Which Way Did They Go? One Went Up and Three Went Down
It’s time for New Year’s Resolutions to make a better “us” - time to set tasks for the new year to make sure the practice stays up to date and is functioning optimally. This includes staying on top of policy changes, fee schedules and contracts with individual payers. Some payers issue changes on a fiscal schedule, but the majority release new fee schedules at the beginning of the year. These schedules can generally be obtained on the payer’s online portal or through a written request sent to the payer. This is an excellent time to review all your payer contracts and verify any policy changes.
RVU Changes in 2019
On the horizon for 2019 are some slight changes to the RVUs for CMT codes 98940-98943. The practice expense (PE) RVUs dropped by .01 for codes 98940, 98942, and 98943. The final 2019 PFS conversion is $36.04 compared to the 2018 PFS conversion of $35.99. In the chart below, you’ll notice a very slight increase to the 98941 reimbursement and a decrease ranging from 0.30-0.33 for 98940, 98942 & 98943 respectively. However, verify if there is a sequestration in place with your Medicare Administrative Contractor (MAC) so that you utilize the exact fee schedule applicable to your office and jurisdiction. (Note: The table below is not your Medicare fee schedule.)
As chiropractors dealing with Medicare, fees are regulated only for the code set 98940-98942. Other commercial carriers, with expanded coverage for other services, may utilize the same RVUs in calculating their fees. You could see similar reductions and/or increases to fees for the allowable amount for your other service.
Do You Know Your Enrollment Status?
When evaluating fee schedules for your office, be aware of your enrollment and/or participation status with every payer as this can sometimes affect the allowable rate with Medicare. Chiropractors are afforded two options with Medicare: Participating (par) or Non-Participating (non-par). Pay careful attention to the fees associated with your enrollment type when verifying the fee schedule with Medicare. Please note that charging above the limiting fee by non-par providers can leave you subject to civil monetary penalties of $10,000 per occurrence for violating the Medicare limiting charge. No matter if you are Par or Non-Par, make sure to update your ABN form so that it is reflective of the current allowable rates with Medicare.
Let’s Dig Further
In 2019, the Medicare penalties for EHR Attestation/Meaningful Use and PQRS will no longer be individually assessed on reimbursements. In 2017, the MIPS program was introduced which became an umbrella to these two programs and added a measure labeled Improvement Activities. MIPS participation became mandatory under two threshold limits; however, if you fell under either of the thresholds, you were listed as exempt from mandatory reporting. Being exempt from MIPS removed the penalty for not participating with the Quality Reporting (formerly known as PQRS) and Advancing Care (EHR Attestation), and this will be evidenced on the 2019 reimbursements. If you were required to participate with the MIPS program in 2017 and did not satisfy the requirements, you will see a decrease to your reimbursements in 2019.
A final thought… When looking at the changes to the fee schedule above, one could be tempted to think about moving all 98940’s to 98941’s to capture the increase in reimbursement, but it is not that simple. Medicare, and other payers, have very strict rules on the utilization of any code relative to the patient’s complaint, condition and the medical necessity of the service. One of the biggest misconceptions we see at KMC University is the over usage of the 98941. While we often find ourselves adjusting 3-4 regions, we cannot always support the 98941 code and subsequently must utilize the 98940.
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Yvette Noel is the Membership Services Manager and conference speaker with KMC University. She is a Certified Professional Compliance Officer (CPCO). She has served the chiropractic community for 13 years and has worked in the medical field since 1988. Through this experience, she has continued to develop her skills of medical coding and billing. Before coming to KMC University, she managed a very successful Chiropractic and Occupational Health business. She remains very passionate about KMC University and takes much pleasure in helping members with their documentation, reimbursement, and compliance needs.