Attorney Knicole Emanuel has posted a chilling blog on her site about hidden RAC (Recovery Audit Contractor) audits.
Blog Posts About Regulatory Updates
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).
New Surgical Treatment of Nails Policy
This policy is being contested by multiple stakeholders, including the American Podiatric Medical Association.
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.
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.”
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?
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.
The Devil in the Documentation Details of the Proposed Novitas LCD on “Skin Substitutes” – Part 5
In case you think you are safe because you live in another MAC jurisdiction, it’s the same as the First Coast policy and it won’t surprise me to see all the MACs adopt the same (flawed) policies.
The Devil in the Documentation Details of the Proposed Novitas LCD on “Skin Substitutes” – Part 4
This is Part 4 of the list of what you need to document (per the proposed rule) if you want to use a skin substitute (CTP) for a DFU or VLU.
The Devil in the Documentation Details of the Proposed Novitas LCD on “Skin Substitutes” – Part 3
Novitas is going to limit clinicians to 2 applications of a “specific skin substitute” over the 12-week period defined by the date of the first application.
The Devil in the Documentation Details of the Proposed Novitas LCD on “Skin Substitutes” – Part 2
I am not even halfway through the details of the proposed policy, so stay tuned for more.
The Devil in the Documentation Details of the Proposed Novitas LCD on “Skin Substitutes” – Part 1
If you want to present comments on any of the proposed policies in the Novitas LCD, sign up to attend the Open Meeting.
The Department of Justice and the Drug Enforcement Agency Announce New Searchable Portals for “Guidance Documents”
This portal contains a single, searchable, indexed database that contains links to all DEA guidance documents.
Zero Day Postoperative Global Periods
If you perform either or both of the procedures represented by CPT 28820 and 28825, be sure to code appropriately for the services performed during the postoperative global period.
CMS Rulings Are Not Law; Yet Followed By ALJs
As wound care begins to shift into the private doctor’s office – doctors are not going to be able to just may paybacks without a fight.
You said it Knicole! Stop Auditing Practitioners and Start Auditing Medicare Advantage Plans!
“Maybe it’s time to switch our telescopic lens from auditing providers to auditing MCOs and MAs. Let’s get these RAC, ZPIC, and TPE auditors focused on the stewards of our tax dollars, the prepaid entities.”
Take a Firsthand Look at a TPE (Targeted Probe & Educate) Audit
Dr. David Charash has just put out an article in Today’s Wound Clinic describing his experience with a TPE (Targeted Prove and Educate) audit. Check it out!
General Confusion About Hyperbaric Oxygen Therapy Chamber Supervision (and the Pandemic)
HBOT treatments are most commonly provided in the hospital-based outpatient department (HOPD) but are also sometimes provided in the physician’s office.
The FDA Updates Its List of Conditions for Which HBOT Chambers are Cleared for Use
Did you notice that Acute Arterial Insufficiency is NOT on the list? The rest of us hadn’t paid attention to that either…
The Future of Wound Infections – at the APWCA Meeting This Week in Philadelphia
Great opportunities to advance wound care knowledge, this week in Philadelphia!
Medicare and the Game of “Gotcha”
In this game, you may find out the rules only when someone gets a penalty.
WATCH THIS: Trends in Wound Care Audits & Denials, with Dr. Caroline Fife and Dr. Helen Gelly
Last week, Dr. Caroline Fife and Dr. Helen Gelly enjoyed a relaxed, unscripted conversation about...
The History of Medicare Administrative Contractor (MAC) Debridement Audits
The MACs have been auditing wound debridements. I thought it might be useful to understand the history of debridement audits.
The 2022 Physician Fee Schedule Proposed Rule is Open for Comment
These proposed “rules” are hundreds of pages and filled with jargon. However, the details will control how physicians get paid in 2022.
Welcome to the Intellicure Blog!
Fellow Wound Care Warriors, welcome to the Intellicure Blog! Our team at Intellicure shares a...