Important Medicare Deadline Approaching for Eligible Professionals

If you are an eligible professional for the Medicare Electronic Health Record (EHR) Incentive Program, 2014 is the last year you can start participation in the Medicare EHR Incentive Program in order to receive incentive payments. Eligible professionals who begin participation in the Medicare EHR Incentive Program after 2014 will not be able to earn an incentive payment for that year or any subsequent year of participation. If you choose to participate in the Medicare EHR Incentive Program for the first time in 2014, you should begin your 90-day reporting period no later than July 1, 2014 and submit attestation by October 1, 2014 in order to avoid the payment adjustment in 2015.

Note: October 1 is the attestation deadline for eligible professionals in their first year of participation to avoid the payment adjustment. However, eligible professionals who miss this deadline can still demonstrate meaningful use during the last 90-day reporting period of the year (October through December 2014) and earn an incentive payment for 2014.

Providers Who First Begin Participation in 2014 must:

• Demonstrate Stage 1 of meaningful use 
• Meet 2014 EHR certification criteria 
• Select any 90-day reporting period to demonstrate meaningful use, but must start no later than July 1, in order to avoid the adjustment

To Earn Your Maximum Medicare Incentive

• Demonstrate 90 days of Stage 1 of meaningful use in 2014 to earn up to $11,760. 
• Demonstrate a full year of Stage 1 of meaningful use in 2015 to earn up to $7,840. 
• Demonstrate a full year of Stage 2 of meaningful use in 2016 to earn up to $3,920.

If you successfully demonstrate meaningful use each year beginning in 2014, your total payment amount could be as much as $23,520.

Additional Resources
The EHR Incentive Program website offers several helpful tools and resources so you can successfully begin participation:

• An Introduction to the Medicare EHR Incentive Program for Eligible Professionals 
• Interactive Eligibility Assessment Tool 
• The Stage 1 Meaningful Use Attestation Calculator 
• My EHR Participation Timeline 
• Payment Adjustments & Hardship Exceptions Tipsheet for Eligible Professionals

Do you want to check your progress towards meeting the 2013 PQRS reporting requirements? Now you can.

If you are an individual eligible professional who reported at least one PQRS quality measure in 2013 via claims-based reporting, you can now view the entire calendar year (first through fourth quarter) of data using the 2013 PQRS Interim Feedback Dashboard.

If you reported individual measures or measures group(s), the dashboard will display your summary data by Taxpayer Identification Number (TIN) or individual detail by your National Provider Identifier (NPI).

The Dashboard data allows you to monitor the status of your claims-based measures and measures group reporting to see where you are in meeting the PQRS reporting requirements.

The Dashboard is available through the Physician and Other Health Care Professionals Quality Reporting Portal, with Individual Authorized Access to the CMS Computer System (IACS) sign-in.

Dashboard Resources

The following CMS resources are available to help you access and interpret your 2013 PQRS interim feedback data:

• The User Guide: 2013 Interim Feedback Dashboard provides detailed information about accessing and interpreting the data provided in the feedback report. 
• IACS Quick Reference Guides provide step-by-step instructions on how to request an IACS account in order to access the Portal, if you do not already have one.

Note: The Dashboard does not provide the final data analysis for full-year reporting, or indicate 2013 PQRS incentive eligibility or subjectivity to the 2015 PQRS payment adjustment or the Value-based Payment Modifier to be implemented in 2015. The Dashboard will only provide claims-based data for 2013 interim feedback. Data from other CMS programs will not be included for purposes of the 2013 Dashboard data feedback. Data submitted for 2013 PQRS reporting via methods other than claims will be available for review in the fall of 2014 through the final PQRS feedback report or the QRUR for 2013 PQRS GPROs.

For More Information about PQRS

For more information about participating in PQRS, visit the PQRS website. For additional support or questions, contact the QualityNet Help Desk.

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Centers for Medicare & Medicaid Services (CMS) has sent this update. To contact Centers for Medicare & Medicaid Services (CMS) go to our contact us page.

To keep you updated with information on the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs, CMS has recently added three new FAQs and five updated FAQs to the CMS FAQ system. We encourage you to stay informed by taking a few minutes to review the new information below.

New FAQs:

• For Eligible Professionals (EP) in the Medicaid EHR Incentive Program using the group proxy method of calculating patient volume, how should the EPs calculate patient volume using the “12 months preceding the EP’s attestation” approach, as not all of the EPs in the group practice may use the same 90-day period. Read the answer.
• Can a hospital count a patient toward the measures of the “Patient Electronic Access” objective in the Medicare and Medicaid EHR Incentive Programs if the patient accessed his/her information before they were discharged? Read the answer.
• When demonstrating Stage 2 meaningful use in the EHR Incentive programs, would an EP be required to report on the “Electronic Notes” objective even if he or she did not see patients during their reporting period? Read the answer.

Updated FAQs:

• Do States need to verify the "installation" or "a signed contract" for adopt, implement, or upgrade (AIU) in the Medicaid EHR Incentive Program? Read the answer.
• For Stage 1 and 2 meaningful use objectives of the Medicare and Medicaid EHR Incentive Programs that require submission of data to public health agencies, if multiple EPs are using the same certified EHR technology across several physical locations, can a single test or onboarding effort serve to meet the measures of these objectives? Read the answer.
• For the Stage 2 meaningful use objective of the Medicare and Medicaid EHR Incentive Programs that requires the successful electronic exchange of a summary of care document with either a different EHR technology or the CMS designated test EHR, if multiple EPs are using the same certified EHR technology across several physical locations, can a single test meet the measure? Read the answer.
• In calculating the meaningful use objectives requiring patient action, if a patient sends a message or accesses his/her health information made available by their EP, can the other EPs in the practice get credit for the patient’s action in meeting the objectives? Read the answer.
• When reporting on the Summary of Care objective in the EHR Incentive Program, which transitions would count toward the numerator of the measures? Read the answer.

Want more information about the EHR Incentive Programs? Make sure to visit the Medicare and Medicaid EHR Incentive Programs website for the latest news and updates.

Are you a provider participating in Stage 2 of meaningful use for the Electronic Health Record (EHR) Incentive Programs? If so, use the new CMS Stage 2 Meaningful Use Attestation Calculator to determine if you will successfully meet Stage 2 requirements. Like the Stage 1 calculator, eligible professionals, eligible hospitals, and critical access hospitals (CAHs) can enter and review their data for each measure. The tool then calculates whether or not you will successfully demonstrate Stage 2 of meaningful use. A results page explains why you may or may not receive an incentive payment by displaying a pass/fail summary for each measure.

Get Started

Take four easy steps to get started:
   • Select your provider type: eligible professional or eligible hospital/CAH
   • Answer questions on your meaningful use core objectives
   • Answer questions on your meaningful use menu objectives
   • Receive your results

Be sure to answer each measure you intend to meet by either filling in the numerator and denominator values or marking down an exclusion (for those that apply).

Please note: The attestation calculator is not actual attestation and does not guarantee that you will meet the program’s qualifications. It is only a guide of whether or not you would meet the program’s Stage 2 meaningful use requirements.

Resources Providers who have completed at least two years of Stage 1 of meaningful use will demonstrate Stage 2 in 2014. Additional Stage 2 resources:
   • Stage 2 Guide
   • Stage 2 Meaningful Use Specification Sheet Table of Contents for Eligible Professionals
   • Stage 2 Meaningful Use Specification Sheet Table of Contents for Eligible Hospitals and CAHs
   • Stage 2 Data Sharing Tipsheet for Eligible Professionals

Want more information? Visit the Registration and Attestation and Stage 2 pages for useful resources to help you successfully demonstrate meaningful use.

On April 9, as part of the Obama administration’s work to make our health care system more transparent, affordable, and accountable, HHS Secretary Kathleen Sebelius announced the release of new, privacy-protected data on services and procedures provided to Medicare beneficiaries by physicians and other health care professionals. The new data also show payment and submitted charges, or bills, for those services and procedures by provider.

The new data set has information for over 880,000 distinct health care providers who collectively received $77 billion in Medicare payments in 2012, under the Medicare Part B Fee-For-Service program. With this data, it will be possible to conduct a wide range of analyses that compare 6,000 different types of services and procedures provided, as well as payments received by individual health care providers.

The information also allows comparisons by physician, specialty, location, the types of medical service and procedures delivered, Medicare payment, and submitted charges. Physicians and other health care professionals determine what they will charge for services and procedures provided to patients and these “charges” are the amount the physician or health care professional generally bills for the service or procedure.

Last May, CMS released hospital charge data allowing consumers to compare what hospitals charge for common inpatient and outpatient services across the country.

Full text of this excerpted CMS press release (issued April 9).

Arlington, Va.—The American Chiropractic Association (ACA) today announced its intention to appeal the recent dismissal of its claims against American Specialty Health Inc. and American Specialty Health Networks Inc. (collectively, "ASHN"), and CIGNA Corporation and Connecticut General Life Insurance Company (collectively, "CIGNA"). Significantly, the dismissal was based upon a variety of procedural considerations--not the substance of ACA’s claims.

ACA’s legal counsel is optimistic about the chances of a successful appeal, noting that this area of the law is the subject of increasing judicial focus.

“Recently, there have been several significant rulings recognizing that providers are entitled to assert claims under ERISA to challenge benefit determinations by insurers, including with regard to recoupments of previously issued payments”,” said Brian Hufford, Esq., of Zuckerman Spaeder LLP, who represents ACA in the class action suit. "We believe that federal courts are increasingly recognizing that individual providers and associations such as the ACA have standing to assert the claims brought in this action.”

ACA's litigation against ASHN and CIGNA alleges, among other things, that CIGNA--in violation of ERISA--failed to comply with terms and conditions of its plan to afford subscribers or their health care providers an opportunity to obtain a "full and fair review" of denied or reduced reimbursement, and failed to make appropriate and non-misleading disclosures to subscribers or their health care providers.

"ACA took this action against ASHN and CIGNA because it is patients who suffer most when doctors must choose between providing necessary care and adhering to requirements imposed by payers," said ACA President Anthony Hamm, DC. "We will not rest until patients receive the care they need and have paid for through their insurance premiums."

Providers who believe they and/or their patients have been affected by ASHN and/or CIGNA's improper practices can visit the Chiropractic Networks Action Center to submit a complaint to ACA.

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The American Chiropractic Association (ACA), based in Arlington, VA, is the largest professional association in the United States advocating for more than 130,000 doctors of chiropractic (DCs), chiropractic assistants (CAs) and chiropractic students. ACA promotes the highest standards of ethics and patient care, contributing to the health and well-being of millions of chiropractic patients. Visit us at www.acatoday.org.

The timeline that CMS provided to allow providers to transition from the old version of the CMS-1500 claim form (08/05) is coming to an end. Effective April 1, claims will only be accepted if submitted on the new version of the claim form identified by the date 02/12 in the lower right hand corner. The CMS-1500 Form has been revised to give providers the ability to indicate whether they are using the International Classification of Diseases, ninth edition, Clinical Modification (ICD-9-CM) codes or its successor, the ICD-10-CM and allows for additional diagnostic codes to be reported. Additional changes were made to item numbers 14, 15 and 17, which now have qualifiers to identify provider roles such as ordering, referring or supervising. ACA has prepared a 1500 Claim Form Fact Sheet, which is free to members, to assist your clinic in making the needed changes. Further information from CMS on this topic can be found here.

Additionally, the National Uniform Claim Committee (NUCC) has developed a 1500 Reference Instruction Manual detailing how to complete the claim form. The purpose of this manual is to help standardize nationally the manner in which the form is being completed. The current version of the instructions (v 9.0) was released in July 2013: Version 9.0 7/13

1. How long do I have to submit my appeal request?
   
   Answer: You have 120 days from the date of the original Medicare remittance advice to submit an appeal. Multiple resubmissions of a claim will not extend the 120-day time limit. The time limit begins with the original denied/processed claim. 
2. Can an appeal be filed past the 120-day limit?
   
   Answer: The time limit may be extended if good cause for late filing is shown. If good cause is not found, the request for appeal will be dismissed. The issue of good cause for the provider and beneficiary is addressed in the Centers for Medicare & Medicaid Services (CMS) Internet-Only Manual (IOM) Publication 100-04, Medicare Claims Processing Manual, Chapter 29, Section 240. (982 KB) 
3. Must a redetermination request have a signature, and what type of signature is needed?
   
   Answer: Yes, it must be a full signature (first and last name) on the redetermination request form in order for it to be a valid request. 
4. How can I follow up on claims that are already in the appeal process?
   
   Answer: Please visit http://www.NGSConnex.com or call our IVR system at 877-908-9499. Both of these self-service tools allow providers/suppliers to obtain the status of all redetermination/reopening requests. Remember, the contractor has 60 days from the date the appeal was received to make a determination. 
5. I have made corrections to my denied claim. Should I rebill?
   
   Answer: A claim should only be rebilled if the claim was rejected with message MA130. If the claim denies for any other reason, do not rebill as it could result in a duplicate claim or cause delay of payment. 
6. What is a reopening?
   
   Answer: A reopening is an alternative to the appeals process where minor errors or omissions in filing claims have occurred. For more information regarding the appeals process, visit the Review Process > Appeals section on our Web site. 
7. How do you determine whether you need to submit a first level appeal request (the redetermination) or a second level appeal request (the reconsideration)?
   
   Answer: An initial claim submission will show the MA01 remark code, which states you have 120 days to appeal and request a redetermination. If you see this remark code on your claim, you need to request a redetermination from us.
   
   Adjustments resulting from a redetermination decision can be identified by the remark code of MA02, “If you do not agree with this determination, you have the right to appeal. You must file a written request for appeal within 180 days of the date you receive this notice.
   
   Please note the difference in the amount of time to request a second level appeal, also known as the reconsideration. The MA02 message gives you appeal rights for the second level appeal or the reconsideration. If you wish to appeal claim adjustments with the MA02 remark code, you must file a reconsideration request to the Qualified Independent Contractor. 
8. Do redetermination requests have to be made in writing?
   
   Answer: Yes, they have to be made in writing or sent electronically through the http://www.NGSConnex.com portal. 
9. Where can I find the redetermination form?
   
   Answer: The National Government Services Medicare Redetermination Request form, along with additional information, is located under Quick Links > Forms.
   
   Related Content: Medicare Redetermination Request Form - First Level of Appeal (CMS-20027) 
10. Can I request a redetermination for all services in question on a specific claim at one time, or must I submit a separate redetermination form for each service in question?
    
    Answer: No, you do not have to submit a separate form for each service on the claim. In fact, we encourage you to request a redetermination for all services in question on the claim at one time. This ensures a faster response since any adjustments that need to be performed on your claim can be done at one time. This will also cut down on the number of letters and remittances you receive from us.

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These questions and answers come from the NGS Medicare frequently asked question (FAQ) database. FAQs cover a variety of topics and are a great resource for answering your questions, please visit our Web site at http://www.NGSMedicare.com, choose your Jurisdiction and Business and click on the FAQ tab.

On February 11, 2014, the Chair of the Workers’ Compensation Board (Board) adopted amendments to the regulations governing the conduct and reporting of Independent Medical Examinations (IMEs) (12 NYCRR §300.2). The amended regulation became effective on February 26, 2014.

This Subject Number highlights the significant changes contained in the amended regulation. The complete text of the amended regulation is located on the Board’s website under Laws, Regulations and Decisions.

Notices, Provision of Information, and Requests for Information

Service of Notices by Overnight Mail: Notice of the scheduled IME may be made using overnight mail as long as the notice is received by the claimant at least seven days prior to the scheduled examination.

Provision of Information: A new requirement has been added to the regulation that requires that every record, document, or test result supplied to an IME examiner for review in connection with an IME or records review must be a part of the Board file. Any information that is not already part of the Board file must be submitted before or at the time the IME or records review is arranged. Information submitted to the Board before or at the time the IME is arranged should not be submitted to the Board as a Request for Information using an IME-3.

Note: The submitting IME examiner must list all documents, reports, and other items reviewed in the IME or records review report.

Requests for Information: An IME-3 must be submitted to the Board when the provider receives any substantive communication regarding the claimant. An IME-3 shall not include documents, records, and items that are part of the Board file.

Reports of Examinations without Physical Examination or Records Reviews

A records review conducted by a medical provider without physically examining the claimant must be completed by a medical provider authorized to treat workers’ compensation claimants or authorized to conduct IMEs, or “qualified” within the meaning of 12 NYCRR §300.2 (b)(9). A medical provider that completes a records review must adhere to the rules governing IME reports at 12 NYCRR §300.2 (d)(4) including certifying the contents of the report and listing every document, record, or item reviewed in connection with the records review. A report of a records review must be submitted to all parties and the Board at least three business days before the hearing where it will be referenced.

Videotaping of IMEs

The amended regulation clarifies that an IME examiner may not refuse to conduct an IME when a claimant appears at the IME prepared to record or videotape the IME. A party (or agent of a party) may not alter a recording or videotape, nor may a videotape be distributed beyond its use in a hearing of the Board.

Reports

The amended regulation sets forth specific criteria for the content, certification, and signing of an IME report and a records review report. The reports must list all documents, records, and items reviewed by the examiner. Any questionnaires or intake sheets completed by the claimant must be attached to the report. In addition to the parties and the Board, copies of all reports must be submitted to attending providers that have treated the claimant within the last six months. The regulation states that a treating provider who examined the claimant solely for consultation or to perform a diagnostic test does not need to receive a copy of the report. The regulation specifies that a report may not be based on a checklist or questionnaire.

Exemptions

The amended regulation clarifies that a carrier's medical professional, as that term is defined in 12 NYCRR §324.1 (c), is not an IME examiner within the meaning of WCL §137 and 12 NYCRR §300.2. In addition, an examination conducted at a clinic that is a member of an occupational health network established pursuant to WCL §151 (3) is not an IME within the meaning of WCL §137 and 12 NYCRR §300.2.

IME entities

The term IME entity is defined. Services that may be supplied by an IME entity are described. The amended regulation sets forth clear and specific rules for IME reports submitted by IME entities. The amended regulation also clarifies that the IME examiner is responsible for certifying the contents of a report and that an IME report may not be derived from an IME examiner completing a checklist or form. The process for registering an IME entity is updated.

Suspension and revocation of the authorization of IME examiners and IME entities

The amended regulation updates the process and basis for suspending and revoking the authorization of a provider to perform IMEs and records reviews. The process and basis corresponds to the process and basis for suspending and revoking the authorization of treating providers as set forth in WCL §13-d.

The amended regulation also sets forth a process for revoking the registration of an IME entity.

Robert E. Beloten
Chair

CMS is extending the deadline for eligible professionals to attest to meaningful use for the Medicare EHR Incentive Program 2013 reporting year from 11:59 pm ET on February 28, 2014 to 11:59 pm ET March 31, 2014.

This extension will allow more time for providers to submit their meaningful use data and receive an incentive payment for the 2013 program year, as well as avoid the 2015 payment adjustment.

This extension does not impact the deadlines for the Medicaid EHR Incentive Program or any other CMS program, including the electronic submission for the Physician Quality Reporting System EHR Incentive Program Pilot.

How to attest?

If you are an eligible professional, you may use the registration and attestation system to submit your attestation for meaningful use for the 2013 reporting year. You must attest prior by 11:59 pm ET on March 31, 2014 to meet the new 2013 program deadline.

Resources

If you are an eligible professional working on your attestation for the 2013 reporting period, there are resources available to help you with the registration and attestation process.

• Stage 1 Meaningful Use Calculator
• Registration and Attestation User Guides
• EHR Incentive Program Website

The EHR Information Center is open to assist you with all of your registration and attestation system inquiries. Please call, 1-888-734-6433 (primary number) or 888-734-6563 (TTY number). The EHR Information Center is open Monday through Friday from 7:30 a.m. – 6:30 p.m. (Central Time), except federal holidays.

Tips

In addition, there are some simple steps you can take which will help to make the process easier for you:

• Ensure that your payment assignment and other relevant information is up to date in the Medicare payment system PECOS
• Make sure to include a valid email address in your EHR program registration
• Consider logging on to use the attestation system during non-peak hours such as evenings and weekends
• Log on to the registration and attestation system now and ensure that your information is up to date and begin entering your 2013 data
• If you experience attestation problems, call the EHR Incentive Program Help Desk and report the problem
• If your organization has more than 1,000 providers assigned to a proxy user, use the PECOS system to designate additional proxies to facilitate attestation.

"For possibly the first time since this "great compromise" between workers and employers was reached in 1914, the whole system is under review, not only by the Board but be representatives of all system participants. Never before has the Board taken the opportunity to work in conjunction with stakeholders and other major participants to examine the entire scheme and to seek to address the issues within it and to build into the system methods and mechanisms for making it self-correcting in the future."

BPR As-Is Assessment Report

NYSCA recognizes the currently challenges of NY's Workers Compensation system. As such we have been and will continue to be part of this review process. We will be meeting with the WCB again next week to continue to advocate for the needs of the injured workers of New York and our members.

Following our release of the fee schedule increase for Medicare codes 98940,-41 and -42 there seemed to be some disappointment in the overall results. While we all acknowledge that the most commonly used code, 98940 (thanks to Medicare audits), had the lowest percentage increase, the implicates can have far reaching impact as other carriers look to the RVU that Medicare sets. In addition, the ACA Medicare Carrier Advisory Committee and executives of the ACA have been diligently meeting the CMS and HHS to get us full scope coverage to include E & M codes as well as active and passive modalities. Unfortunately, as we know just from our dealings in NY that major changes take time. In the interim, a 2% increase in 98940 is better than another decrease, and as we draw closer to paying off the 2% reduction due to the overage of the demonstration project (thanks to some of our colleagues in part of Chicago), that decrease is anticipated to be lowered in the coming year.

For further information on the efforts of the ACA, please check out the following links:

• ACA Responds to Joint Congressional Discussion Draft on Medicare Physician Payment Reform (Nov 2013) 
• ACA RUC Advisors Comment to CMS on DCs Billing for Evaluation & Management (E/M) Services 
• ACAtoday.org Medicare Advocacy 

Respectfully submitted,
Mariangela Penna, DC
NY CAC Representative

A New Jersey federal judge has ruled that a doctor of chiropractic (DC) may pursue his overpayment allegations against UnitedHealthcare (United) even though his patients are no longer insured by the company. The ruling says patients are still subject to the health insurer's overpayment recoupment procedures.

United stands accused of retroactively reducing the amount of money owed to doctors of chiropractic as reimbursement for their incurred expenses. The litigation, filed on Jan. 24, 2011, represents a nationwide class of health care providers who were subjected to United's improper recoupment of payments for services provided to United subscribers. ACA joined the lawsuit in April 2011 when it added a host of injurious practices perpetrated upon practitioners by Optum, United's subsidiary.

Learn more about ACA's insurance advocacy work in the Chiropractic Network Action Center, www.acatoday.org/CNAC, which provides helpful resources and the latest information regarding network concerns for providers and their patients.

As per the recent ACA press release, thanks to the longstanding and ongoing efforts of the ACA effective 1/1/2014 there will be an increase in the RVU for CMT codes in the Medicare fee for service system. The increase amounts to slightly over 2% for code 98940, 9% for 98941 and 10% for 98942. As we know many other systems look to Medicare as their fee schedule base, theses increases may have far reaching impact. In addition there will be upcoming decreases in the fee reduction penalties due to the expenditures from the demonstration project. However please be advised that there is still a 20% reduction pending if the SGR remains in place. Although every year Congress acts at the last minute to repeal the SGR one never knows and a last minute grass roots effort may be necessary to hold off this reduction. Watch your emails for how you can help!

PQRS

It still isn’t too late to start for 2013, start now and you can avoid penalties in 2015! There will be some changes for 2014 and we will get those out to you as soon as they are available. Don’t wait start reporting appropriate G codes today. Visit www.acatoday.org and search PQRS2-13 toolkit for details.

Railroad Medicare Update

The ACA continues to dialogue with administrators from Palmetto GBA regarding their blanket denials and excessive documentation requirements. CMS prefers that this gets handled between Palmetto and the ACA but will step in if necessary. If you receive a denial on Railroad Medicare please appeal, it will be important if CMS has to intervene.

2014 Medicare Deductible

The Medicare deductible for 2014 is $147, unchanged from 2013. Medicare Part C (Advantage Plans) copayment for chiropractic services cannot exceed $20 or 50% in the case of co-insurance. If you have evidence of non-compliance with this please send it to the ACA. If patient is in a Part C plan that does not have a chiropractic panel and there is no out of network benefit you may charge the patient the appropriate Medicare limiting charge and are exempt from sending a claim.

Proper Use of an ABN Form

There is NO OPTING OUT of Medicare, you may be participating (accept assignment) or not. If you choose to not obtain a Medicare provider number you CANNOT see Medicare patients, the choice is yours. Having them sign an ABN on the first visit, declaring them maintenance with instruction to select Option 2 is not appropriate. As this is becoming a trend in some states with some groups many state boards are looking into this to sanction doctors.

For a properly delivered ABN, whether the patient selects Option 1 or 2 you may collect your full fee without Medicare fee restrictions. If the patient selects Option 1 submit the bill to Medicare, if Option 2 is selected a bill is not submitted.

CERT Reviews

Changes being made to CERT reviews, the time frame to respond was 75 days with 4 reminders by letter. Effective 1/1/2014 CERT review timeframe response has been shortened to 60 days with the initial letter Day 1 and reminders Days 30 and 45. As with all audits, read the letter carefully and send documentation as required by the letter, for assistance and guidance visit the ACA website at www.acatoday.org/Medicare.

Respectfully submitted,

Mariangela Penna, DC
NY CAC Representative