flexibility to adjust exam parameters or modify orders without consulting AUC, submit orders themselves if they have relevant patient clinical information, and occasionally use AUC as appropriate to demonstrate that a test was warranted.

     

    Response: We understand that in certain situations updates or modifications to orders for advanced diagnostic imaging services may be warranted once the beneficiary is under the care of the furnishing professional. As a commenter noted, the Medicare Benefit Policy Manual (Pub. L. 100–02) addresses rules around these situations in Chapter 15, sections 80.6.2–4. We do not believe it was the intent of section 218(b) of the PAMA to reverse these rules, and we expect furnishing professionals and facilities to continue to adhere to them so as to avoid additional burden, workflow interruptions and delays in medically necessary services. In instances when the furnishing professional must update or modify the order for an advanced diagnostic imaging service, the AUC consultation information provided by the ordering professional with the original order should be reflected on the Medicare claim to demonstrate that the requisite AUC consultation occurred. In future rulemaking, we expect to establish a means to account for instances when the order must be updated or modified. We anticipate addressing this issue in rulemaking to develop policies relating to the identification of outlier ordering professionals, and in order to inform the prior authorization component of this program.

     

    Thanks,

    Matt

    _______________________

    Matt Dewey, MMCi

    Chief Information Officer

    WAKE RADIOLOGY

    3949 Browning Pl

    Raleigh, NC 27609

    ( 919.232.4748 Office

    ( 919.781.9792 Fax

    * mdewey@wakerad.com

    http://www.wakerad.com

     

     


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  • 23.  RE: CMS Transmittal - AUC HCPCS modifiers and G codes

    Posted 07-31-2019 08:20
    Perfect! Thank you!

    Sent from my iPhone





  • 24.  RE: CMS Transmittal - AUC HCPCS modifiers and G codes

    Posted 07-31-2019 09:21

    Does anyone have a plan on how to get the referring physicians to use AUC and what approved resources they will be using?

     

    Joanne Chichizola

    Billing Manager

     






  • 25.  RE: CMS Transmittal - AUC HCPCS modifiers and G codes

    Posted 07-31-2019 13:03

    Joanne, we will be taking advantage of the ACR toolkit to use their form letter (modified of course) to send to many of our referring physicians in the next couple of months. (those without access to a CDSM in their EHR).  The vast majority of our referring physicians are on EPIC with CareSelect built in.  We of course need to figure out the details of the modifiers getting passed in our billing file as we use a third party billing company.  There are a couple of free CDSM's that referring physicians will be able to use if they are smaller offices without the resources to have it as part of their EHR.  CMS as a list of the qualified CDSM's listed here. https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Appropriate-Use-Criteria-Program/CDSM.html

    I have done a demo of Test Appropriate CDSM which is a free offering and am waiting to do a demo of National Decision Support Company CareSelect free version that I was told would not be available until November or so.  AIM Specialty Health also is listed as having a free offering.

     

    My plan is to include choices in the letter that we send to the referring providers.  For our imaging center we just won't schedule them until AUC information is provided.  The other facilities that we read for that do not have EPIC are mostly CAH's and should not need to consult.  Our one multi-specialty clinic we read for has the incentive to consult AUC as they won't get paid for the technical if they don't. 

     

    It will take some education but we plan to start early with letters and then follow-up visits to our referrers that our not part of the health systems EPIC community connect program.  Luckily probably 85% have access to EPIC and it will be turned on as a requirement whenever advanced imaging is being ordered.

     

    John Griffith

    Administrator

    DakotaRadiology

    2929 5th Street, Suite 230

    Rapid City, SD  57701

    Office: 605.721.8545

    Fax: 605.721.8827

    JGriffith@dakota-radiology.com

    www.dakota-radiology.com

     

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  • 26.  RE: CMS Transmittal - AUC HCPCS modifiers and G codes

    Posted 07-31-2019 10:47

    Here are Section 80.6.2-4 which describe the circumstances a new consult would NOT be required.  I added the underline in the first paragraph to point out when a new order is expected.  If the intention is to use the existing consult info on the new order there will be a significant workflow issue to address in the EMR which, in most systems, will attach the consult to the initial order.  The revised test will require a new order, but would not have the consult info naturally attached to it in the EMR. In all likelihood, this would be a manual process performed by someone at the facility with access to that portion of the system.  Doable, but it'll take some getting used to so the rads actually get the consult info for the new order/procedure.

     

    Michael Bohl, Chief Strategic Advisor

    Radiology Group, PC, SC

    mbohl@rgimaging.com

    -----------------------------------------------------------------------

     

    80.6.2 - Interpreting Physician Determines a Different Diagnostic Test is Appropriate (Rev. 80; Issued:  01-11-08; Effective:  01-01-03; Implementation:  11-19-07)

     

    When an interpreting physician, e.g., radiologist, cardiologist, family practitioner, general internist, neurologist, obstetrician, gynecologist, ophthalmologist, thoracic surgeon, vascular surgeon, at a testing facility determines that an ordered diagnostic radiology test is clinically inappropriate or suboptimal, and that a different diagnostic test should be performed (e.g., an MRI should be performed instead of a CT scan because of the clinical indication), the interpreting physician/testing facility may not perform the unordered test until a new order from the treating physician/practitioner has been received.  Similarly, if the result of an ordered diagnostic test is normal and the interpreting physician believes that another diagnostic test should be performed (e.g., a renal sonogram was normal and based on the clinical indication, the interpreting physician believes an MRI will reveal the diagnosis), an order from the treating physician must be received prior to performing the unordered diagnostic test.

     

    80.6.3 - Rules for Testing Facility to Furnish Additional Tests (Rev. 80; Issued:  01-11-08; Effective:  01-01-03; Implementation:  11-19-07)

    If the testing facility cannot reach the treating physician/practitioner to change the order or obtain a new order and documents this in the medical record, then the testing facility may furnish the additional diagnostic test if all of the following criteria apply:

    • The testing center performs the diagnostic test ordered by the treating physician/practitioner;
    • The interpreting physician at the testing facility determines and documents that, because of the abnormal result of the diagnostic test performed, an additional diagnostic test is medically necessary;
    • Delaying the performance of the additional diagnostic test would have an adverse effect on the care of the beneficiary;
    • The result of the test is communicated to and is used by the treating physician/practitioner in the treatment of the beneficiary; and
    • The interpreting physician at the testing facility documents in his/her report why additional testing was done.

    EXAMPLE:  The last cut of an abdominal CT scan with contrast shows a mass requiring a pelvic CT scan to further delineate the mass; (b) a bone scan reveals a lesion on the femur requiring plain films to make a diagnosis.

     

    80.6.4 - Rules for Testing Facility Interpreting Physician to Furnish Different or Additional Tests (Rev. 80; Issued:  01-11-08; Effective:  01-01-03; Implementation:  11-19-07)

    The following applies to an interpreting physician of a testing facility who furnishes a diagnostic test to a beneficiary who is not a hospital inpatient or outpatient.  The interpreting physician must document accordingly in his/her report to the treating physician/practitioner.

     

    Test Design

    Unless specified in the order, the interpreting physician may determine, without notifying the treating physician/practitioner, the parameters of the diagnostic test (e.g., number of radiographic views obtained, thickness of tomographic sections acquired, use or non-use of contrast media).

     

    Clear Error

    The interpreting physician may modify, without notifying the treating physician/practitioner, an order with clear and obvious errors that would be apparent to a reasonable layperson, such as the patient receiving the test (e.g., x-ray of wrong foot ordered).

     

    Patient Condition

    The interpreting physician may cancel, without notifying the treating physician/ practitioner, an order because the beneficiary's physical condition at the time of diagnostic testing will not permit performance of the test (e.g., a barium enema cannot be performed because of residual stool in colon on scout KUB; 170.5PA/LAT of the chest cannot be performed because the patient is unable to stand).  When an ordered diagnostic test is cancelled, any medically necessary preliminary or scout testing performed is payable.