This was posted on the WPS Medicare ListServ and seems to clarify it affects claims based on date of service, not date transmitted.
QUESTIONS AND ANSWERS (QS & AS) REGARDING THE HOLDING OF CLAIMS PAID UNDER THE MEDICARE PHYSICIAN FEE SCHEDULE (MPFS)
The Questions and Answers below apply to the recent decision by the Centers for Medicare & Medicare Services to hold claims paid under the Medicare physician fee schedule (MPFS) up to 10 business days that contain July 2008 dates of service.
Q1. Will claims containing services paid under the MPFS be held that contain both June and July dates of service?
A1. Yes, your local contractor will hold the entire claim for 10 business days.
Q2. Will claims be held that contain both services paid under the MPFS and services paid under a separate fee schedule?
A2. Yes, claims that contain both services paid and not paid under the MPFS will be held. For example, a claim with a July date containing an Evaluation and Management code and a drug code would be held.
Q3. Does the holding of claims paid under the MPFS also include anesthesia and purchased diagnostic services?
A3. Yes, contractors will hold all claims with dates of service July 1, 2008, and after that contain services paid under the MPFS, including anesthesia and purchased diagnostic services.
Standard disclaimer: Do not take this as billing advice. Genius Solutions requires you to decide when to bill your claims. Our Support Department will not be able to answer questions regarding this.
You can follow the latest news on this at http://news.google.com/news?q=CMS+JULY+FEE+CUT
and feel free to send me an email at mark-2008@geniussolutions.com if you have any comments.
Today I was talking to Patrice, a THOMAS trainer from Florida, and she had what I thought was an interesting idea. If Congress does not act before July 16 and CMS processes physician claims at a 10.6% reduction, that there is then a possibility that later Congress may act to make that 10.6% payment later in a separate payment. If this scenario happens, it would be a lot of work for billers to have to repost the second payment.
Her suggestion was that maybe holding your Medicare claims until after you knew you would not be paid at the reduced rate might save billers time in the long run by not having to double post. Of course you would have to have be able to survive without Medicare payments at all until then.
Another strategy would be go ahead and bill, but don't post the payments until you are sure there won't be an adjusting payment coming down the road. More work, but you may get paid sooner.
I'm not sure what is going to happen, but I hope it will be a good topic to be included in the July 11 Genius Solutions Conference Call.
Again, this is outside of Genius Support, but I felt it might be interesting to our clients.
A couple of people got the email invitation to the Genius First Friday Conference Call and couldn't wait to hear what and why we had the topic Medicare holding claims 7/1 to 7/15/2008, so here is a link to Google News that should point you to some stories about the scheduled 10% fee cut for Medicare providers and attempts to block it.
http://news.google.com/news?q=CMS+JULY+FEE+CUT
Update: I found this article:
CMS has requested the following information be furnished to providers of health care.
To the extent possible, CMS is working with Congress, health care providers and the beneficiary community to avoid disruption in the delivery of health care services and payment of claims for physicians, Non-Physician Practitioners (NPPs) and other providers of services paid under the Medicare Physician Fee Schedule (MPFS), beginning July 1, 2008. In this regard, CMS has instructed its contractors to hold these claims for the first 10 business days of July, for dates of service in July. This should have minimum impact on provider cash flow because, under current law, electronic claims are not paid any sooner than 14 days (29 days for paper claims) after the date of receipt. Meanwhile, all claims for services delivered on or before June 30, 2008, will be processed and paid under normal procedures.
After 10 business days, contractors will begin releasing claims to process under the fee schedule which implements current law. This, of course, could result in claims being processed with the negative 10.6 percent update. If a new law is enacted which changes the negative 10.6 percent update, retroactive to July 1, CMS is prepared to automatically reprocess most of those claims that have already processed.
Under the Medicare statute, Medicare pays the lower of submitted charges and the Medicare fee schedule amount. Claims with dates of service on or after July 1, 2008, billed with a submitted charge at least at the level of the January 1 – June 30, 2008, fee schedule will be automatically reprocessed, if Congress retroactively reinstates the update that was in effect for that time period. Any lesser amount will likely require providers to resubmit a revised claim.
To the extent possible, providers may hold claims in-house until it becomes clearer as to whether new legislation will be enacted or until cash flow becomes problematic. This will reduce the need for providers to reconcile two payments (i.e., the initial claim and the reprocessed claim), and it will simplify provider billings of beneficiary coinsurance and payment calculations for payers that are secondary to Medicare.
Due to the Fourth of July holiday, the July Genius Solutions First Friday of the Month Conference Call is scheduled for July 11, 2008 at 10:00 a.m. Eastern time.
Planned topics for the conference call (so far) are:
CMS Matching Legal Business Name and IRS numbers causing problems?
TaxID/SSN on Rendering Provider. Required?
Medicare holding claims 7/1 to 7/15/2008
Florida Blue Shield password changing requirements
General interest questions and answers from the listeners.
Final comments
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At 10:00 7/11/2008 you may call the regular main number 1-712-432-3000
Conference Bridge Number: 478288
Please note, it sometimes takes up to a minute to ring through and get prompted for the bridge number.
If at the time of the Conference Call you can't possibly get in on the main number, then you should check the http://www.geniussolutions.com/news page to see if we have an alternate number.
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We plan to also host a "Webinar" at the same time, so if you have high speed Internet you can watch Genius' computer screen while you listen to the phone call.
To join the webinar you will need to register at https://www2.gotomeeting.com/register/813307157 as soon as possible. After you register, a link will be emailed to you. This link is used to join the webinar at 10:00 a.m. on July 11, 2008. We recommend trying to join the webinar about 10 minutes before the webinar is scheduled.
We hope you find the Webinar Web Site easy to use. We may talk about connecting to the webinar at the beginning of the Conference Call to see how you did and possibly have some last minute tips for those having difficulty connecting. The webinar does not play the audio, you still need to dial into the conference call phone number.
Even if you do not have high speed internet, or can't get the webinar to work on your computer, you can still hear the audio portion with the Dial-In Conference Number, just as all the previous conference calls have worked.
As always, we will try to record the conference for those who can not attend in person and make it available on our News Page a couple of days later.
The next scheduled Genius Solutions First Friday of the Month Conference Call will probably be August 1, 2008.
The recording of the June 6, 2008 Genius Solutions First Friday of the Month Conference Call is available here in MP3 format.
See you July 11, 2008 at 10:00 Eastern time for the next one.
We have completed our Summer 2008 newsletter.
The June Genius Solutions First Friday of the Month Conference Call is scheduled for June 6, 2008 at 10:00 a.m. Eastern time.
Planned topics for the conference call (so far) are:
1. DME DMERC changing from Adminastar to NGS CEDI. cedi@geniusolutions.com
2. Genius Solutions Summer 2008 Newsletter on News page
3. The NPI Only deadline one week later. What happened, what to do
4. 24% of medicare claims rejected May 23, usually 6%, according to Emdeon Business Services
5. WPS Medicare sending legacy number on some ERAs
6. One client's BCBSM EDI termination date problems
7. Availity (First Coast Florida client) "Legacy identifier, EID may not be used" change
8. BCBSM "looking into" problems with "many legacy to one npi"
9. BCBSM Crossover claims getting Non Payment Code 535 - what to do?
10. One client's experience with one NPI for 3 locations
11. How to easily change all claims to NPI Only
12. General interest questions and answers from the listeners. 5* to raise/lower your hand
13. Final comments
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Last month we had over 100 callers which exceeded the Conference Call system we use. So this month we will try to add a second number in case there are more callers. Unfortunately the second number is "Listen Only", meaning you can't raise your hand or be unmuted. So if you think you might want to join the conversation, dial the first number, if know you just want to listen or can't get through the first number, then use the second (listen only) number.
If you might want to join the conversation:
Dial-In Conference Number 1-712-432-3000
Conference Bridge Number: 478288
Please note, it sometimes takes up to a minute to ring through and get prompted for the bridge number.
If you only want to listen or can't get thorough the first number:
Dial-In Listen Only Conference Number 712-432-1399
Access code 138994638
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We plan to also host a "Webinar" at the same time, so if you have high speed Internet you can watch Genius' computer screen while you listen to the phone call.
To join the webinar you will need to register at https://www1.gotomeeting.com/register/941298605 as soon as possible. After you register, a link will be emailed to you. This link is used to join the webinar at 10:00 a.m. on June 6, 2008. We recommend trying to join the webinar about 10 minutes before the webinar is scheduled.
We hope you find the Webinar Web Site easy to use. We may talk about connecting to the webinar at the beginning of the Conference Call to see how you did and possibly have some last minute tips for those having difficulty connecting. The webinar does not play the audio, you still need to dial into the conference call phone number.
Even if you do not have high speed internet, or can't get the webinar to work on your computer, you can still hear the audio portion with the Dial-In Conference Number, just as all the previous conference calls have worked.
As always, we will try to record the conference for those who can not attend in person and make it available on our News Page a couple of days later.
The next scheduled Genius Solutions First Friday of the Month Conference Call will probably be July 11, 2008 since the first Friday is a holiday.
The following was in the WPS Listserv on 6/1/2008, and is the first real news and statistics I've seen from a Medicare contractor regarding the May 23 deadline:
Medicare FFS has made excellent progress over the past week, since fully implementing the NPI. In fact, the favorable trend in NPI compliance is better than we expected with most of the Medicare contractors reporting that over 90 percent of claims are NPI-compliant, with some reporting 100 percent compliance. Furthermore, we have experienced relatively few problems to date and we are working daily with our contractors to help resolve those issues that exist.
We would like to point out that, on May 23, there were a number of rejections for claims with legacy numbers in the SECONDARY provider identifier field. As indicated, we are seeing this particular issue rapidly improve as more and more providers realize the need for NPI-only in secondary identifier fields and the relative ease in which they can appropriately complete these fields.
In the way of background, Medicare allowed legacy-only numbers in the secondary fields up until May 23. To assist those billing providers which, after reasonable effort, are still unable to obtain NPIs for secondary providers, Medicare has instituted a temporary measure that allows billing providers to use their own NPI in secondary identifier fields. Thus, providers are not unduly burdened to ensure secondary identifier fields have an NPI.
While CMS is seeing some issues in some areas of the country, we are continuing to monitor and assist providers in becoming fully NPI-compliant. Progress has been substantial in recent days and weeks and this favorable trend is expected to continue. We would also like to mention that we monitor Medicare Part C (Medicare Advantage) and Part D (Prescription Drug Program) and we have received no reports of NPI problems.
Medicare Reminder--Accelerated/Advance Payments May Be Available for Financial Hardships Associated with NPI Implementation
Some Medicare providers, physicians, other practitioners, and suppliers might experience cash flow issues during their efforts to implement the NPI. The Medicare contractors and the Centers for Medicare & Medicaid Services (CMS) will consider, in limited circumstances, the availability of advance or accelerated payments where facts and circumstances fall within the scope of the CMS regulations and/or manual requirements for such payments.
In general, entities who bill without an NPI do not warrant consideration for an advance or accelerated payment since Medicare providers have been given ample time to secure an NPI.
Medicare providers who may be experiencing cash flow problems related to NPI claims processing issues should contact their Medicare contractor to determine if they are eligible for an advance or accelerated payment. The Medicare contractor will review the request and provide a decision.
We updated our "How to quickly set all insurance codes to NPI Only" documents to help answer common questions and we thought it might be good to clarify some things when activating this setting.
Here are the instructions for eTHOMAS or dTHOMAS and THOMAS Lite.
1. Don't expect your NPI Indicator in your Insurance Code File screen to change. For example, they won't suddenly all have "N" in them. In fact you really can't tell you did it right unless you print a claim.
2. This setting ONLY affects Insurance Codes that have a blank NPI Indicator. If you have "B" or "L" in your NPI Indicator that Insurance code will not be NPI Only.
3. You don't have to go in and change all your NPI indicators from "N" (NPI ONLY) to blank.
4. If you think you need to report both legacy and NPI for a certain payor, then set that one Insurance Code NPI Indicator to "B". If you think you need to report ONLY Legacy, and NO NPI, then set that one Insurance code to "L". We would not expect this to be necessary, and it is not recommended unless you have a very good reason such as a payor saying they were not NPI only ready and require legacy numbers.
5. You can confirm you did it right and it is working by printing a few claims. Look for your Organizational NPI in Item 33 of the CMS-1500 form and your Individual NPI on 24J. If you are really a "sole provider" and do not have an organizational NPI, you should see your Individual NPI in Item 33, and 24J will be blank.
6. We recommend you proceed cautiously if you decide to enable this setting. This setting is intended for people that are confident all (or most) of their payors are working with NPI Only.
7. We would recommend sending a couple of claims NPI Only to each payor, then in a day or two, check your EDI Reports. Your 997's should still say accepted, and you should not have 277 NPI related rejections before billing large numbers of claims.
I am surprised, thus far, that NPI Only does not seem to be as bad as I expected. Maybe everyone is holding their breath (and claims).
First Coast Florida was the first rejection I saw and that seems to be because the claims had a tax id number in the 2310b rendering provider loop. So far we have seen only one client with this problem, please let us know if you experience it as well. Please don't try removing your tax id yourself, because it is required in the Pay-to-Provider loop for tax purposes.
I have spoken to a few billers this week that were bummed out. Even though they were proactive and "got their NPI" when the enumerator first opened up, they just found out they need an Organization NPI (Type 2) and need to register/enroll with Medicare and BCBS. I'm afraid that might be a lengthy process. The simple way to explain it is, if you are incorporated, the Final Rule requires you to have an Organizational NPI for the corporation and an Individual NPI for the provider, even if you are not a "group". Only if you really are a "sole provider" would you not use an Organizational NPI. Please keep in mind Genius can not tell you how to enumerate yourself, please check with your CPA and payors.
Today I saw a BCBSM 277 rejection with "A271 Rend Prov State License number missing/invalid". The example rejection I saw was dated May 22, which is before the NPI deadline. The problem is, we don't see a problem with the claim file, nor did the BCBSM EDI rep we spoke to. The U277 report says "277 UNSOLICITED REPORT - P&A" on the top, therefore I can tell it was not rejected by the EDI department, it was actually rejected by Blue Cross. Our BCBSM EDI rep is looking in to it and will let us know what they find. This might be affecting a few people. We are continuing to work with BCBSM EDI and should have it sorted out soon. Because this was before the NPI deadline we are not sure if it is related.
Seems like CMS Medicare is sticking to their guns enforcing the May 23 deadline. I have not see any statistics of how many claims they are rejecting or any announcement of any contingency plan.
If you have been holding claims, or just starting NPI Only, I would recommend you try billing a couple of claims NPI Only now that we are past the deadline to ensure you are ready to go. A day or two after you transmit a couple of claims, check your EDI response files to make sure they are working well before doing large volumes of claims.
If you are getting NPI rejections that you can't figure out, first make sure you have notified your payors of all your NPI numbers. You could also try printing the claim to paper to see if the correct NPI numbers are in the right places. If all else fails, then please fax us a copy of your rejection to speed up figuring out what needs to be done. Our fax number is 586-751-3016. Please include your name, office name, phone number, and best times to call.