Medicare Update 2009

1. Medicare Update 2009 Stephen Meritt, D.P.M.

2. Ulcer Debridement • FCSO will be following cases of multiple ulcer debridements. • More then 2 ulcer debridements per session may result in requests for documentation of medical necessity. • All ulcer treatments, whether surgical debridement or office visits require location, sizing, and staging of the ulcerations.

3. New Ulcer Staging Codes • New ICD 9 codes have been added for 2009. • These are additional use codes for staging that are to be added to the pressure ulcer location codes when billing for ulcer debridement. • Documentation in your medical records must match the billing codes submitted.

4. Ulcer stages • Stage I – Healing pressure ulcer, pre-ulcer skin changes limited to persistent focal erythema. • Stage II – Healing pressure ulcer with abrasion, blister, partial thickness skin loss involving epidermis and/or dermis. • Stage III – Healing pressure ulcer with full thickness skin loss involving damage to necrosis of subcutaneous tissue.

5. Ulcer stages • Stage IV – Healing pressure ulcer with necrosis of soft tissue through to underlying muscle, tendon, or bone.

6. New Ulcer Staging Codes • 707.20 – 707.25 Pressure ulcer stages • Code first site of pressure ulcer then add staging code. • 707.07 Heel ulcer and 707.09 Other site. • Decubitus ulcer of heel stage II would be coded for billing as, - 707.07 (707.22). • Decubitus ulcer of the 5th metatarsal head stage IV would be coded as, - 707.09(707.24)

7. New CPT codes • 20696 Application of multiplane (pins or wires in more than one plane), unilateral, external fixation with stereotactic computer-assisted adjustment. • 20697 – exchange (i.e., removal and replacement) of strut, each.

8. New CPT codes • 64455 Injection(s), anesthetic agent and/or steroid, plantar common digital nerve(s) – (e.g., Morton’s neuroma). • 64632 Destruction by neurolytic agent, plantar common digital nerve, (Morton’s neuroma).

9. E-Prescribing Bonus • Starting in 2009 if you E-prescribe and submit the coding G8443 on your Medicare billing and this makes up at least 10% of your Medicare charges, then you could receive a 2% bonus in 2010. That is 2% of all your 2009 Medicare charges. • You must have a qualified electronic prescribing system. • G8445 for visits with no prescriptions written. • G8446 for pharmacy limitations or Pt. refusal.

10. Qualified EPS • Must be able to generate a complete medication list with available data from pharmacies and benefit managers. • Be able to select medications and transmit prescriptions electronically (not via fax) following applicable federal standards, after warning the prescriber of any possible safety issues associated with the drug orders. • Provide information on lower-cost, therapeutically appropriate alternatives.

11. Qualified EPS • Provide drug plan information, such as formularies, patient eligibility and authorization requirements.

12. Signature stamps banned • CMS has completely banned the use of signature stamps on billing, progress notes, orders, and treatment plans. Only written or electronic signatures will be allowed as well as fax copies of an original written signature.

13. PECOS expanded to Florida • CMS had expanded PECOS (Provider Enrollment, Chain and Ownership System) to Florida. • Allows physicians to enroll, make a change in their Medicare enrollment, view their Medicare enrollment information on file with Medicare, and check on the status of a Medicare enrollment application on line. • https://pecos.cms.hhs.gov

14. DMEPOS • Accreditation is NOT required for podiatrists. • If you have been denied – reapply.

15. Federal Trade Commission Red Flag Rules • The FTC recently came out with “red flag rules” which will apply to us. • Federal legislation passed that requires any creditor that maintains a covered account to have very specific identity theft prevention mechanisms and policies in place. • Creditor: anyone who defers payment for services or provides a service and subsequently follows up with a bill for services already provided. Starts March 1???

16. Teaching Physician Documentation • If you have a resident in surgery with you, then you must use a –GC modifier on your billing form. (28298 –GC) • You must indicate in your operative note that you were present for the entire case or the key portions of the case. (Failure to note this could result in non-payment or a refund request)

17. Teaching Physician Documentation • Progress note/H & P documentation examples • Complete Assessment: “ I was present with the resident during the history and exam. I discussed the case with the resident and agree with the findings and plan as documented in the resident’s note.” OR • “I saw and evaluated the patient. Discussed with resident and agree with resident’s findings and plan as documented in the resident’s note.”

18. Teaching Physician Documentation • Subsequent visit : “I saw and evaluated the patient. Discussed with resident and agree with resident’s findings and plan as documented in the resident’s note.” OR • “I saw the patient with the resident and agree with the resident’s findings and plan” • Unacceptable Documentation: • “Agree with above.” or “Rounded, Reviewed and agree.” or “Discussed with resident. Agree.” or “Seen and agree.” or signature.