Update from your MOKSACVPR Standards and Issues Chair…
The Bill HR1155 AND S1361 that allows ARNP’s and PA’s to be the supervising provider during CR and PR has passedl! Key elements have been clarified as outlined below
1. The passage will unfortunately not be effective until 2024! This was due to the CBO score. An earlier implementation date would have prevented the bill from being included in the Balanced Budget Act (BBA) of 2018. However, AACVPR/GRQ will work with the American Heart Association to see about moving the date up. It will not be a priority – Karen Lui says they need to let the dust settle!
NPPs can now independently order CR and PR? – the answer is NO! The bill only addressed supervision, not ordering. CR and PR must be ordered by an MD or DO – or at least cosigned by an MD or DO.
2. In 2017 CR Audit was completed some key points are outlined below:
- 7500 claims from 376 providers; CMS did not receive records from 55 providers. She assumed the billing offices did not notify the CR programs of the audit!
- 60% of the denials were appealed – the final denial rate was 38%
- Most common reasons for denial were: Lack of required documentation, including lack of MD signature on ITPs, lack of psychosocial assessment and outcomes on ITP, ITP MD signature was not timely.
- Take home from the audit: The MD signature MUST be on the ITP prior to or on the first day a charge is submitted.
3. DOTH 2018: 80 people from 32 states attended. Main message was thanking members for supporting HR 1155 and S.1361, and requesting support for fixing Section 603 of the BBA of 2015 that has had a negative impact on the ability of CR and PR programs to expand due to the change to Physician Fee Schedule reimbursement which is a fraction of the reimbursement of Hospital Outpatient Prospective Payment System. Most meetings seemed to be positive – they understood the issue, and they were aware of it b/c they have heard from hospitals about the problem. Hope to have a champion soon who will sponsor a bill, or move to try for an administrative fix to the language to exclude CR and PR from the effects of the BBA of 2015.
4. KX Modifier – MLN Matters came out recently that was referring to “therapy” meaning PT/OT. Many people felt it was related to CR and PR. It is not. There is no change in how CR and PR use the KX Modifier.
5. Palmetto MAC recently published a new CR LCD stating there must be 31 minutes of exercise rather than session duration of 31 minutes. They must have copied and pasted from an old LCD. If you have people asking about this, it does not affect our MAC! Liaisons from that MAC and Karen will be having a call with the Palmetto Medical Director to help him understand the error in the LCD, and change it.