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RHC Modifier HCSPC conflict 11721
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9/10/2020 @ 5:59:00 PM
Post 11 of 47

Contributor: Nathan Baugh, National Association of Rural Health Clinics

Yes, as Patty said, it means you cannot bill these codes with modifier CG as the main reason for the RHC encounter.

Shirley, I do want to caution against your comment that we can simply "carve out" time and supply costs for these services. We are not supposed to be flipping back and forth between RHC and non-RHC billing the way you are implying.

You can have non-RHC time scheduled in advance but you should not be "billing things to part B" if the patient comes in during your RHC scheduled hours and needs one of these services. 

9/11/2020 @ 8:53:00 AM
Post 12 of 47

Contributor: Jan Oberlin, Dickinson County Healthcare System RHCs

Nathan,

Thank you for further pursuing this issue with CMS. I think they really need to re-think the "list." Per CMS rules, Medicare Claims Processing Manual, Chapter 12, Section 40.1.C. every procedure (whether major or minor) includes an "inherent" E/M component and , as such, you may not report a separate E/M service on the same date of service. If they exclude these procedures from our AIR payment then how are we to be reimbursed for the "inherent" E/M component (face to face visit) that is included in the procedure? It would be tempting to bill an additional E/M service with modifier CG just for the purpose of receiving our AIR payment, but totally inappropriate. Not only would that be incorrect coding, but it would also cause the patient 20% coinsurance to be inflated.

Thank you,
Jan Oberlin, CCS-P, CPMA
Provider Coding Compliance Coordinator
Dickinson County Healthcare System
P 715.528.4775 ext 3016
Jeanette.oberlin@dchs.org

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9/11/2020 @ 8:54:00 AM
Post 13 of 47

Contributor: Joyce Harper, MDH Family Medicine

Thank you for putting this together .

Joyce

9/11/2020 @ 9:33:00 AM
Post 14 of 47

Contributor: Shirley Gamble, Sterling Medical Center

Nathan,
Thanks for your reply. Yes, I am aware about the carve out issues but was
grasping at straws. One of my providers performed a laceration repair
12001 (which couldn't/shouldn't have to wait until after RHC hours or
necessitate an ER visit ) It was a fairly straight forward repair so
questionable that an E/M code would be appropriate since the procedure
includes a minimal E/M evaluation. Just seems this is
discriminatory against RHCs when non RHC providers can get paid for taking
care of their patients by performing these services for their patients. I
am really struggling with how most of the services on the list can be
determined by a Committee or group of persons as not qualifying for
reimbursement when done by an RHC provider. You stated in one of your
previous posts that we may have to appeal code by code. Is this something
I can do for this claim? I am considering contacting my congressman about
this. Anything else I can do? I now have a handful of claims that were
denied as not qualifying for CG, therefore unable to be paid.


*Shirley L Gamble, CPC*

Clinic Coding Manager


Sterling Medical Center

239 N Broadway Sterling, KS 67579

620.278.2123 Main

620.278.2712 Fax



On Thu, Sep 10, 2020 at 5:01 PM NARHC News
wrote:

>
9/11/2020 @ 10:04:00 AM
Post 15 of 47

Contributor: Patty Harper, InQuiseek Consulting

It's difficult to understand why most of these codes are conflicted. If RHCs are required to be able to provide emergency care, then a laceration repair makes sense especially in rural areas-farming or ranching injuries, work-related injuries, sports injuries. It's great to know that we have a way to challenge this. I believe the 20% coinsurance defense would be good because we could be saving beneficiaries coinsurance if we weren't required to have an unnecessary E & M.

Patty Harper, RHIA, CHTS-IM, CHTS-PW, CHCR
Healthcare Consultant/Principal
318-243-2687 (Cell)
866-855-0683 (Fax)

940 Ratcliff Street
Shreveport, LA 71104

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9/18/2020 @ 11:41:00 AM
Post 16 of 47

Contributor: Shauna Stokes, Lakewood Clinic Staples

If a visit does not qualify as stand alone, for example 11721, can we change it to an E/M code and remove the procedure code for the visit completely?

10/15/2020 @ 12:31:00 PM
Post 17 of 47

Contributor: Julie York, Marengo Family Medical Clinic

Have there been any updates from CMS on the HCPCS conflict 11721? What are others doing in the meantime?

Julie York
Clinic Billing Supervisor
Compass Memorial.org

10/15/2020 @ 4:18:00 PM
Post 18 of 47

Contributor: Diane Condon, Mitchell County Regional Health Center

Our HIM Director listened in on the WPS foot care webinar and asked about the issue with 11721 and the response is below. I'm also interested if RHCs have any other option to be reimbursed for this code as well as other codes on the conflict list.

CMS updates the Inpatient/Outpatient Code Editor (I/OCE) on a quarterly basis. The latest update removed procedure code 11721 from the list of qualifying visits. This means as of July 1, 2020, you would no longer submit this procedure code to receive the All-Inclusive Rate (AIR) payment. Charges for this procedure code would instead be part of your cost report. You can find more information in the resources below.

OCE Quarterly Release Files https://www.cms.gov/Medicare/Coding/OutpatientCodeEdit/OCEQtrReleaseSpecs
Change Request 11792 Transmittal 10165 dated June 5, 2020 Version Updates https://www.cms.gov/files/document/r10165cp.pdf

Diane Condon
Director of Patient Financial Services
Mitchell County Regional Health Center
Phone: (641) 732.6074
Fax: (641) 732.6080
Email: condond@mercyhealth.com
[cid:image003.png@01D50B2B.F6D39BA0]


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10/16/2020 @ 12:08:00 PM
Post 19 of 47

Contributor: Jackie King, ArchProCoding

Please note that Nathan and NARHC are working on this issue at the Federal level. We have provided him with examples of claims and denial reasons. I don't believe there has been any update (unless I missed it).

Thank you,
Jackie

[cid:image001.png@01D579EB.4BFCECC0]

Jackie King, MSHI, CPC, COC, RH-CBS
Director of Compliance & Clinical Informatics, HIM Consultant
Illinois Critical Access Hospital Network (ICAHN) | 1945 Van's Way, Princeton, IL 61356
P 815.875.2999 | F 815.875.2990 | jking@icahn.org | www.icahn.org



11/17/2020 @ 10:17:00 AM
Post 20 of 47

Contributor: Deyon Suchla, Eide Bailly - South Dakota

Just checking in to see if anyone has been successful when appealing these codes with supporting documentation to their MAC? ( including 11750, 12001, 20600)


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