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One Medicare Contractor OK’s RNs and LPNs to Furnish Annual Wellness Visit

CMS staffers confirmed this week that MACs can determine whether they’ll allow licensed practical nurses (LPNs) and registered nurses (RNs) to perform annual wellness visits (AWVs) and collect from Medicare for those services. That’s the word from a Feb. 22 CMS Open Door Forum, where providers called in with several questions affecting Part B providers.

One caller phoned into the forum to ask about a Q&A posted on the Web site of WPS Medicare, a Part B payer in four states, which asks whether an RN or LPN can perform “the entire annual wellness visit (AWV, G0438-G0439).” WPS responds on the site, “Yes, an RN or LPN can perform the visit. They need to be under the direct supervision of a physician and the state license needs to allow for them to do all the ocmpoennts of the service.” (http://www.wpsmedicare.com/part_b/education/awv-faq.shtml). The caller asked whether this is a general CMS policy or if it only applies to WPS Medicare.

“Remember, the LPN’s not billing,” said CMS’s William Rogers, MD, reminding the caller that the visit would be billed under the physician’s NPI as “incident to.” But the caller still considered it “odd” that an LPN could perform an AWV, since it’s similar to an E/M service.

“It’s a different sort of service – there’s not really any clinical judgment involved,” Rogers said. “It’s a service which includes a lot of sort of administrative steps, verifying that people have certain preventive services done and things like that, and so it is intended to be a collaborative service.”

Keep in mind that CMS does not have a national policy allowing LPNs and RNs to perform AWVs, but reps from the agency confirmed that it’s within the rights of the individual MACs to make this determination.

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Look Up New Observation Codes When Reporting ‘Middle Days’

2011 brings a new coding option when reporting the middle day of observations that last longer than two days. Check out this expert advice on how CPT additions will affect your FP’s observation care services coding starting on Jan. 1, 2011.

Until this point, coding for the “middle days” of an observation service caused problems. Although not the norm, there are times when a physician admits a patient to observation and she remains in that status for three or more days. CPT 2011 addresses these middle days between admission and discharge by introducing three new E/M codes. The additions parallel the hospital subsequent care series in terms of component requirements and time frames:

  • 99224 – Subsequent observation care, per day, for the evaluation and management of a patient, which requires at least 2 of these 3 key components: Problem focused interval history; Problem focused examination; Medical decision making that is straightforward or of low complexity. Counseling and/or coordination of care with other providers or agencies are provided consistent with the nature of the problem(s) and the patient’s and/or family’s needs. Usually, the patient is stable, recovering, or improving. Physicians typically spend 15 minutes at the bedside and on the patient’s hospital floor or unit.
  • 99225 — … an expanded problem focused interval history; an expanded problem focused examination; Medical decision making of moderate complexity. Counseling and/ or coordination of care with other providers or agencies are provided consistent with the nature of the problem(s) and the patient’s and/or family’s needs. Usually, the patient is responding inadequately to therapy or has developed a minor complication. Physicians typically spend 25 minutes at the bedside and on the patient’s hospital floor or unit.
  • 99226 — … a detailed interval history; a detailed examination; Medical decision making of high complexity. Counseling and/or

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Check CCI Edits For New Vaccine Administration Codes

Many of the new code pair additions involve CPT codes that debuted on Jan. 1, with CCI now halting payment if you report certain procedures together.

For instance, you’ll find vaccine administration codes 90471 (Immunization administration [includes percutaneous, intradermal, subcutaneous, or intramuscular injections]; 1 vaccine [single or combination vaccine/toxoid])and 90473 (Immunization administration by intranasal or oral route; 1 vaccine [single or combination vaccine/toxoid]) bundled into new vaccine administration code 90460 (Immunization administration through 18 years of age via any route of administration, with counseling by physician or other qualified health care professional; first vaccine/toxoid component), and no modifier can separate these edits. This edit prevents mixing and matching the new immunization administration codes with the old, established immunization administration codes when delivering multiple vaccines at the same visit.

In addition, CCI bundles the new subsequent observation care codes 99224-99226 into inpatient neonatal and pediatric critical care codes 99468-99476.

CCI Has Good News on the Modifier Front

Not all news coming out of the new edition of CCI is bad. Effective Jan. 1, you’ll be able to use a modifier (such as 59, Distinct procedural service) to separate the edit bundling wound care management codes 97597-97602 into the newly-revised debridement codes 11042-11044. In the past, if your pediatrician performed both procedures on the same date of service, you could not collect for both no matter what, but now you will be able to if your documentation demonstrates the separate and distinct nature of the services and you append the appropriate modifier.

Swapped pairs: In addition, CCI did an about-face on several edits this round. In the past, if you reported 94660 (Continuous positive airway pressure ventilation) or 94662 (Continuous negative pressure ventilation) with an outpatient E/M code (99201-99215), CCI would reimburse you for the pressure ventilation and deny

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New AWV Codes: Here’s What the MACs Are Saying

Stop worrying if your claims were denied, you still hold a chance as many carriers are reprocessing.

Almost a year ago, practices were told that Medicare will cover an annual wellness visit (AWV) for Part B beneficiaries effective Jan. 1 and last month, CMS announced the new codes for the AWVs. Everything seemed to look perfect until came the time for claims submissions and came the denials along with it.

The MACs may have hit a few speedbumps while processing the first of the AWV claims, but are attempting to get their systems rolling smoothly as January closes out for codes G0438 (Annual wellness visit, initial) and G0439 (Annual wellness visit, subsequent). We give you answers to several questions — straight from the MACs themselves — which may help you ensure that your claims go through smoothly.

Which Diagnosis Code Should You Use?

Several subscribers have told the Insider that they submitted their AWV claims using ICD-9 code V70.0 (Routine general medical examination at a health care facility), but faced immediate denials due to MACs claiming that this is the wrong diagnosis code.

It appears that those denials were the result of a computer glitch that made the AWV codes non-payable when billed with V70.0, but some payers have already fixed this problem.

National Government Services, a Part B payer in four states, sent out a notification on Jan. 25 stating that they “omitted the editing for diagnosis code V70.0 that is allowable with HCPCS codes G0438 and G0439, and claims that were initially denied are being reprocessed.

Pinnacle Business Solutions, a Part B MAC in two states, ran a notification on its Web site on Jan. 21 stating that a system error in the claims processing system incorrectly denied claims for G0438-G0439 between Jan. 1 and Jan 20. “A…

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Ordering/Referring PECOS Edits Won’t Be Instituted Until July

Here comes a late holiday gift for Part B practices. Thanks to a new transmittal on the topic, CMS has announced that MACs won’t institute ordering/referring PECOS edits until July.

Currently, if you submit claims for services or items ordered/referred and the ordering or referring physician’s information is not in the MAC’s claims system or in PECOS, your practice will get an informational message letting you know that the practitioner’s information is missing from the system. It was previously announced that MACs would start denying these claims on Jan. 3, but CMS announced on Dec. 16 that claim denials won’t begin until July 5.

In Part B, MACs will take two steps before denying your claims. First, the carrier will check whether the ordering/referring physician is in PECOS. If not, the MAC will try to find the provider in the Claims Processing System Master Provider File. If the physician is in neither system, the claim will be rejected starting this July.

Even though CMS won’t reject your claims this month, you should still take this time to ensure that you and your ordering/referring providers are in PECOS as soon as possible, just in case the MAC edits become a reality, said National Government Services’ Andrea Freibauer during a Nov. 9 webinar on ordered and referred services.

To read the updated CMS transmittal, visit http://www.cms.gov/transmittals/downloads/R825OTN.pdf.

Hospices benefited from a separate holiday gift that CMS delivered just before Christmas – a delay of the enforcement date for the new face to face encounter requirement.

For weeks, hospices, home care providers, and their representatives had been giving CMS the full court press about the burdensome new physician visit requirement. In a Dec. 15 letter to CMS Administrator Donald Berwick, more than 25 senior and long-term care organizations joined the National…

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CPT 2011: Pay Attention To These New Joint Injection Guidelines

Remember to check for updated or revised guidelines when preparing to use your new code books for 2011, not just code descriptors. CPT 2011 includes new details for coding some common injection procedures, as pointed out at the AMA’s CPT and RBRVS 2011 Annual Symposium in Chicago. Read on for a few pointers to help stay on the right track.

The introduction of new codes for paravertebral facet joint injections in 2010 (64490-64495) meant changes to how you reported related codes. During the CPT and RBRVS Symposium, Douglas G. Merrill, MD, MBA, of the American Society of Anesthesiologists, pointed out two revised guidelines dealing with paravertebral facet (spinal) joint procedures.

Instructions in CPT 2010 directed you to report 64999 (Unlisted procedure, nervous system) if the provider used ultrasound guidance during paravertebral facet joint injections. The AMA released a correction later in 2010, and the CPT 2011 clarifies the situation. If your provider used ultrasound guidance when administering paravertebral facet joint injections, report the appropriate code(s) from 0213T-0218T (Injection[s], diagnostic or therapeutic agent, paravertebral facet [zygapophyseal] joint [or nerves innervating that joint] with ultrasound guidance …).

T12-L1 change: CPT 2010 guidelines mandated that you report 64493 (Injection[s], diagnostic or therapeutic agent, paravertebral facet [zygapophyseal] joint [for nerves innervating that joint] with image guidance [fluoroscopy or CT], lumbar or sacral; single level) for an injection to the T12-L1 joint, or nerves innervating that joint. New 2011 guidelines direct you to submit 64490 (Injection[s], diagnostic or therapeutic agent, paravertebral facet [zygapophyseal] joint [for nerves innervating that joint] with image guidance [fluoroscopy or CT], cervical or thoracic; single) instead.

In addition, the 2011 guidelines direct providers to report paravertebral facet joint injections performed without image guidance with the appropriate trigger point injection code. Submit either 20552 or 20553 (Injection[s]; single or multiple trigger…

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96446 And Dozen Others Join The List of CCI Edits

Effective Jan. 1, 2011, new CPT codes and, inevitably, new Correct Coding Initiative (CCI) physician edits are there for physicians. For version 17.0, “19,822 new edit pairs have been added to the database while 9,778 have been terminated, for a net gain of 10,044 new edit pairs,” according to Frank Cohen, MPA, MBB, of the Frank Cohen Group, in his Dec. 14, 2010, “NCCI Version 17.0 Change Analysis” announcement.

The main edits you want to be sure to watch for are those related to new code 96446 (Chemotherapy administration to the peritoneal cavity via indwelling port or catheter).

The 96446 non-mutually exclusive (NME) edits are largely what you would expect based on other chemotherapy code edits — bundles with E/M, anesthesia, venipuncture and other vascular procedures, for example. You want to be sure to watch which is the column 1 code and which is the column 2 code for these bundles.

CCI places E/M codes 99217-99239 in the column 1 position and 96446 in the column 2 position. On the other hand, CCI places 96446 in the column 1 position and E/M codes 99201-99215 in the column 2 position, as shown below:

Column 1 Column 2
99217-99239 96446
96446 99201-99215

Remember that if you report both codes in an NME edit pair without a modifier, Medicare (and payers who adopt these edits) will deny the column 2 code and pay you only for the column 1 code. The edits in the table above all have a modifier indicator of 1, meaning that you may override the edits with a modifier when appropriate, such as in the case of distinct,…

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