Hi Leslie
I believe it's the NPI of the ordering clinician that may need to be reported, not the TIN. While this was stated in some of the early documents CMS published (for example
https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/Downloads/AUCDiagnosticImaging-909377Print-Friendly.pdf), I note that it's not mentioned in the most recent MLN Matters (
https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/MM11268.pdf). I suspect that may be an oversight, since surely CMS wants to know who is doing the ordering and consultation. As you note, there is no place to report a TIN. Presumably, the NPI would go in box 17b.
I think the CAH issue is even less clear. While I know some CMS reps have said informally that a radiologist reading a study from a CAH wouldn't be required to report AUC, I don't believe the regulations have been revised accordingly. The regs say that CAH are excluded based on their special payment mechanism, but that wouldn't apply to physicians paid under the MPFS. As you note there is currently no way to report that the TC was done in a CAH on a professional component claim. My expectation is that CMS will have to provide a modifier for this case, but it hasn't been done yet. We're taking a wait and see approach to this issue, and we will likely report MH on those claims for now.
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David Smith FACMPE
Executive Director
United Imaging Consultants
Mission KS
(785) 393-8387
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Original Message:
Sent: 12-19-2019 11:55
From: Leslie Lochmann
Subject: CDSMs
We are in the process of drafting a letter to our referring providers outlining CDS. I viewed the ACR sample letter to providers and it states the results of the consultation as well as the TIN of the referring provider must be reported. Does anyone know if reporting the TIN of the reporting provider is still a requirement? If so, what box or loop on the claim form will the TIN need to be included?
Also, regarding Critical Access Hospitals (CAH's) being exempt from reporting. Would you use code G1011 with modifier MD to support billing advanced imaging performed at these locations? We are unsure how to report to CMS the advanced imaging service was performed at a CAH since Box 32 is the location at which the interpretation was provided. Often this is not the technical component location. Reporting the POS code in 24B does not identify the location as a CAH if applicable.
Thanks for any guidance!
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Leslie Lochmann
Billing System Manager
Cape Radiology Group, Inc.
Cape Girardeau MO
(573) 334-6071
Original Message:
Sent: 12-17-2019 10:35
From: Barbara Rubel
Subject: CDSMs
That's what I have as well and suspected we would use the G1011. Thank you!
Barbara F. Rubel MBA, FRBMA
Senior VP, Marketing & Client Services
brubel@msnllc.com
904-657-2038 (Office) | 770-823-3597 (Cell)
MSNLLC.com
Original Message------
Hello,
I did not see any update of the G codes in the December revision of MM11268. My read is that we use G1011 for those without a specific G code. These are the ones for which I do not see the code.
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