PPM Pages October 2011

Pursuant to the final rule issued by Centers for Medicare & Medicaid Services (“CMS”) on August 31, 2011, physicians now have until November 1, 2011 to apply for an exemption to avoid financial penalties for failing to comply with Medicare's
e-Prescribing requirements. Precision strongly recommends that all physicians who did not issue and report at least 10 electronic scripts by June 30, 2011 review the allowed exemptions and submit an online application for each applicable exemption category as soon as possible to avoid the 1.0% reduction in Medicare Part B claim payments in 2012. 

The six exemption categories are as follows:

1. Your practice is located in a rural area without high-speed Internet access.
2. Your practice is located in an area without sufficient available pharmacies for e-Prescribing.
3. You are registered to participate in the Medicare or Medicaid electronic health record incentive program and you adopted certified EHR technology by October 1, 2011, prior to requesting an exemption.
4. You are unable to e-Prescribe because of local, state or federal laws or regulations.
5. You do not prescribe on a regular basis.
6. There were too few opportunities for you to report the e-Prescribing measure because of limitations of the measure’s denominator.

If you meet one or more of the aforementioned exemptions and would like assistance with submitting your application to avoid the 2012 penalty, please contact Jessica Poepping, Precision EHR Implementation Specialist, atJPoepping@precisionpractice.com.

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Please don’t forget that CMS issued a revised Advance Beneficiary Notice (“ABN”) earlier this year. The revised ABN, and associated instructions, can be accessed at http://www.cms.gov/BNI/02_ABN.asp. Precision recommends utilizing the new ABN (with the release date of 3/2011 printed in the lower, left-hand corner) today. Commencing January 1, 2012, CMS will consider all prior ABN forms invalid.  CMS had previously indicated the revised ABN would be effective September 1, 2011 but extended the date to January 1, 2012.

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Modifier 33, effective since January 1, 2011, precludes carriers (including commercial carriers) from imposing cost sharing on a physician practice or patient for an office visit if the primary reason for the office visit is the receipt of preventative services.  Cost sharing for an office visit, however, is permitted (i) if the office visit is billed separately from the preventative services and the primary purpose of the office visit is not the receipt of preventative services or (ii) when the provider is out-of-network.

Modifier 33 should be appended in the following circumstances:

• The primary reason for the office visit is preventative and the physician desires to mark the service as preventative so the carrier will process the claim accordingly.
• The primary visit is preventative but resulted in a therapeutic service.
• Multiple preventative services are provided the same day and the physician wants to identify each preventative service that day.

Please note that Modifier 33 does not need to be appended for inherently preventative services, such as services that include the word “screening” in their description.

Carriers are implementing this policy as new coverage is established or as existing coverage is renewed. If you notice any of your carriers are passing on part of the cost for the above-mentioned services to your practice or your patients, we recommend reviewing the coding of the services, and if billed correctly, contacting your carriers to question the adjudication of the claims.

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