Friday, June 1, 2018

Medicare Trivia Tidbits: Specimen Validity Testing, MACs and RACs, and Digestive Enzymes

Medicare issues hundreds of transmittals a year to its contractors (see 2018 here).  There have been about 13,000 from 2008 to 2018.   They cover topics both things that are major and minutiae.

What's interesting is there is often a story behind them.

Absolutely-Never-Ever-Never Bill Specimen Validity Testing
Document SE18001, issued March 29, 2018, informs drug testing labs that they absolutely, definitely, for sure, must not report specimen validity testing separately (e.g. pH or specific gravity testing).  The codes already say this ("sample validitation not reported separately") but someone at CMS wanted to be extra sure the message was clear.

MACs to the left of you, RACs to the right
In the past, as RACs (recovery audit contractors) developed audit programs, they were supposed to confer with regional MACs.  Document CR10349, issued in January 2018, says the MACs don't have to do that any more.   MAC stays on its side of the street, RAC on theirs.

Saga: Getting a HCPCS Code in Emergency Session
There must be a saga behind this one.  At the May 2017 HCPCS application public meetings, one of the most interesting was from a company that provided a special digestive enzyme cartridge which helps patients on enteral nutrition digest certain fats.   Like most code applications, in November 2017, CMS turned down that one as not necessary.  See the turn-down here (HCPCS 2017, #17.084, Alcresta Therapeutics, RELiZORB, here.)  CMS argued the product was already bundled into codes for feeding tube home supplies (B4034, '35, '36, based on syringe, pump, or gravity methods).

However, CR10626, June 1, 2018, issues a Q code (a special rapid CMS code) for the product, effective July 1, 2018.  It will be Q9994, "in line cartridge containing digestive enzymes, for enteral feeding, each."   My point is, there must be be an active back story with stakeholders up and down the hallways of the agency between December and June.  Congratulations on their success.

Why I Remember the Digestive Enzyme HCPCS Code Presentation:
Lesson Learned

I was in attendance at the May 2018 HCPCS meetings, and one of the nicest (clear, convincing) presentations was from Alcresta.   The speaker, with a right-sized set of good slides, explained that some patients had major problems with lipid digestion, that pre-digested lipids were unstable, and several clearly documented benefits of lipase enzyme supplements had major clinical impacts on patients with these lipid digestion problems.   When he finished, a CMS medical director asked, "Don't we already cover a hydrolyzed amino acid product?"   The speaker turned pale and hesitated a moment.   "This is...about..lipid digestion, not amino acids."   The medical director adjusted his glasses and shuffled his notes and nodded, "Yes, I think maybe you did mention lipids."    The take home lesson is that it's safest to assume your listener (and the key decision maker) is only processing about 10% of what you are saying, even after you've revised your 8-slide deck ten times and practiced your speech ten times.