First Coast Service Options (FCSO), Medicare’s Florida Medicare contractor, has recently updated the 2023 reimbursement allowable rates. A synopsis is available of the allowed reimbursements and limiting fees in Florida for the 3 reimbursable chiropractic services, in the 3 Medicare regions for Participating providers, NonParticipating providers accepting assignment and NonParticipating providers not accepting assignment. The allowable rates for 2022 are struck through, the “A” rates reflect the individually looked up codes and the “B” rates are from the data files.

This information may be found on the FCSO’s website https://medicare.fcso.com by looking up the individual codes or downloading the data files for all reimbursable codes. These data files may not be shared or disseminated due to copyright issues. The data files, however, are pertinent to understanding the PIP reimbursement limitations that are based primarily on 200% of the Medicare “participating” rates. In past years, the Medicare rates have changed between January and March. Subsequently the PIP law references the Medicare rates “in effect on March 1st of the service year the services were rendered” but are to be no lower than the Medicare rates for 2007. Sadly, the 2023 Medicare rates are lower than 2022. Also 2007 Medicare rates are lower than the 2023 rates. Accordingly, if your fees are based upon the Medicare rates, please remember to adjust them in your system.

As we move into the new year, the Medicare allowable reimbursements will go into effect January 1st.  A reference document is available to view the Medicare allowable fees for 98940, 98941 and 98942.  

For those members wishing to access the Medicare allowables for all Medicare reimbursable items, the instructions are in the reference document.  Many practices adjust their fees annually, based on Medicare's allowables.  Although the fees listed are effective as of January 1, Medicare has been known to change their allowable fees after January 1, sometimes into early March.  Additional information on the Par, NonPar and Limiting Charges may be found on First Coast Service Options website. 

Additional information on Replacement plans, as well as Par, NonPar and Limiting charges may be found by downloading this document.

As of January 1, 2022, the No Surprises Act (NSA) requires providers and facilities to issue a Good Faith Estimate (GFE) to uninsured and self-pay patients (cash pay, high deductibles, patients having health insurance but not using it). Please see the FCA’s prior Bulletin for a more detailed discussion of this GFE requirement.

On December 2, 2022, CMS published a single FAQ indefinitely extending the current requirement that the GFE include expected charges from co-providers or co-facilities until future rulemaking is issued.

Until this week, the NSA required providers to give Good Faith Estimates not only to their uninsured and self-pay patients, but also from co-providers or co-facilities (think referral to an orthopedic doctor or referral to an MRI facility). Fortunately, CMS has delayed the co-provider or co-facility GFE requirement in response to industry comments surrounding the substantial technical infrastructure and business practice complexities.

The FCA launched its Members-Only NSA Toolkit and an NSA Diagram to assist your staff in following the NSA requirements. For this helpful information, click here.

Join here to be an FCA member.

Medicare announced that they are resuming revalidation activities on 1/31/2022.  Don’t wait to revalidate if CMS assigned a 2022 due date.  To maintain Medicare billing privileges, you must revalidate your enrollment record every five years.  DMEPOS suppliers revalidate every three years.  Keep in mind that a chiropractor cannot opt out of Medicare.  Note that opting out and being non-participating are not the same thing.  Chiropractors may decide to be participating or non-participating in Medicare, but they may not opt out.  (MedLearn Matters SE0479).  If you see Medicare-eligible patients, you must be accredited as a provider with Medicare.  To avoid a hold on your Medicare payments and deactivation of your Medicare billing privileges, revalidate before your due date.

There are several ways to find your revalidation due date:
Revalidate online using PECOS  https://pecos.cms.hhs.gov/pecos/login.do#headingLv1
Search the Medicare Revalidation List at https://data.cms.gov/tools/medicare-revalidation-list
CMS posts revalidation due dates seven months in advance.
 
Revalidate if you are within three months of your revalidation due date, even if you haven’t received a notification.  DO NOT Revalidate if your due date is more than seven months away unless you’ve received a revalidation notice.  These unsolicited revalidations will be returned.

Click here for "Tips to Facilitate the Medicare Enrollment Process".

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.