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Public Policy & Advocacy

Local Medicare Issues from Medicare Carrier Advisory Committee
By Fitzhugh Pannill, M.D., FACP, CT ACP Chapter liaison to Medicare CAC

National Government Services (NGS) held its quarterly CAC meeting in early June to discuss a number of issues.

Several Local Medical determinations were reviewed about colonoscopy and other specialty procedures.

The issue of most concern to ACP was the audit of high level nursing home codes 99310 that NGS has done.

In the NY CT region there were 1300 99310s A DAY. Only 15 to 20% were properly documented and the rest were downcoded, if NGS received a copy of the notes. About 40% of MDs didn't even bother to reply to the request for documentation.

Other members pointed out the absurdity of the documentation requirements for nursing home patients (how do you do a11 point ROS in a demented patient?).

I raised the concern that if physicians can't be sure they will be paid for complex, usually emergency visits to a nursing home, many of them will just say "Send the patient to the ER" where the costs will be far higher. The argument did not seem to carry much weight.

NGS said their hands were tied, as the documentation standards are established by CMS. They welcomed any efforts by professional organizations to change these requirements. (this is their stance on most issues...they are only doing what CMS mandates).

I think ACP has a huge stake here, along with AAFP and the Medical Directors association. I would like to see if we can generate some national interest in 1) changing the documentation requirements and 2) monitoring the utilization of ER visits as these codes are not paid for.

Please contact me if there are issues you would like me to address with the local Medicare carrier.

Page updated: 07/30/10

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