Minutes for Region D DAC Teleconference with CMS/NAS/CEDI
Wednesday, January 9th, 2013 3:00 PM CST
Leslie Rigg, Region D DAC Chair opened the meeting and welcomed everyone. Introductions were done and the meeting protocol was reviewed.
The meeting minutes from the Face to Face Meeting in Atlanta (November 2012) were reviewed. Bob Clock made a motion to approve, and Peggy Walker seconded it. All were in favor. The minutes were approved.
The CEDI Update was provided by Sally Hopkins and is attached to the minutes.
Mr. Ralls from CMS was not in attendance, thus no CMS update given.
No Provider Enrollment update was given. Mark Majestic and Zabeen Chong had previously sent regrets they could not be in attendance at this meeting.
Dr. Whitten provided the Medical Director Update.
Dr. Whitten said he had just returned from an Open Door Forum on the PMD Demo. CMS does not yet have data to release but did say that the process is steadily improving. More information on this will be made available in the near future.
Dr. Whitten informed the DAC that there had been a number of updates on the following policies:
When the AFO policy was released there was much discussion held on the size and fit. Most of it pertained to the L1900 and L1910-L1990 or to ankle gauntlets. This has been recently updated and should be much clearer.
The Glucose Monitor Policy was updated and the consumable/non-consumable language was added into the LCD. It better explains what documentation is necessary for high end users especially in the audit process. This became effective 11/01/12.
The O2 and PAP Policy were updated. Home sleep testing is now referred to as “overnight oximetry” to minimize confusion with home sleep testing. This is done when diagnosing obstructive sleep apnea.
Dr. Whitten wanted to mention some points he felt might be important as he referenced the questions.
In regards to the IV PEN question #3. It may be helpful to point out that the point is to document the proof of delivery, not the proof of shipment.
They are presently reviewing the ostomy question from Med Supplies but it is important to note that these changes were subject to comment at the time this was revised.
The Rehab question #10 regarding the order in which the face to face, 7 element order, and detailed product description are gotten was discussed. This is discussed in more detail in the actual Q & A.
In question 12 The Rehab Team had requested the opportunity to present a list of diagnoses they felt might meet the criteria. Dr. Whitten explained that the appropriate way to do this is to submit an LCD Reconsideration. The link to do this was provided with the response to the question.
Dr. Whitten explained that they were unable to answer questions 18-21. These all have to do with Medicare C which they are not able to access data from.
Deanne Birch asked if there had been any update on the examples she sent to Dr. Evan’s and Dr. Whitten regarding the denials from the state Medicaid’s for overlapping dates billed. The history of this concern is as follows:
This issue comes from the Medicare proof of delivery requirements stating the bill date must be the ship/delivery date which results in overlapping dates on the claims. Dr. Evans asked for Deanne to please resend the information again. She said that it is important that they look at all underpayments as well as overpayments. Deanne will resend Dr Evans and Dr. Whitten the information. Deanne did clarify that most of the underpayments for Region D were with California Medical Claims, while other denial example were in Region C.
*** Deanne requested that other suppliers in the DAC provide examples of these Medicaid denials for overlapping dates. These examples must not include PHI and should be sent to Barb to include with correspondence to Dr. Evans.
Dr Evans explained that RAC is a national program and covers 4 regions. Each region prepares their own issues and query. They are submitted to CMS for approval and then released to providers throughout the region.
*** Update: 10/17/12 Tiffany Dschaak did forward the prior emails and documentation to Dr. Evans whom responded that she will follow up internally next week and research. Deanne will forward this email to Barb.
Dr. Whitten had not heard anything but encouraged the DAC to send a note to Dr. Ellen Evans, and Jim Ralls explaining that we would like an update at our meetings and how sorry we were they missed this meeting. He will try and follow up with them on this. Since our upcoming meeting is in Las Vegas he felt that Dr. Evans would try to be there. Barb will take care of this and see if we can have them attend our meetings.
Jody Whitten provided the POE update. It is attached to these minutes.
Leslie Rigg, Chair discussed the Audit situation and how it is affecting providers. Many are overwhelmed by the number they receive. The DAC as a whole has heard many concerns and are trying to get examples together from members that they can submit as concerns. The DAC will continue working on this and hopes to have something to present by our next meeting.
Leslie brought up the CO-226 denials. Reports are that it is slowing in some areas but still very significant in others. Jody explained that suppliers should not longer be receiving these if their information was submitted within the time frame. There was a time that this would happen but things have been fixed on their end. If we are still seeing this after 10/01/12 we should submit these examples to her.
Deanne Birch asked if there had been any response or discussion with CMS on the letter to Marilyn Tavenner, from NHIA and the IV Pen Team on Proof of Delivery. Dr. Whitten responded no, he has not heard anything. She asked if Dr. Whitten could possibly direct it to CMS. They believe this could be part of the solution when addressing the number of audits that are seen.
Jody Whitten Provider Outreach and Education gave the POE Update. This is attached to the minutes.
Deanne Birch presented the Proof of Delivery issue. This has been a concern since 2001. Deanne asked if the Medical Directors had seen any response or had any conversation with CMS since the December 2011 letter from NHIA to CMS Administrator, Marilyn Tavenner, Re: Medicare and Medicaid Program; Regulatory Provisions to Promote Program Efficiency, Transparency, and Burden Reduction (CMS-9070-P).
Summary quote from the letter: “We do not understand the basis for the use of the shipping date as the date of service. We believe that claims reflecting the actual usage period for PEN, EN, IVIG and external infusion pumps would be more accurate and would avoid the confusion that results from overlapping claims. Therefore, we urge CMS to allow suppliers to use the date that a beneficiary begins using PEN, EN, IVIG and other drugs and supplies used with external infusion pumps as the date of service.”
Dr. Whitten explained they have not heard anything back from CMS on this yet. He will notify us when he does.
The next Combined Meeting will be at 10:00 am PST on March 20th, 2013. It will be held at the Mandalay Bay North Convention Center in Room Coral A.
With no further business at hand the meeting was adjourned.
Respectfully,
Barb Stockert
Administration