Practice Management

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  • 1.  Proposed 2021 MPFS Rule Out - Silent on AUC/CDS

    Posted 08-03-2020 21:59
    Oddly, there appears to be no discussion of the requirement for physicians who order advanced imaging to use clinical decision support mechanisms to consult appropriate use criteria. As you all know, this year is an education and testing year. The expectation had been that the MPFS rule would include an announcement as to whether CMS was going to require such consultation to be mandatory in 2021 or issue a delay. 

    https://www.cms.gov/files/document/cms-1734-p-pdf.pdf

    There must be some other vehicle where CMS will announce the fate of AUC/CDS for 2021.




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    Thomas W Greeson
    Reed Smith LLP
    (703) 517-0495
    tgreeson@reedsmith.com
    ------------------------------


  • 2.  RE: Proposed 2021 MPFS Rule Out - Silent on AUC/CDS

    Posted 08-04-2020 10:23
    Tom,
    Thanks for the update ... It appears our facilities are awaiting the storm, but hoping for another delay.  


    Also, I was not able to make your link work. 


    image.png
    This was the link from Melody:



    Parke Keith

    Radiology of Huntsville

    256.539.0457 Office

    pkeith@radhunt.com

     

    This email contains CONFIDENTIAL INFORMATION which may include protected health information and is legally privileged. This information is intended only for the use of the addressee named above. If you are not the intended recipient of this email or the employee/agent responsible for delivery to the intended recipient, you are hereby notified that any disclosure, copying, distribution, or action taken in reliance on the contents of this email may be strictly prohibited. If you received this email in error please notify the sender immediately.






  • 3.  RE: Proposed 2021 MPFS Rule Out - Silent on AUC/CDS

    Posted 08-04-2020 11:14

    In case others have not found a better link to the proposed MPFS 2021 rule (which worked last evening, but not today), here is a link.

     

    https://www.federalregister.gov/documents/2020/08/17/2020-17127/medicare-program-cy-2021-revisions-to-payment-policies-under-the-physician-fee-schedule-and-other

    Thomas W. Greeson
    703.517.0495
    tgreeson@reedsmith.com

     

     

     






  • 4.  RE: Proposed 2021 MPFS Rule Out - Silent on AUC/CDS

    Posted 08-04-2020 16:22

    Tom – In my thus far quick review there are a couple of things that cause me to stop and think. Yes it looks like the E&M code changes may go into effect, but they don't say that , only clarifying the level of service that some high end activities will qualify for upon submission – ESRD etc.

     

    But the combination of two areas makes me stop and think

     

    1. The fact that NPPs may be allowed to provide supervision for diagnostic tests
    2. The direct supervision of diagnostic tests may be done via Interactive Telecommunications

     

    These two changes could dramatically alter the offering of radiology exams that require direct supervision. Am I seeing these suggested changes correctly?

     

    Keith E. Chew, MHA, CMPE, FRBMA

    Principal – Consulting with Integrity

    18 Hawks Nest Chatham, IL   62629

    217-971-5293 Direct

     






  • 5.  RE: Proposed 2021 MPFS Rule Out - Silent on AUC/CDS

    Posted 08-04-2020 16:26
    Both of those are allowed now under the PHE, the proposed rule is to let them continue after the PHE is over. 

    Donna Richmond, BA, RCC, CIRCC, CPC
    Senior Healthcare Consultant

     

    651-424-4225

    C 337-412-2272
    www.panaceainc.com

     

     

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    *HFMA staff and volunteers determined that CDMauditor® – Hospital Zero-Base Pricing® and related modules have met certain criteria developed under the HFMA Peer Review Process. HFMA does not endorse or guarantee the use of this service.   

     

     

     







  • 6.  RE: Proposed 2021 MPFS Rule Out - Silent on AUC/CDS

    Posted 08-04-2020 16:28

    Yes. Thus the concern for the long term impact instead of the short term impact of an emergency order approach.

     

    Keith E. Chew, MHA, CMPE, FRBMA

    Principal – Consulting with Integrity

    18 Hawks Nest Chatham, IL   62629

    217-971-5293 Direct

     






  • 7.  RE: Proposed 2021 MPFS Rule Out - Silent on AUC/CDS

    Posted 08-04-2020 16:44
    Keith and Donna, my interpretation of what CMS has proposed is to permanently permit mid-levels to supervise diagnostic tests.  The proposal to permit the use of audio or other electronic presence to supervise tests that require direct supervision runs to the end of the public health emergency or until Dec. 31, 2021.

    ------------------------------
    Thomas W Greeson
    Reed Smith LLP
    (703) 517-0495
    tgreeson@reedsmith.com
    ------------------------------



  • 8.  RE: Proposed 2021 MPFS Rule Out - Silent on AUC/CDS

    Posted 08-04-2020 16:47
    Thanks Tom, I was running through it pretty quickly looking looking for keywords and highpoints.  Will have a more detailed look later.  

    Donna Richmond, BA, RCC, CIRCC, CPC
    Senior Healthcare Consultant

     

    651-424-4225

    C 337-412-2272
    www.panaceainc.com

     

     

    Subscribe to Panacea Insights

    Stay up to date on the latest in healthcare coding,
    compliance, and reimbursement

     

     

    *HFMA staff and volunteers determined that CDMauditor® – Hospital Zero-Base Pricing® and related modules have met certain criteria developed under the HFMA Peer Review Process. HFMA does not endorse or guarantee the use of this service.