August
19, 2013
Drill
Down – Glucose Monitors Excessive Units Billed
RAC Region A contractor Performant has posted an automated review regarding
beneficiaries receiving diabetic supplies above the maximum allowable limits.
The supplies in question are the glucose monitor test stripes and lancets in
quantities greater than maximally allowed and medically necessary every three months for beneficiaries who are
currently being treated with insulin injections and who have not seen their
physician within six months prior to having ordered the supplies. This audit issues references both
the NHIC Local Coverage Determination (LCD) and its corresponding Local
Coverage Article.
Local Coverage
Determination (LCD): Glucose Monitors
To be eligible for coverage of home blood glucose
monitors and related accessories and supplies, the beneficiary must meet both
of the following basic criteria (1) – (2):
1.
The beneficiary has
diabetes (ICD-9 codes 249.00-250.93); and
2.
The beneficiary’s
physician has concluded that the beneficiary (or the beneficiary’s caregiver)
has sufficient training using the particular device prescribed as evidenced by
providing a prescription for the appropriate supplies and frequency of blood
glucose testing.
The quantity of test strips (A4253) and lancets
(A4259) that are covered depends on the usual medical needs of the beneficiary
and whether or not the beneficiary is being treated with insulin, regardless of
their diagnostic classification as having Type 1 or Type 2 diabetes mellitus.
Coverage of testing supplies is based on the
following guidelines:
Usual Utilization
·
For a beneficiary who is not currently
being treated with insulin injections, up to 100 test strips and up to 100
lancets every 3 months are covered if the basic coverage criteria (1) –
(2) (above) are met.
·
For a beneficiary who is currently
being treated with insulin injections, up to 300 test strips and up to 300
lancets every 3 months are covered if basic coverage criteria (1) – (2) (above)
are met.
High Utilization
·
For a beneficiary who is not currently
being treated with insulin injections, more than 100 test strips and more than
100 lancets every 3 months are covered if criteria (a) – (c) below are met.
·
For a beneficiary who is currently
being treated with insulin injections, more than 300 test strips and more than
300 lancets every 3 months are covered if criteria (a) – (c) below are met.
A. Basic coverage criteria (1) – (2) listed above for all home
glucose monitors and related accessories and supplies are met; and,
B. The treating physician has seen the beneficiary, evaluated their
diabetes control within 6 months prior to ordering quantities of strips and
lancets that exceed the utilization guidelines and has documented in the
beneficiary's medical record the specific reason for the additional materials
for that particular beneficiary; and,
C. If refills of quantities of supplies that exceed the utilization
guidelines are dispensed, there must be documentation in the physician's
records (e.g., a specific narrative statement that adequately documents the
frequency at which the beneficiary is actually testing or a copy of the
beneficiary's log) that the beneficiary is actually testing at a frequency that
corroborates the quantity of supplies that have been dispensed. If the
beneficiary is regularly using quantities of supplies that exceed the utilization
guidelines, new documentation must be present at least every six months.
If neither basic
coverage criterion (1) or (2) is met, all testing supplies will be denied as
not reasonable and necessary. If quantities of test strips or lancets that exceed
the utilization guidelines are provided and criteria (A) – (C) are not met, the
amount in excess will be denied as not reasonable and necessary.
NHIC Local Coverage
Article: Glucose Monitors - Policy Article - Effective July 2011
For
glucose test strips (A4253), 1 unit of service = 50 strips. For lancets
(A4259), 1 unit of service = 100 lancets.
Manufacturers often include sample
amounts of glucose test strips, lancets and other supplies with a new glucose
monitor. Claims for supplies included in the new monitor “kits” must be coded
A9900.
RAC issues for the
week of August 19th – August 23rd 2013:
RAC Region A
Performant
DME Supplier
§ Beneficiaries
Receiving Diabetic Supplies Above the Maximum Allowance - Jurisdiction A - Potential incorrect billing occurred for claims reporting
quantities of test strips and lancets greater than the maximum amounts that are
considered to be medically necessary every three months for beneficiaries who
are currently being treated with insulin injections and who have not seen their
physician within six months prior to having ordered quantities of strips and
lancets that exceed the utilization guidelines, per NHIC's Local Coverage
Determination (LCD) L11530 and related article A33614.
§ Home Health
Consolidated Billing and Medical Supplies - DME Supplier - Jurisdiction A - According to the Medicare Benefit Policy Manual, Chapter
7, Section 10.11 (B) (Home Health Services Consolidated Billing), all medical
supplies (routine and non-routine) are bundled to the Home Health Agency (HHA)
episode payment rate while the patient is under a home health plan of care.
Payment is made to the HHA and there is no separate payment to the DME
Suppliers.
RAC Region C Connolly
Inpatient Hospital
§ CMS Pre-Pay Demonstration:
MS-DRG-391- Esophagitis, Gastroenteritis, and Miscellaneous Digestive Disorders
w MCC - The Recovery Audit Prepayment Review
Demonstration will allow Medicare Recovery Auditors to review claims before
they are paid to ensure that the provider complied with all Medicare payment
rules. The demonstration has been approved with the following limitations: •
CMS approves all issues for review; and • The issues reviewed have a high
Comprehensive Error Rate Testing (CERT) rate The demonstration will begin
initially with short-stay inpatient hospital claims in the seven Health Care
Fraud Prevention and Enforcement Action Team (HEAT) states (Florida,
California, Michigan, Texas, New York, Louisiana, and Illinois) and one state
in each of the four Recovery Audit jurisdictions with the highest number of
inpatient stays (Pennsylvania, Ohio, North Carolina, and Missouri). Initial
claims selected for review will be those billed with the top Medicare Severity
Diagnosis Related Groups (MS-DRGs) on the CERT report. The first edit that
Fiscal Intermediaries (FIs)/ Part A and Part B Medicare Administrative Contractors
(A/B MACs) shall install is for claims that meet the following criteria: •
Billed with MS-DRG-391- Esophagitis, Gastroenteritis, and Miscellaneous
Digestive Disorders w MCC • Length of stay is two days or less; • From
providers who practice in the applicable demonstration state(s) only. RACs WILL
ALSO REVIEW documentation for DRG Validation requiring that diagnostic and
procedural information and the discharge status of the beneficiary, as coded
and reported by the hospital on its claim, matches both the attending physician
description and the information contained in the beneficiary's medical record.
Auditors will review claims for principal diagnosis, secondary diagnosis, and
procedures affecting or potentially affecting the focused MS-DRGs.
Inpatient PPS
§ Minor Surgery
and Other Treatment Billed as an Inpatient Stay - IOM 100-02, Chapter 1, Section 10, states “Minor Surgery
or Other Treatment - When patients with known diagnoses enter a hospital for a
specific minor surgical procedure or other treatment that is expected to keep
them in the hospital for only a few hours (less than 24), they are considered
outpatients for coverage purposes regardless of: the hour they came to the
hospital, whether they used a bed, and whether they remained in the hospital
past midnight.” Claims billed for minor surgical or other treatment are
identified for medical record review based on risk of improper payment for
inpatient care when outpatient care was provided. Claims for patients admitted
through the emergency department are excluded. RACs WILL ALSO REVIEW
documentation for DRG Validation, requiring that diagnostic and procedural
information and the discharge status of the beneficiary, as coded and reported
by the hospital on its claim, matches both the attending physician description
and the information contained in the beneficiary's medical record. Reviewers
will validate for MS-DRG, principal diagnosis, secondary diagnosis, and
procedures affecting or potentially affecting the DRG.
IP Hospital
§ CMS Pre-Pay Demonstration:
MS-DRG-391- Esophagitis, Gastroenteritis, and Miscellaneous Digestive Disorders
w MCC - The Recovery Audit Prepayment Review
Demonstration will allow Medicare Recovery Auditors to review claims before
they are paid to ensure that the provider complied with all Medicare payment
rules. The demonstration has been approved with the following limitations: •
CMS approves all issues for review; and • The issues reviewed have a high
Comprehensive Error Rate Testing (CERT) rate The demonstration will begin
initially with short-stay inpatient hospital claims in the seven Health Care
Fraud Prevention and Enforcement Action Team (HEAT) states (Florida,
California, Michigan, Texas, New York, Louisiana, and Illinois) and one state
in each of the four Recovery Audit jurisdictions with the highest number of
inpatient stays (Pennsylvania, Ohio, North Carolina, and Missouri). Initial
claims selected for review will be those billed with the top Medicare Severity
Diagnosis Related Groups (MS-DRGs) on the CERT report. The first edit that
Fiscal Intermediaries (FIs)/ Part A and Part B Medicare Administrative
Contractors (A/B MACs) shall install is for claims that meet the following
criteria: • Billed with MS-DRG-391- Esophagitis, Gastroenteritis, and
Miscellaneous Digestive Disorders w MCC • Length of stay is two days or less; •
From providers who practice in the applicable demonstration state(s) only. RACs
WILL ALSO REVIEW documentation for DRG Validation requiring that diagnostic and
procedural information and the discharge status of the beneficiary, as coded
and reported by the hospital on its claim, matches both the attending physician
description and the information contained in the beneficiary's medical record.
Auditors will review claims for principal diagnosis, secondary diagnosis, and
procedures affecting or potentially affecting the focused MS-DRGs.
§ CMS Pre-Pay
Demonstration: MS-DRG-392- Esophagitis, Gastroenteritis, and Miscellaneous
Digestive Disorders w/o MCC - The Recovery
Audit Prepayment Review Demonstration will allow Medicare Recovery Auditors to
review claims before they are paid to ensure that the provider complied with
all Medicare payment rules. The demonstration has been approved with the
following limitations: • CMS approves all issues for review; and • The issues
reviewed have a high Comprehensive Error Rate Testing (CERT) rate The
demonstration will begin initially with short-stay inpatient hospital claims in
the seven Health Care Fraud Prevention and Enforcement Action Team (HEAT)
states (Florida, California, Michigan, Texas, New York, Louisiana, and
Illinois) and one state in each of the four Recovery Audit jurisdictions with
the highest number of inpatient stays (Pennsylvania, Ohio, North Carolina, and
Missouri). Initial claims selected for review will be those billed with the top
Medicare Severity Diagnosis Related Groups (MS-DRGs) on the CERT report. The
first edit that Fiscal Intermediaries (FIs)/ Part A and Part B Medicare
Administrative Contractors (A/B MACs) shall install is for claims that meet the
following criteria: • Billed with MS-DRG-392- Esophagitis, Gastroenteritis, and
Miscellaneous Digestive Disorders w/o MCC • Length of stay is two days or less;
• From providers who practice in the applicable demonstration state(s) only.
RACs WILL ALSO REVIEW documentation for DRG Validation requiring that
diagnostic and procedural information and the discharge status of the
beneficiary, as coded and reported by the hospital on its claim, matches both
the attending physician description and the information contained in the
beneficiary's medical record. Auditors will review claims for principal
diagnosis, secondary diagnosis, and procedures affecting or potentially
affecting the focused MS-DRGs.