Click here for a printer-friendly version of this issue of Reimbursement Watch.

Are You Frustrated Trying to Understand PA Reimbursement Requirements?

Please note: The Webinar previously announced in this section of Reimbursement Watch has been cancelled due to technical difficulties. For further information, please contact Reimbursement Department staff at ext. 3211, 3219, or 3218.

CMS Wants to Know If You're Satisfied

The Centers for Medicare & Medicaid Services (CMS), the federal agency that administers the Medicare and Medicaid programs, launched its fifth annual survey to determine whether health care professionals and organizations that provide care to Medicare beneficiaries are satisfied with the contractors that process and pay more than $370 billion in fee-for-service Medicare claims each year. The Medicare Contractor Provider Satisfaction Survey (MCPSS) offers professionals and provider institutions (e.g., hospitals, nursing homes, rural health clinics, hospice facilities, etc.) an opportunity to give CMS feedback on their level of satisfaction, attitudes, perceptions, and opinions about the services provided by contractors that process claims and respond to inquiries. The MCPSS, which is a requirement of theMedicare Prescription Drug, Improvement and Modernization Act of 2003, is one of the few opportunities that CMS has to collect quantifiable data on contractors.

Survey questions focus on seven key business functions of the provider-contractor relationship such as inquiries, outreach and education activities, claims processing, appeals, enrollment, medical review, and audit and reimbursement functions.

CMS is sending the 2010 survey to approximately 30,000 randomly selected health care professionals and provider organizations, including physicians, physician assistants, and other health care practitioners, suppliers, and institutional facilities. Those health care professionals selected to participate in this year's survey will be notified starting this month. CMS will analyze the 2010 MCPSS data and release a summary report in the summer. For more information about the MCPSS, go to http://www.cms.hhs.gov/MCPSS.

If you click on the link to the MCPSS, you will find a listing of the various health care professionals and provider /supplier types that are eligible to participate in the survey. Physician assistants are listed, albeit with that darn apostrophe "s." While it's nice to be noticed, we don't understand why CMS lists PAs separately from other professionals (NPs, podiatrists, psychologists, etc.) who fall into the category of licensed practitioners. We are asking CMS to delete a separate mention of PAs, as they clearly belong in the same grouping with other licensed practitioners.

CMS will use the results from the survey to monitor trends, improve contractor oversight, and increase the efficiency of certain aspects of the Medicare program. Results of the survey will be posted on the MCPSS web site listed above.

Clarification on Respiratory Therapy Orders Causes Problems

A recent clarification of a 1986 Centers for Medicare and Medicaid Services (CMS) policy has caused problems with respiratory care ordered by PAs in hospitals. The current CMS interpretation is that respiratory therapy orders can be issued by PAs. However, CMS also requires that a physician co-sign the orders. No time frame for the co-signature is given. It is unclear why respiratory therapy orders were singled out to require a co-signature when so many other responsibilities provided by PAs do not.

The offending language, "[Respiratory] Services must be provided on, and in accordance with, the orders of a doctor of medicine or osteopathy," appears in section 482.57(b)(3) of the Code of Federal Regulations, first issued in the June 17, 1986 Federal Register. Apparently this requirement remained "under the radar screen" in recent years. And, at times language such as, ". . . in accordance with the orders of a doctor or medicine or osteopathy" is interpreted by CMS to include those who deliver physician services. That is not the case in this situation.

In the past, the Joint Commission (JC) was silent on this issue. In July 2009, JC promulgated a policy that did not allow PAs to order respiratory therapy. In late 2009, due to AAPA involvement, that policy was changed to allow PAs to write the order. Unfortunately, JC adopted language similar to CMS requiring a physician co-signature.

Many hospital electronic order entry systems will not allow an order to be carried out without the appropriate authentication. The option of having the order co-signed by the physician at a later date is not an option. The current interpretation has the potential of slowing down the ordering process and the timeliness of patients receiving needed care.

AAPA has a meeting scheduled on February 8th with the Chief Medical Officer for CMS, Dr. Barry Straube. This issue will be front and center in our discussions with Dr. Straube as AAPA believes that the requirement hinders patient access to timely care.

Opportunities to Talk In-Person with CMS Staff

The Centers for Medicare & Medicaid Services' (CMS) Open Door Forums provide an opportunity for dialogue between CMS staff and the health care professional and provider communities to better understand Medicare regulations and requirements, with the ultimate goal of assisting in providing more efficient and effective care to Medicare beneficiaries. Any interested party can take part in the calls. Participants in the open door conference call-type forums learn from each other's discussions, uncover useful clarifications regarding the different rules and instructions associated with coverage, coding, and payment policies. The forums typically occur every 4-6 weeks. The calls typically last an hour with the first 15-minutes used by CMS staff to provide updates on policies and ongoing issues. The next 45-minutes are devoted to answering questions from those who call in.

The fifteen open door forums focus on the following areas:

• Ambulance
• Disability
• Diversity
• End-stage Renal Disease
• Health Plans
• Home Health, Hospice & Durable Medical Equipment
• Hospitals
• Low-income health access
• Medicare Beneficiary Ombudsman
• New Freedom Initiative
• Pharmaceutical, Pharmacy & device Manufacturers
• Physicians, Nurses and Allied Health Professionals
• Rural Health
• Skilled Nursing facilities/Long-term Care
• Special Issues (as necessary)

The free-flowing exchanges of the Open Door Forums allow the healthcare community to interact with the agency personnel and also with CMS staff from the Regional Offices. The Open Door Forums provide an informal and candid discussion of current and recently proposed regulations or draft guidance. CMS points out that the forums are intended in all circumstances to be a complementary dialogue, and don't take the place of the formal comment periods associated with the rulemaking process.

To sign up to be notified about the Open Door calls and updates, or to choose the forums of greatest interest to you, go to https://subscriptions.cms.hhs.gov/service/subscribe.html?code=USCMS_C115.

Reimbursement Watch is a bi-monthly newsletter written by Michael Powe, AAPA Vice President of Health Systems and Reimbursement Policy. You are more than welcome to reprint items, just credit American Academy of Physician Assistant's Reimbursement Watch. Your comments, questions, and suggestions are welcome. Phone 703-836-2272 ext. 3211, Fax 703-684-1924 or Write: AAPA 950 North Washington Street, Alexandria, VA 22314-1552. E-mail address: This e-mail address is being protected from spambots. You need JavaScript enabled to view it .