Without Warning – the Outpatient Prospective Payment Final Rule Cuts HBOT Facility Fees by 40%
What we need is for people to submit a comment, and to spread the word that hyperbaric oxygen therapy is in a crisis.
ICD-10 Changes
A new ICD-10 Clinical Modification (ICD-10-CM) code set took effect October 1, 2023. In this new code set, there are many code additions, deletions, and modifications.
Modifications Needed to Wound Center EHR to Support DME Orders for Dressings
Your EHR will need to be modified to meet the DME documentation requirement burden (and if you think the list below is ridiculous – it is, but it’s still required).
Mindfulness, Electronic Health Records and Ebola
A recent Ebola outbreak in Dallas was blamed on a “flaw” in the hospital’s electronic health record (EHR). Yes, you heard me correctly.
JZ Modifier Use With Skin Substitutes
CMS has issued guidance requiring the use of Modifier JW on all claims for biologicals from single-dose containers that are separately payable under Medicare Part B when there are unused / discarded amounts.
Observations About the 2024 PFS Pertaining to Cellular and/or Tissue-Based Products in the Doctor’s Office Setting
On July 13, 2023, CMS issued proposed rules for the 2024 Physician Fee Schedule (PFS) and the Hospital Outpatient Prospective Payment System (OPPS).
“Hidden RAC Audits” – Seriously…
Attorney Knicole Emanuel has posted a chilling blog on her site about hidden RAC (Recovery Audit Contractor) audits.
Ulcer Debridement & Total Contact Cast Application
We cannot submit CPT®[1] coding for both ulcer debridement and total contact cast application when both are performed for the same ulcer at the same encounter.
Listen to a Podcast with Dr. Helen Gelly, “How to Get Your Wound Clinic Through an Audit”
On your drive home, check out this podcast with Helen Gelly MD, FUHM, FACCWS, UHM/ABPM, “How to Get Your Wound Clinic Through an Audit.”
HBOT Facility Payments are Under Attack (Physician Supervision is Next…)
We need individuals at all training levels to comment on the proposed changes that CMS is proposing in the Medicare Physician Fee Schedule (MPFS) for the technical payment of HBOT.
Check Out the Long List of CTPs (“Skin Subs”) Not Covered in the CGS, First Coast, & Novitas LCDs
Three Medicare Administrative Contractors (MACs) issued their final Local Coverage Determinations (LCDs) for Cellular and/or tissue-based products (CTPs).
Highlights of the 2024 Outpatient Prospective Payment System (OPPS)
You should read the documents yourself, but here are some highlights of the 2024 OPPS proposed rule (in no particular order).
PRESS RELEASE: New Study in Journal of Medical Economics Shows Decrease in Chronic Wound Medicare Costs Amid Increase in Chronic Wound Prevalence
Over 2014-2019, the number of Medicare beneficiaries with chronic wounds increased 13% to 10.5 million amid a surprising 20% reduction in chronic wound expenditures. Researchers seek to explain why, and what the policy implications may be.
New Surgical Treatment of Nails Policy
This policy is being contested by multiple stakeholders, including the American Podiatric Medical Association.
Chiropractors Treating Diabetic Foot Ulcers?
I am highly suspicious that this is being driven by the manufacturers of CTPs, and is yet another indication that the CTP industry is out of control.
Prior Authorization Nightmares & the Antidote to Burnout
Here’s a doctor who knows his days are numbered, and he’s making the most of every one because he has a purpose.
HIPAA Does NOT Require That Healthcare Providers Obtain Patient Authorization to Disclose Protected Health Information (PHI) to Other Clinicians for Treatment Purposes
HIPAA does NOT require that health care providers obtain patient authorization to disclose protected health information (PHI) to other clinicians for treatment purposes.
Medicare Extrapolation Under 50% Error Rate? No Extrapolation ALLOWED!
In Knicole Emanuel’s latest blog, she discusses the new Medicare rules stating that no extrapolation may be run if the error rate is under 50%.
Thoughts on the ICD-10-CM 7th Character in the HOPD
In the HOPD, for injuries and external causes, the “A” value should be used for the 7th character to report for active treatment.
The Quality Payment Program and What it Means for the Future of Wound Management & HBOT
The Big Picture of Physician Payment Within CMS The big picture is still playing out for physician...
The Lymphedema Treatment Act Passed!
The LTA will improve insurance coverage for the medically necessary, doctor-prescribed compression supplies that are the cornerstone of lymphedema treatment.
Medicare Posts Final Rule for 2024 Policy Changes to Medicare Advantage Plans – Review of Medical Necessity Requirements
Undersea and Hyperbaric Medicine IS a recognized medical subspecialty so that might help patients obtain necessary HBOT treatments.
New CTP Coding Requirement
Effective July 1, 2023, providers must report the JZ modifier when an entire skin substitute product is applied to a Medicare Part B beneficiary and there is no waste.
Medicare Posts Final Rule for 2024 Policy Changes to Medicare Advantage Plans
The rule goes into effect Jan 1, 2024. Whether this will make MA less of a Medicare DIS-advantage is yet to be seen.
CMS Published 2023 Medicare/caid Health Care Providers’ Audit Process – Read Attorney Knicole Emanuel’s Offer to Clinicians Being Audited
Nearly every wound care and hyperbaric medicine practitioner is undergoing some sort of Medicare audit.
New Suture / Staple Removal CPT® Codes
These CPT codes can be used if the patient is not in a global period for the provider who removes the sutures / staples.
Wound Care Services and the Jimmo Settlement – Why it Matters to Patients Who Are in Palliative Wound Care
Unfortunately, some Medicare auditors are not following the law as it pertains to the presence or absence of a beneficiary’s potential for improvement.
Are Verbal Orders Prohibited?
There are no federal regulatory prohibitions on the use of verbal orders, although CMS frowns upon verbal orders in the context of medications.
Give Yourself the Gift of an Audit
A self-audit is a miserable “gift” to give yourself, but a real audit is a gift that just keeps on giving when you are not prepared.
Debunking Myths About Who Can Enter Information Into the Patients’ Medical Record
In its effort to debunk regulatory myths, the American Medical Association (AMA) has produced this useful fact sheet, “Who can document components of E/M services?”
Check Out the AMA Summary of the 2021 Rules for Billing E/M Visits by Time
The AMA reminds physicians that that there is no requirement to document the total time spent if the physician is not using time to calculate the level of service.
The AMA Debunks Myths Around Clinical Support Staff Documentation Inside EHRs
The American Medical Association (AMA) has been debunking several myths in a project called “Debunking Regulatory Myths.”
Reminder: 10 Days Until the Close of the 2022 MIPS Data Submission Period
The Centers for Medicare & Medicaid Services (CMS) has opened the data submission period for Merit-based Incentive Payment System (MIPS) eligible clinicians who participated in the 2022 performance year of the Quality Payment Program (QPP).
District Court Upholds ALJ’s Decision That Extrapolation Was Conducted in Error
A new post by attorney Knicole Emanual is vitally important for anyone under a Medicare audit.
Check Out This Article by Kathleen Schaum in Today’s Wound Clinic
Check out this article by Kathleen Schaum in Today’s Wound Clinic: Are You Prepared to Implement the 2023 CTP Final Rules?
Pandemic Emergency Declarations Scheduled to End May 11, 2023 – Check Out These CMS Resources
On January 30, 2023, the Biden-Harris Administration announced its intent to end the national emergency and public health emergency (PHE) declarations related to the COVID-19 pandemic on May 11, 2023.
More Exciting E&M Changes!
The process by which office and other outpatient evaluation and management (E&M) levels (CPT® 99202 – 99215) are selected was changed by the AMA CPT® Editorial Panel effective January 1, 2021.
Join the Fight with the Alliance of Wound Care Stakeholders
Are you feeling frustrated and helpless in the face of overwhelming regulatory burdens, capricious...
Consolidation of E&M Services in 2023
Effective January 1, 2023[1], under the guidance of the AMA CPT Editorial Panel, many evaluation...
Check Out This Post: The Ugly Truth about Medicare Provider Appeals
The way these audits work, it’s assumed you are guilty and you have to prove you are not – in a one way conversation.
Documentation Requirements for Wound Care Services – Part 3
Not only do you need to document the goals of therapy, but you need to document whether your treatments are achieving them.
Documentation Requirements for Wound Care Services – Part 2
Healing does not have to be the goal, but if not, we had better state goals like, “getting the wound to a state in which the patient and family can care for it with only periodic physician assessment,” or “preventing progression and hospitalization.”
Documentation Requirements for Wound Care Services – Part 1
I am going to discuss the wound care policy that’s been in effect since 07/23/2020 for the Novitas jurisdiction.
CMS and CTPs (Cellular Tissue Products)
The full attention of every aspect of CMS is now focused on the use of CTPs. Why do you think that is?
Place of Service for “Observation” Status Patients
It is important to know if the patient is in the hospital under “observation” status or “inpatient” status because this affects CPT® code selection.
The 2023 Medicare Physician Fee Schedule Proposed Rule is Out
Sweeping changes are proposed for cellular and/or tissue-based products (CTPs) when applied in the physician’s office.
RAC Provider Audits and Why You Need to Worry
If you want to know what topics the Centers for Medicare and Medicaid Services (CMS) are auditing,...
The Importance of CPT® 99024
Yes, specialists who are not the admitting / primary physician may submit CPT 99304 in certain situations.
Watch Session 4 of the Intellicure Webinar Series: Keeping Your Payments — After An Audit — Is In Your Control
On Wed., Oct. 26, Dr. Caroline Fife and Kathleen D. Schaum presented the fourth and final session...
Watch Session 3 of the Intellicure Webinar Series: Keeping Your Payments — After An Audit — Is In Your Control
On Wed., Oct. 19, Dr. Caroline Fife and Kathleen D. Schaum presented the third session of...