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Question: I know the No Surprises Act (NSA) and the CMS rules that put it in practice require that provider directories be kept up to date. But I thought that was all the insurers’ responsibility. The other day I was looking at guidance from a CMS’ Center for Consumer Information & Insurance Oversight (CCIIO) that says, among other things, “Under the No Surprises Act, providers and health care facilities must generally ... refund enrollees amounts paid in excess of in-network cost-sharing amounts with interest, if the enrollee has inadvertently received out-of-network care due to inaccurate provider directory information.” Why is this the providers’ responsibility?
Question: I have read the Part B News story about service animals in the practice (PBN 4/9/18). Since that story was published, I have seen a lot of coverage of “emotional support” animals and wonder if shared public spaces like the doctor’s office are required to accommodate them as well.
Question: What is the best way to determine if an E/M service is above and beyond the physician work normally associated with a procedure to justify the use of modifier 25 (Significant, separately identifiable E/M service by the same physician on the same day of the procedure or other service)?
Question: We have a provider who is performing knee implants that will allow him to bill for the remote therapeutic monitoring (RTM) codes (98980 and 98981). The vendor is telling us that clinical staff can perform these services based on coding information they found online, but a recent CPT Assistant seems to be saying that a physician or qualified health care practitioner (QHP) must personally perform those services and that they can’t be billed by clinical staff. I am not sure how to proceed.
Question: I read your recent article about incident-to billing. One of my practitioners has a question I am unable to answer. Is there a time limit on what is considered a new problem? For example, if a patient is not treated for a particular problem in over a year, is it now considered a new problem? Please advise.
Question: We performed transitional care management (TCM) on a patient who had been discharged as an inpatient by a provider from a different practice. When our claim went in, the payer did not have the discharge summary on file and denied our claim. What can we do?
Question: How do you code and bill for wound debridement involving the disposal of unused cellular-based tissue product (CTP)?
Question: Under the new E/M office visit guidelines, is there a way to code an office visit when the note doesn’t contain enough information for medical decision-making (MDM)? We regularly see charts that say things like “nosebleed” or “reviewed labs.” Asking providers to update their notes doesn’t work.
Question: Our practice is looking for ways to reduce the number of documents we use. Are we allowed to create our own version of Medicare’s advance beneficiary notice of non-coverage (ABN) that is based on a financial waiver used by some of our private payers?
Question: The CPT guidelines for E/M office visits (99202-99215) do not include examples of tests or treatments that are low risk or minimal risk. Our coders aren’t sure how to score risk for some encounters, so they send questions to the providers, which has had a negative impact on everyone’s productivity. Can we continue to use the examples of low and minimal risk management options from Medicare’s table of risk to code our office visits?


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