Bill These Patients with an Abundance of Caution

The FCA has been receiving an increase in calls from members reporting notices from Medicare and Medicare Advantage insurers that they must refund patients for copayments and deductibles. These determinations are a result of the Qualified Medicare Beneficiaries (QMB) program which was reported about over a year ago.
In summary – The following actions should be considered:
• Consider asking every patient on every visit if there have been any changes in their health care insurance. Although regular Medicare only changes once a year on January 1st, Medicaid and replacement plans can change much more frequently. Some offices have incorporated a yes/no response to this question on their sign-in sheet or equivalent.
• If the patient is a QMB, these rules apply whether or not you are enrolled in Medicaid.
• Potentially covered services by either Medicare and Medicaid include spinal manipulations visits, and some x-rays.
• Medicaid’s reimbursement for a spinal manipulation visit includes an exam if necessary, but does not cover an exam if a spinal manipulation is not rendered.
• Consider the QMB possibilities when implementing your “No Surprises Act” Toolkit. The FCA’s information on this can be found on fcachiro.org. After logging on, search for “No Surprises Act” or click here to be redirected to that page.
• Monitor your EOBs in a timely fashion to identify potential issues quickly, before either refunds or patient balances become excessive or delinquent.
• Review network contracts to understand what services are bundled in YOUR contract.

Yesterday, CMS issued some well-needed clarity on the No Surprises Act (NSA) through six FAQs on the topic of Good Faith Estimates (GFE) put into effect for all providers as of January 1, 2022. As previously published by the FCA, the NSA was created to provide additional protections against surprise medical bills, including:

• Requiring good-faith estimates of medical items or services for uninsured (or self-paying) individuals.
• Requiring notice posted in your office and on your website of the uninsured/self-insured’s right to receive a good faith estimate.
• Establishing a patient-provider dispute resolution process for uninsured (or self-paying) individuals to determine payment amounts due to a provider or facility under certain circumstances.

Have you received your Comparative Billing Report (CBR)?

Several FCA members have recently reported to the FCA’s Help Desk that they received a CBR from Medicare. The CBR, Comparative Billing Report, identifies that provider’s Medicare activity based on bills submitted in 2017, 2018 and 2019.

 The Chiropractic Medicare Coverage Modernization Act (H.R. 2654), legislation that would ensure that Medicare beneficiaries have full access to all the services a chiropractor can provide under his or her state’s chiropractic scope of practice, was introduced in the U.S. House of Representatives on April 19, 2021. 

President Biden has signed S. 610, the “Protecting Medicare and American Farmers from Sequester Cuts Act,” which delays the Medicare sequester, makes changes to Medicare payments, and modifies procedures affecting federal budget scorekeeping and federal borrowing.

What do you need to do about Medicare to have a smooth transition to 2022?  Review these pointers to stay on top of year-end Medicare concerns.

Medicare Participation Status may be changed once a year, if postmarked before January 1st.

CMS has approved the updated ABN form with an expiration date of 6/30/2023.  The deadline date for use of this updated form, originally mandated by August 31, 2020, has been extended to 10/14/2021 due to the pandemic. The renewed form may be implemented prior to the mandatory deadline. Read on for links to the form, instructions and important clarifications.

Medicaid Claims will Deny if a Referring, Ordering, Prescribing, or Attending Provider is Not Enrolled IN Medicaid

(From CMS Newsletter of March 30, 2021)  "In anticipation of possible Congressional action to extend the 2% sequester reduction suspension, we instructed the Medicare Administrative Contractors (MACs) to hold all claims with dates of service on or after April 1, 2021, for a short period without affecting providers’ cash flow. This will minimize the volume of claims the MACs must reprocess if Congress extends the suspension; the MACs will automatically reprocess any claims paid with the reduction applied if necessary."