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Blog Posts About Regulatory Updates
Due to the Impact of Beryl, CMS Has Automatically Applied a Hardship Exemption Within the 2024 Merit-Based Incentive Payment System (MIPS) Performance Period to Eligible cC Areas
The extreme and uncontrollable circumstances (EUC) policy will apply in affected Texas counties as identified by federal public health emergency and disaster declarations.
Check Out the New Article in TWC “I’m Getting Audited – Now What?” by Stephen Bittinger
Mr. Bittinger’s article explains the various types of audits, what’s at stake, and how an attorney might help.
Aetna to Cut Payment for Urgent Care Surgical Services and Payments for NPs and PAs
Wound Care practitioners who bill site of service 49 (independent clinic) take note!
In 2025, Physicians Face a 2.8% Pay Cut While Mandatory Participation in an MVP Looms
In 2024, physicians had a 1.68% pay cut and they remain the only Medicare providers to not receive an inflationary update.
Noridian and CGS Release FAQs on Lymphedema Compression Treatment Items
Noridian and CGS Provider Outreach and Education have released the most frequently asked questions (FAQs) on lymphedema compression treatment items under the Lymphedema Treatment Act.
Health Information Technology Proposed Rule (HTI-2) is Out
ONC will be hosting information sessions in the coming weeks, including an overview session on July 17 at 2:00 PM ET.
2025 Medicare Physician Fee Schedule is Out (and CMS Did Not “Package Price” Cellular Tissue Products / Skin Substitutes in the Doctor’s Office)
The billing of CTPs in the doctor’s office is unchanged. The 2025 Medicare conversion factor is set to decrease for the fifth straight year.
Breaking News! OPPS Proposed Rule is Out!
At first glance, there are no changes to Cellular Tissue Product /skin substitute payment, which remain under package pricing in this site of care.
Accelerated and Advance Payment (AAP) for Medicare Ends on July 12
CMS announced that Medicare payments under the Accelerated and Advance Payment (AAP) Program for the Change Healthcare/Optum Payment Disruption (CHOPD) will end on July 12.
CMS Adds 76 New Items to its Master List of DME Supplies That May Be Subject to Prior Authorization (and Some Surgical Dressings are on the List)
The Centers for Medicare & Medicaid Services (CMS) added 76 new items and deleted three from its master list of durable medical equipment (DME), prosthetics, orthotics, and supplies.
Skin Substitute Proposals: What You Can Do
These proposals are in a comment period until June 8, 2024. Any interested stakeholder may submit comments to share their feedback on these proposals.
Pneumatic Compression Devices Are in the Spotlight for 2024 Audits
Check out the article by Knicole Emanuel in Today’s Wound Clinic: Pneumatic Compression Devices Are in the Spotlight for 2024 Audits.
CMS Explains its 2024 Value-Based Care Strategy
CMS ALWAYS tell us what they are going to do before they do it. Then they do it, and we are surprised.
A Little Reprieve for Physician Pay Cuts
A 3.4% Medicare physician pay cut took effect on January 1, 2024. However, thanks to the passage...
MIPS Quality Measure #130 Documentation
Too many providers are under the impression that merely documenting the patient’s medication list satisfies the performance of this measure, and it does not.
CMS Announces Flexibilities in the Wake of the Change Cyberattack
CMS is encouraging MA plans to offer advance funding to health care professionals most affected by the cyberattack.
CMS Announces Reopening of 2023 MIPS EUC Application in Response to Change Healthcare Cyberattack
I am reposting the entire message from the CMS about the extension of the Extreme and Unavoidable...
CMS Removes the Requirement for AUC From the 2024 Medicare Physician Fee Schedule
Implementing the AUC program would have been a time consuming and expensive lift for practitioners.
Update on the Surgical Dressing Policy – Thanks to the Alliance of Wound Care Stakeholders
The Alliance of Wound Care Stakeholders has had another policy win!
Resources from CMS and the AMA to Help You Implement Changes to Physician Documentation & Billing
There have been two major changes in the regulations pertaining to physician documentation during ambulatory visits, both of which are favorable for wound care practitioners.
Medicare Audits on Pneumatic Compression & Surgical Dressings – “It’s About the Documentation…”
I am a huge fan of attorney Knicole Emanuel’s blog and her most recent post is directly relevant to the field of wound care.
Be Careful Billing the New CMS G2211 Add-on Code for Visit Complexity
It is intended to “better recognize the resource costs associated with evaluation and management visits for primary care and longitudinal care.”
Noridian Has Begun Requesting “Documentation to Support Credentialing of the Provider Performing the HBO Service”
If there are super-secret requirements that Noridian has now decided to impose, then they should be enshrined in a public document somewhere.
CMS Final Rule on Prior Authorization Released
Prior authorization (PA) is costly, inefficient and responsible for patient care delays. The...
The Deadline to Submit MIPS Data for 2023 is April 1 at 6 pm EST to Avoid up to a 9% Penalty on Medicare Revenue
The data submission period for Medicare’s Merit-Based Incentive Payment System (MIPS) 2023 performance year is underway.
Time Sensitive! It’s Not Too Late to Sign the Letter to CMS Protesting the 41.5% Reduction of HBOT Facility Fees!
I know the holidays are busy – but most of us would like to have a job to go back to in January…
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).
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).
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.”
Expansion of Lymphedema Treatment
The CY 2024 Final Home Health Prospective Payment System Final Rule contains significant changes that expand coverage for lymphedema treatment.
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...