Region D DAC Combined Meeting Minutes s1

Region D DAC Combined Meeting Minutes

Committee: Region D DAC Combined Quarterly Meeting / Time called to order:
Date: 10.28.15 / Time adjourned:
Members Present: Attendee List Attached to the Minutes / Location: Georgia World Congress Center
Atlanta, GA
Contractor Attendees:
NAS: Dr. Whitten, Dr. O’Neal, Cindy White, and Maggie Biel
CEDI: Stacy McDonald
CBIC: Elaine Hensley
CMS: Laurie Tan (on phone)
Jurisd. C: Michael Hanna / Chairperson: Mary Stoner
Record er: Barb Stockert, Administration
Purpose: Quarterly Meeting Update

AGENDA ITEM

/ RECOMMENDATIONS

OR ACTIONS

1.  Review of August 18th, 2015 Meeting Minutes / ·  Laura McIlvaine made a motion to approve them and Bob Clock seconded it. The minutes were approved.
2.  Product Education / ·  Ronda Buhrmester, VGM presented a request for product education at Noridian. As an example she said that Ventilator Suppliers could provide education and involve medical review nurses. Dr. Whitten said he felt this would be particularly helpful to everyone and this is why they go to Med Trade. Ronda said that it could be arranged to have medical review on the phone or the DAC could bring directly to you. If it is set up ahead of time it could include the PDAC. Don Hardin explained how this had been done before and Dr. Whitten said he appreciates the DAC and believes this will be very helpful.
3.  Announcement of New Executive Committee / ·  Mary Stoner announced the newly elected Executive Committee for the DAC. Chair: Gilbert Herrera, Vice Chair: Lelia Wilkerson, Secretary: Cindy Coy, Treasurer: Kimberlie Rogers-Bowers, and Past Chair: Mary Stoner.
4.  CEDI / ·  Stacy McDonald presented the CEDI Update. This is attached separately to the minutes.
3.  CMS / ·  Laurie Tan was only one in attendance but no update was given.
4.  RAC / ·  Dr. Philip Benjakul was not in attendance so no update was given. Dr. Whitten encouraged the DAC to continue to reach out to him. They are headquartered in Las Vegas so they would likely be able to attend our meeting in Feb/March.
5.  CBIC / ·  Elaine Hensley provided the CBIC Update. Elaine reported this is a very busy time for both suppliers and the CBIC.
·  Round 1 2017. Deadlines to note are: Registration closes on11/20/2015. Bidding is currently open but the covered document review date deadline is 11/16/2015. DeBids closes on 12/16/15 and the hardcopy package receipt deadline is 12/16/15.
·  If a mistake is made during submission of the bid it can be resubmitted within 10 days. Paula Koenig raised some valid points and suggested to register and add the profile going in. It is always open and does not have a deadline. Information needs to be current. Be paperless and go green is encouraged.
·  Bid evaluations for the Round 2 Re-compete are being done. Bonafide bid letters are due to go out in the next 30-60 days. These are to justify the bid amount. As an example if a supplier intended to bid $10.00 but it comes out as $100.00 the regulation is written that the bid cannot be changed. Suppliers have to be able to provide documentation that you can provide an item for your bid amount. Contract offers will be mailed starting in Jan. through March. Announcements of bid winders will be made. If your bid is not accepted you can contact the local liaison or call center.
·  Violeta Arnobeit said there were 19 winning bidders in Hawaii but they did not provide the services they were contracted or were not willing to provide these services. Because of this referral agents are not contacting them. Elaine explained CMS allows suppliers to bid and they are not required to live in the area. She said until this regulation is changed there is not much a supplier or referral source can do except contact the CBIC office. Competitive Bidding problems like this create issues because it impacts patients directly. Elaine said they do research the complaints and try to understand what is happening. She also said she understands how difficult this can be.
·  Paula Koenig also added that if someone was a contracted provider for Round 1 and even if they have not provided any service at all they would still be able to receive a contact for the new Round. The only thing that would exclude them would be a breach of contract. Kim Brummett also added that if a person is found to be in breach of their contract that the terms are noted in the letter they receive.
·  Paula Koenig noted that since transitions will be coming to a close in Round 2 that there is likely to be a shift in contract suppliers. Paula asked if there will be a focus on education to help patient’s transition to a new supplier? Elaine said they will do their best and some of these programs are more successful in some areas than in others.
·  A discussion on supplier documentation followed. Kimberlie Rogers-Bowers and Paula Koenig pointed out that there are significant issues with supplier’s previous documentation. Often they find that it either does not exist or there are a number of issues with it. Many times they will not accept the patient because they do not have the download or information that qualifies the patient. This is predominant for CPAP and is a huge problem with transitioning patients Elaine responded that this is outside the scope of Competitive Bidding but they are discussing potential changes. Kim Brummett suggested that they review CR 8952 and all they would have to do is add “and supplies” to the language of this Resolution. Dr. Moynihan has indicated that this is a problem that needs a solution. Mary Stoner asked if there was a definite person we could express our concern to. Kim Brummett stated that the next open door forum is on Nov. 4th and even though there is often not anyone responsible for DME on the call we should make the point. Kim reported that AA HomeCare is recommending to CMS that this needs to be fixed and will resubmit the issue so they can be prepared for it.
6.  Filing for O2 Denial / ·  This was presented by Kim Brummett at the 04/15 Combined Meeting. It was requested that the previous instruction that Jurisdiction B had on their website could be reintroduced and implemented across all Jurisdictions. Dr. Whitten reported that the DME’s discussed this but were not going to change it. They did not believe it was a policy issue. They suggested we take back to CMS. This will be removed from the agenda.
7.  CERT
Contractor Timelines / ·  This question was presented at the 04/15 Combined Meeting. What is the required time frame for CERT to respond to an audit? Michael Hanna with CGS responded that they had received the same question yesterday and he is not aware of a timeline. Sheila Roberson commented that it had gotten somewhat better and was averaging about 8 months now. Cindy White checked while discussion was going on and there is not currently a timeline for them.
8.  Allowable Pricing for National Rollout / ·  This was presented on the August, 2015 teleconference by Paula Koenig. There has been no update as of today. Paula followed up by saying we are desperate for pricing and a list of the codes.
9.  Providing Non-Covered Capped Rental Items as a Purchase / ·  Assistance is requested from CMS on this subject. Sometimes suppliers provide capped rental items as a purchase when secondary funding is willing to pay. Most often these companies require a Medicare denial to process and pay the claim. The way it is currently set up the claim cannot even get into the system. Discussion followed and this will be researched. It is possible something could be done or an edit added.
10.  Revising Codes E1399 and K0108 / ·  Paula Koenig replied that we saw the update on the proposal and appreciate that this will not be implemented.
11.  Timeline on Policy Changes / ·  Gilbert Herrera brought this concern to the group. We are often not able to provide feedback when appropriate. Sometimes on new or revised polices it appears they do not go out for full comment. Bill Noyes commented that this problem was seen with the entropic issue with IV PEN. The Pneumatic Compression Devices policy also appeared to have this problem.
Dr. Whitten responded that CMS, the attorney’s and they Medical Directors did not feel these things were in conflict with the rules. However if the DAC feels that something is not handled right or if the appropriate requirements were not met feel free to submit a complaint. It will be researched. He said the Medical Directors value the opinion of the DAC and they do not want to be over restrictive.
12.  Medical Director Update / ·  Dr. Whitten provided the update. He apologized that Dr. Moynihan was not there. They will try not to have this happen again.
·  Pneumatic Compression Devices have been the hot topic as of late. The Medical Directors are willing to meet with those that can provide the relevant information on the medical necessity requirements for needing an E0562./ He stated they will be willing to add this but no one has been able to provide them with this. He said the literature is just not quite there. He further stated that E0676 is a benefit exclusion. He values the opinions of the DAC and is willing to listen to all comments. *** Jonathan Ross with Bio Compression Systems followed up on this later in the meeting. He explained that there is a huge concern with the new LCD on PCD’s. The points are very restrictive and gave the example that the NCD states a patient with lymphedema qualifies after a 4 week treatment, whereas the new policy just states that if the ulcer improves you do not qualify. Another concern is the NCD allows for treatment of limbs with the E0652 but the new policy does not. Dr. Whitten suggested submitting a reconsideration process. They do not see a conflict with the NCD. They agreed to talk off line on this and will work with the National Wound Care Alliance. Jonathan thanked Dr. Whitten and said they look forward to the resubmission.
·  Everyone is looking at appeals and how the timeline can be reduced. They welcome input and appreciate the DAC’s involvement.
·  The Surgical Dressing policy is forthcoming. It definitely needs a complete overhaul and is very confusing. There is lots of controversy. Dr. Whitten also reported that there is a lot of discussion occurring with the Lower Limb Prosthetic policy.
·  Linda Skiple asked for clarification on a statement that was made on the August Ask the Contractor teleconference. This was regarding the NIV (Non-invasive Ventilator) policy and it was stated that the patient must be on the ventilator 24/7. This is not written in the NCD. Cindy White replied that if they are using the E0463 they must be on 24/7 with being able to be off for a very brief timeframe-maybe 2 hours. At this time this is how all contractors are reviewing this. Linda asked how did we get from an NCD that did not have these requirements to this? Dr. Whitten responded that if a E0464 is provided that patient should need full ventilator support. This should not be supplied as a F/S item when it could be handled by a bi-level or capped rent item.
13.  POE Update / ·  Cindy White provided the POE Update. It is attached to the minutes.
14.  Questions to CMS/Noridian / ·  a. Billing a NOC (such as L2999 in the case of orthotics). We have
always been told if there was a code similar to that NOC, we were
to use the description portion of the billing line to say, "similar to
LXXXX," - whatever code was appropriate (in this case, the most
similar code was a prosthetic code, even though we were billing
an orthotic device, which meant that we HAD to useL2999).
Recently this was done in a very complicated case and the NOC lines were denied because "there is a code that is more specific and you are required to bill to the highest level of specificity." When we contacted POE, we were told by a Rep that we were NOT to use the "similar to LXXXX" language, but instead, we were to use a written description of the code that the NOC was similar to (as in, "similar to a diagnostic socket for prosthetic use," as opposed to, "similar to L5620.") This is directly contrary to every instruction that we have ever been given in the past on this issue. We would like to clarify if this is a new process that we are not aware of, or if this is a matter of additional education being needed for the Noridian reps, etc.
Cindy White replied that all 4 medical directors were in agreement that the narrative description is what is important. If you are referencing a code to use in the narrative you should explain this code is similar to this and why you are not using it. You need to draw a parallel and the conclusion. Because is “Critical”.
a.  CGS Connect / ·  b. Cigna developed this service. Is Noridian looking at implementing something similar?
Cindy responded that they are talking about it and looking at the possibility. They allow for dialogue on ADR request as it allows for elimination of denials. Mary Stoner said we are not clinicians and don’t have the medical background to really evaluate and meet the needs of the patients. If we know what the review nurse is thinking up front we can determine if we should provide the product. Cindy reminded everyone that you always have to back up the paperwork, and have to rely what is in the phy. records.
HyQvia Coverage Policy / ·  c. This was brought forth in Oct. 2015. The IV PEN team wanted to know when the HyQvia coverage would be added to the External Infusion Pump LCD. It was understood that there were numerous comments on this.