Business Briefs: Reimbursement Reminder Calendar

  Information regarding coding, coverage, and payment is provided as a service to our readers. Every effort has been made to ensure the accuracy of the information. However, HMP Communications and the author do not represent, guarantee, or warranty that the coding, coverage, and payment information is error-free and/or that payment will be received. The ultimate responsibility for verifying coding, coverage, and payment information accuracy lies with the reader.

  Program directors and medical directors must balance both the clinical outcomes of the patients with chronic wounds and the financial outcomes of the outpatient wound care department. At times this seems like a daunting task. Wound care directors have access to more clinical and reimbursement information than ever before. Of course, wound care directors are excited to read about the most recently published wound related clinical trials and the new wound management related technologies. Reading about new reimbursement issues is not exciting and tends to be put “on the back burner”. In fact, some large important reimbursement documents may not ever be read. Because the financial health of wound departments is very important, this author has prepared a Reimbursement Reminder Calendar that should assist in managing your financial outcomes.

Coding Reminders

  Each year the ICD-9-CM codes, CPT® codes, and HCPCS codes are updated. Wound care directors should order their new coding books and materials every August. This will assure that you have your books in time to implement the ICD-9-CM code changes on October 1 and the CPT® and HCPCS code changes on January 1 of each year.

  NOTE: HCPCS codes are awarded to new drugs and biologics on a quarterly basis. Therefore, wound care directors must monitor the HCPCS section of the CMS website on a quarterly basis (January, April, July, and October) to learn about newly awarded HCPCS codes for drugs and biologics.

  Wound care directors may find it beneficial to attend one of the American Medical Association’s CPT® symposiums which are typically held in November and December each year. At these symposiums, physicians usually review the CPT® changes and matching clinical vignettes. Wound care directors may also find it useful to attend wound care reimbursement webinars that often review the changes to the ICD-9-CM, CPT®, and HCPCS code changes and the payment system changes. Finally, wound care directors may find it beneficial to take their operations team to the Wound Clinic Business all-day seminar that is sponsored by HMP and held throughout the U.S. By the time you receive this journal, there will be one 2009 Wound Clinic Business seminar left to attend in Los Angeles: www.woundclinicbusiness.com/. If you cannot attend that seminar, continue to visit the website for the announcement of the brand new 2010 seminars that will be held in 8 cities throughout the U.S.

Payment System Reminders

  When the new DRAFT RULE and FINAL RULE for the Outpatient Prospective Payment System and the Physician Fee Schedule Payment System are announced in the Federal Register each year, wound care directors often give up before they start because these documents normally contain more than 1000 pages each! Instead the wound care directors should take the time to read and comment on the DRAFT RULES that are typically released in July each year. Then the wound care directors should make tentative plans to implement the new FINAL RULES after they are published in November each year. It pays to read the rules!

  If you use skin substitutes in your program, you should monitor the Average Sales Price (ASP) of the products on a quarterly basis (January, April, July, and October). Medical directors can find the ASP updates at: https://www.cms.hhs.gov/McrPartBDrugAvgSalesPrice/. Program directors can find them at: https://www.cms.hhs.gov/HospitalOutpatientPPS/AU/list.asp#TopOfPage.

  At the beginning of each year, program directors should update their chargemasters and charge sheets to reflect manufacturer’s price changes, new products and procedures, and hospital price changes.

Coverage Reminders

  Wound care directors should monitor their Medicare contractor’s LCDs on a monthly basis: look for new LCDs as well as revised LCDs. Then wound care directors must share the information from the LCDs with their entire medical and professional staff, as well as their office staff.

  After codes and payment systems are updated each year, the Medicare contractors must often update existing Local Coverage Determinations (LCDs) to reflect the coding and payment system changes. In addition, Medicare contractors have the right to create/update LCDs at any time they deem necessary. If the LCDs limit coverage for a product or service, the Medicare contractors should release the new/updated LCD for a public open comment period. That is a wonderful time for wound care providers to provide clinical evidence to assist the Medicare contractor in appropriately fine-tuning and finalizing the new/updated LCD. Wound care directors can help their participating physicians by sharing all of the above LCDs. If the physicians wish to comment about a draft LCD during an open comment period, provide clear instructions how to submit their comments and/or how to register and attend an open LCD comment meeting or teleconference. If an LCD is final and one or more of your physicians wish to recommend an evidence-based change, instruct them how to use the Reconsideration Process to submit their recommendations to your Medicare Contractor Medical Director.

Audit Reminders

  Your Medicare contractor is mandated to educate providers about reimbursement topics that appear confusing and that often cause denied claims. They do this via electronic bulletins and newsletters, educational webinars and seminars, Ask-the-Contractor teleconferences, LCDs, Articles, electronic manuals, etc. Wound care directors can receive this valuable education by registering to be on their Medicare contractor’s distribution list. Your Medicare contractor and your Recovery Audit Contractor (RAC) also publish the issues that they are auditing. Be sure to monitor their websites for this helpful information. In October, the Office of Inspector General (OIG) publishes their Work Plan for the following year. Wound care directors should read this work plan to understand the OIG’s areas of concern. If the OIG is going to monitor something that pertains to your business, you should begin to conduct internal audits on these same issues.

Summary

  Program directors and medical directors of outpatient wound care departments must set aside a significant amount of time each month to maintain their reimbursement knowledge. Following is a Reimbursement Reminder Calendar to help you maintain your department’s positive financial outcomes.

  Kathleen D. Schaum, MS is President of Kathleen D. Schaum & Associates, Inc. Lake Worth, Fla. Ms. Schaum can be reached for questions and consultations by calling (561) 964-2470 or via her email address at kathleendschaum@bellsouth.net.