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Medicare Compliance & Reimbursement

Industry Notes:

CMS Issues New 'Centralized Flu' NPP Specialty Code

If you were beginning to think that CMS had a specialty code for almost everything, here's news that will bolster your suspicions. The agency recently announced that it would be issuing new specialty code 'C1' to designate non-physician practitioners whose primary specialty is centralized flu.

Although CMS does not expound on how to use the specialty code, most analysts believe that it will be used by facilities that perform mass flu immunizations. The new code will not be billable until midway through the upcoming flu season, since it takes effect on Jan. 1, 2013.

Specialty code C1 is only applicable to the CMS-855B enrollment application, CMS notes in MLN Matters article MM7884. To read more about the new code, visit

Get Ready: CMS Plans to Move Medicare SNF payments from Volume to Value-based

In June, CMS sent a report to Congress detailing its plans to implement a Value-Based Purchasing Program (VBP) for skilled nursing facilities. We see the future of health care reimbursement moving from the current volume-based payment methodology to value-based purchasing, David Gifford, MD, MPH, senior vice-president quality and regulatory affairs, for the American Health Care Association (AHCA), tells Eli. Both AHCA and the National Center for Assisted Living (NCAL) strongly support this move, he notes.

The report, which was required by Section 3006 of the Affordable Care Act, discusses the current state of various elements that would be part of a SNF VBP and where the agency will go from there, explains Cassandra Black, senior technical advisor for CMS's Performance-Based Payment Policy Group. These include the following:

  • The agency's current quality measures and process for developing them;
  • Additional quality measures that the agency may want to add;
  • A description of the process for reporting the measures;
  • How payments could potentially be structured;
  • Types of incentive payments;
  • Possible funding sources for the payments; and
  • How the agency would share any information gathered with the public.

The report concludes with a roadmap for implementation of a SNF VBP. CMS will analyze the results of the recently concluded Nursing Home Value Based Purchasing demonstration project, expected to be ready in the fall of 2013, before moving forward with a SNF VBP, Black notes.

Gifford says that this report summarizes many of the ongoing demonstrations on VBP which is helpful guide as SNFs transition from fee-for-service to value based purchasing. Copies of the report are available at: .

Avoid These Diagnoses On Your Hospice Claims To Quell Denials

Don't submit a hospice claim with one of these diagnoses, unless your documentation thoroughly backs it up -- Debility, Alzheimer's disease, and Chronic Airway Obstructions. Medicare Administrative Contractor CGS is continuing a widespread review of hospice claims with these diagnoses, it says on its website.

In a probe review that ran from October 2011 through March 2012, CGS denied most claims for failing to show the terminal prognosis or for certifications that were missing, incomplete or not timely, the MAC says. Hospices also failed to submit documentation at all in response to the ADR.

Reminder: The patient's appropriateness for the hospice benefit must be clearly supported in the medical record from admission and throughout the hospice care provided, CGS tells hospices. Look to local coverage decisions for tips on improving documentation of the terminal prognosis, the MAC adds.