News to Note – April 2020
(*While COVID-19 occupies most of our time, we want to ensure you remain up-to-date on other, less pressing issues so you are prepared once we return to our usual operations)
- You might know Noridian is one of the Medicare Administrative Contractors (MACs). But you probably don’t know that they also have a separate contract to be the Supplemental Medical Review Contractor (SMRC), which reviews claims nationally. That’s right – the same company is performing two completely separate duties for the. Centers for Medicare and Medicaid Services (CMS). It seems Noridian has forgotten that these are separate contracts. In late February, the Noridian SMRC released a notice clarifying what providers should do when there is a denial for no documentation received.But,they released that notice on each of their MAC jurisdiction sites and not on the SMRC site. What good is that notice to the providers in the other 10 MAC jurisdictions who have no reason to read Noridian’s MAC jurisdiction notices?
- Alsoat the end of February, CMS announced the awardees for the Emergency Triage Treat and Transport Model demonstration project, called the ET3. In this program, ambulances dispatched to respond to emergencies will no longer be obligated to transport Medicare beneficiaries to a hospital. They are permitted to set up programs where the patient can be triagedby paramedicsas not needing care in an emergency department but instead can be transported directly to alternative location or treated on scene by a provider,including using telehealth providers. At first, this sounds like a great program which could help with emergency department overcrowding.But,the program only applies to fee-for-service Medicare patients. That means paramedics will need to become insurance experts to determine if the patient is eligible for transportation to an alternative location. CMS does suggest that the awardees work with other payers, including commercial insurers and Medicare Advantage, but they’re on their own to do that. CMS gives several examples of alternative destinations including federally qualified health centers, physician offices, behavioral health centers, and urgent care centers.But,they must have a formal agreement in place for each destination. Imagine trying to get every doctor in town to sign an agreement. They also have to have provisions for alternative locations or treatment of the patient in place to be able to be provided 24/7.There is a lot more to theprogram whichwasslated to startthisSpringbefore COVID-19 hit, but now…who knows?
- CMS used a provision in their policies that allows them to ask another contractor to start serving as a Beneficiary Family Centered Care – Quality Improvement Organization (BFCC-QIO). CMS has called this contract the Indefinite Delivery, Indefinite Quantity contract and it was awarded to Avar Consulting. They have already started requesting medical records for high weighed DRG audits but there is no word yet if they will audit short stays.
- At the end of March, the district court in Connecticut issued a decision in the Alexander v Azar case concerning observation patient appeal rights. The bottom line is that the judge has ordered to allow appeal rights for patients whose status is changed via condition code 44. CMS is certain to appeal so we will see what happens.
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