AMA: 41 Senators Sign Letter to Stop Medicare Cuts

By Staff Reporters

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In a sign of legislative momentum, 41 senators are supporting efforts to prevent a pending 2.8 percent cut in Medicare physician payments that will go into effect January 1st. The bipartisan letter led by Sens. John Boozman, R-Ark., and Peter Welch, D-Vt., to Senate leaders says the cuts would interfere with the ability of physicians to provide high-quality care. “These continued payment cuts undermine the ability of independent clinical practices – especially in rural and under served areas – to care for their communities,” the letter said.

The Senate letter follows one from the American Medical Association (AMA) and 127 other state medical associations and national medical societies asking Congress to use these last few congressional days to prevent the scheduled cuts. The letter to congressional leaders also urges Congress to provide a positive payment update for 2025. All 50 state medical societies – and DC— as well as 77 national medical societies signed.

Source: AMA

CITE: https://www.r2library.com/Resource/Title/0826102549

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What is a Hospital CHARGE MASTER?

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By Dr. David Edward Marcinko MBA MEd CMP

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According to George Washington University, a hospital chargemaster is a comprehensive list of a hospital’s products, procedures, and services. Everything from prescription drugs to supplies for diagnostic tests has a unique price listing in the chargemaster, making it a go-to document for hospital administrators such as CFOs, clinical documentation improvement specialists, and revenue directors.

Chargemaster usage dates back to the mid-20th century. At that time, fee-for-service (FFS) health insurance plans, which allow patients to direct their medical care by choosing physicians and facilities and paying a portion of the billed total, had just emerged in the U.S. healthcare system.

The chargemaster originally served as something akin to an FFS dictionary, with an entry for virtually anything billable under that economic model of healthcare.

CITE: https://www.r2library.com/Resource/Title/082610254

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Over time, FFS itself has evolved and been challenged by alternatives like value-based care (VBC). Chargemasters built for FFS have changed accordingly, and they remain fixtures of the modern hospital revenue cycle. A standard chargemaster is a large electronic file containing multiple elements for each entry. These attributes usually include:

  • The charge for a single unit of the service in question
  • A Current Procedural Terminology (CPT) code; CPT is the official medical code set of the American Medical Association
  • Potentially, a Healthcare Common Practice Coding System (HCPCS) code; HCPCS is based on CPT
  • Alternative CPT and HCPCS codes if needed, e.g. one corresponding only to specific payers
  • A revenue code associated with the charge
  • Flag(s) indicating if the entry is scheduled for deletion, active or inactive
  • An internal reference number within the ledger for accounting purposes

LINK: https://revcycleintelligence.com/features/the-role-of-the-hospital-chargemaster-in-revenue-cycle-management

MORE: https://medicalexecutivepost.com/2013/09/26/some-modern-issues-impacting-hospital-revenue-cycles/

RCC: https://medicalexecutivepost.com/2013/03/06/a-better-approach-to-hospital-cost-estimation/

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MPFS Final Rule Cuts Physician Payments

Medicare Physician Fee Schedule

By Health Capital Consultants

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DEFINITION: The Centers for Medicare and Medicaid Services (CMS) uses the Medicare Physician Fee Schedule (MPFS) to reimburse physician services. The MPFS is funded by Part B and is composed of resource costs associated with physician work, practice expense and professional liability insurance.

Under the MPFS, each of these three elements is assigned a Relative Value Unit (RVU) for each Current Procedural Terminology (CPT®) code. These RVUs are then adjusted based on the Geographical Practice Cost Index associated with various geographic areas for different medical costs and wage differentials. The conversion factor is the national dollar amount that is multiplied by the total geographically adjusted RVU to determine the Medicare-allowed payment amount for a particular physician service.

CITE: https://www.r2library.com/Resource

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MPFS Final Rule Cuts Physician Payments

On November 2nd, 2023, the Centers for Medicare & Medicaid Services (CMS) released its finalized Medicare Physician Fee Schedule (MPFS) for calendar year (CY) 2024. While the finalized fee schedule cuts payments to physicians, there are a number of other (more positive) provisions in the final rule.

This Health Capital Topics article explores the various changes and updates included in the MPFS final rule. (Read more…)

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MEDICAL BILLING: Down and Up Coding?

By Staff Reporters

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DEFINITION

Upcoding is a type of fraud where healthcare providers submit inaccurate billing codes to insurance companies in order to receive inflated reimbursements. These false “current procedural technology” (CPT) submissions indicate that doctors provided patients with treatments that were more complex, costly, and time-consuming than what they actually received. This unlawful scheme is a violation of the False Claims Act (FCA) because it defrauds federal programs including Medicare, Medicaid, and Tricare.

CITE: https://www.r2library.com/Resource/Title/082610254

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There are nearly 7,800 CPT codes used by healthcare providers. Collectively, these codes represent all of the procedures, conditions, and drugs that are currently reimbursable by the health insurance industry. Each one of them has an associated cost for individuals and insurance companies, based upon the urgency of the issue and the complexity of the decision-making required of the healthcare provider. Medicaid and Medicare reimburse providers based on this system.
For example, a five-minute consultation with a nurse for a minor medical question would receive a different, less expensive CPT than the one for a full examination by a doctor lasting 45-minutes. However, if the physician charges the federal programs for the more expensive 45-minute examination when the five-minute consultation is what actually occurred, this would constitute upcoding.

Unbundling

Unbundling is another common form of upcoding. This fraudulent scheme involves billing for individual procedures that are usually performed and billed together under a single CPT code. In some cases, the billing codes for complicated medical operations have associated components built into their CPTs. For example, a hip replacement surgery may factor in the costs of the surgeon’s as well as the use of the operating room. Unbundling occurs when a healthcare provider submits each component within a CPT to Medicare or Medicaid separately. This creates a cost redundancy where wrongdoers can unlawfully seek reimbursement for the same procedure several times over.

CMS: https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/Downloads/Fraud-Abuse-MLN4649244.pdf

What Is Downcoding?

Downcoding is the opposite of upcoding. If you perform a service but record the CPT for a lower-level service, that is downcoding. Downcoding also leaves you vulnerable to an audit, which is never good. But, it can also cost a practice thousands of dollars a year in lost revenue because you’re not getting the higher rate of pay that you would if you had recorded the service properly.

According to the National Correct Coding Initiative (NCCI): “Physicians must avoid downcoding. If an HCPCS/CPT code exists that describes the services performed, the physician must report this code rather than report a less comprehensive code with other codes describing the services not included in the less comprehensive code.”

MORE: https://zeemedicalbilling.com/what-is-upcoding-and-downcoding-in-medical-billing/

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HERE: https://www.ncbi.nlm.nih.gov/pmc/articles/PMC8649706/

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PODCAST: Health Insurance Claims Adjudication Explained

MEDICAL CLAIMS ADJUDICATION

By Eric Bricker MD

Claims Adjudication Occurs between a Healthcare Provider Submitting a Claim to a Health Insurance Company and the Insurance Company Making a Payment Back to the Provider.

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The Healthcare Industry’s Unrecognized Cancer

The Untreated Cancer of Health Informatics Leads to Painful and Unrestrained Growth

By D. Kellus Pruitt DDS

A few days ago, Daniel Palestrant MD, Founder of par8o & SERMO, compared the American healthcare system to a patient with cancer.

The clinically blunt article includes a graphic photo of a fresh tumor the size of a cantaloupe, labeled “AMA.” It is appropriately titled, “I Know Cancer When I See It.”

I believe him. What’s more, Dr. Palestrant shows no respect for cancerous growth in healthcare. That’s Hippocratic cool.

http://par8o.com/wordpress/i-know-cancer-when-i-see-it/

I think we all know which presidential candidate’s think tank is to blame for selfishly stimulating metastasis of their harmful information. Like the American Medical Association, the ADA unwittingly developed informatics cancer years ago. Now, a similar, energy-sapping tumor is becoming increasingly difficult for stoic ADA officials to quietly schlepp around.

My Dental Analogy

If one replaces every mention of “AMA” in Dr. Palestrant’s excerpt below with “ADA,” every “CPT® code” with “CDT® code” and every “physician” with “dentist,” his analogy becomes strikingly similar to one I wore out long ago, but without an ugly photo (My apology to Dr. Palestrant):

1. Divert resources – The ADA’s CDT system creates a maze of payment infrastructure and rules that diverts resources to administration and makes transparency impossible.

2. Fool the immune system – The ADA has fooled the American public into believing they represent the opinion of America’s dentists.

3. Self perpetuate – Like a cancer, the ADA perpetuates itself through special interest lobbying, and most importantly, by updating the CDT codes as frequently as possible and forcing the entire dentalcare system to use them.

Assessment

If it weren’t for CDT® copyright royalties, ADA members’ dues would double – undoubtedly causing members to naturally demand better accountability to their patients’ welfare instead of HIT goals even Newt Gingrich abandoned a few months ago.

He’s a smart politician – arguably smarter than dentistry’s embarrassed leaders who own autographed photos of him.

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Snarky Example of a Medical Practice RAC Audit

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RAC Repayment Demand – Query

I just received a demand for payment from the RAC program for $32.46. I treated a patient with a non-displaced fibula fracture with a BK CAM boot and crutches. I coded 99212-25 and 27786,73610 on 1-29-09.  The audit claims the evaluation and management is part of the fracture care.

Should I appeal for $32.46?

Back then (3 years ago), my records were hand-written and not as comprehensive as they are now with EHR. Am I exposing myself to further inquiry by sending my admitedly inadequate records?

Doctor Name Withheld

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Is Informatics the The Curse of Healthcare Reform?

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Medical Coding Complications and Greed

[By Darrell K. Pruitt DDS]

Coding complications in government healthcare ALWAYS favor the house — CMS guarantees it with lawsuits and whistleblower rewards that could attract dishonest employees. Are you careful who you hire?

Complications 

Complications in healthcare informatics – including 5-digit CPT® code mistakes as well as foul-ups that involve physicians’ “voluntary” 10-digit National Provider Identifier numbers – ALWAYS grant insurers more time to pay past-due bills owed to their clients and their clients’ doctors.

Call me Cynical 

Call me cynical, but if interest rates climb ever higher as predicted, watch for unexplained, proportional increases in coding errors to help fund insurance CFOs’ bonuses while raising the cost of healthcare even more without improving value. Is it any wonder why Americans don’t get the quality of healthcare we purchase compared to citizens in other countries? Tax-payers in my neighborhood are begging for in-network providers who put their patients’ interests ahead of insurers’ as much as allowed by insurers’ self-serving rules – without committing fraud. As a general rule, healthcare stakeholders accommodate parasites more than principals.

CPT® Codes and Patient Care 

Accurate CPT® coding may have nothing to do with patient care, but CMS makes it nevertheless important to physicians. Whereas the most innocent NPI foul-ups reliably delay payment and never turn out well for providers, the new fraud and abuse provisions of the Patient Protection and Affordable Care Act [ACA] can cause an innocent coding mistake on a Medicare claim to land the doc in court with charges of fraud depending on the quality of employees one hires – but only if the error favors the provider and not the payer. In June, David Burda posted “Attorney tells audience to brace for a storm of whistle-blower lawsuits” on ModernHealthcare.com.

http://www.modernhealthcare.com/article/20100623/NEWS/306209989/-1

Of Whistle-Blower Lawsuits

Burda reports that healthcare attorney Joanne Judge, a partner with Stevens & Lee in Reading, Pa., predicts a significant increase in whistle-blower lawsuits simply because the new law makes it far too easy for a dishonest employee to file an unwarranted lawsuit. No longer is there a requirement for the whistleblower, who stands to win money from his or her patriotic effort, to directly witness the crime. That kind of idea could catch on in this economy.

computer-hardware1

“The new law also converts accidental Medicare overpayments to providers into potential false claims, Judge said. She said the law considers an overpayment as fraud if the overpayment isn’t identified by the provider and returned to the government within 60 days. Judge said that will require providers to beef up their internal billing systems to detect an overpayment as soon as possible and then send Medicare back its money.”

Assessment 

What can possibly go wrong with that plan? Thorough background checks on all new employees is increasingly important, doc. For my employment security issues, I’ve learned to depend on Richard at Investigation Resource Service out of Dallas. He’s never let me down (This is not a paid ad).

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Understanding Medical Billing Methodologies

The Cash Conversion Cycle

[By Staff Reporters]

Most patients and financial advisors don’t have a clue about how doctor’s get paid in our current system; but it’s not by magic. Yet, a number of different steps occur during the processing of a medical claim that can be seen in a flow chart. Each step in the process can be mapped out and each is subject to claim payment-or-claim rejection. A payment time line for a typical FFS or PPO can also be subjected to a number of variables, depending on different factors including staff competency, time, outside vendors, information management, management decisions in general, or regulatory requirements. The total transit times may take weeks for electronic claims or up to two-years for some paper based claims.

First Make the Diagnosis

• ICD-9 alpha numeric code for disease classes, not billing.

• HHS offers ICD-9 [CM] for MDs and facilities.

• WHO-1900, updated every 3-10 years, e-ICD-10 [2013].

• Diagnostic Statistical Manual Mental Disorders, 4th Edition [DSM-IV].

Then Select the Current Procedure Terminology® Code

Medical, surgical and diagnostic task & service billing code numbers [5-digit] of AMA used by payers:

• Thousands updated annually

• Secretive with registered mark ®

• Office Visits: [brief, inter, extended, etc]

• # 99214 physical exam

• # 90658 H1N1 flu shot

• # 12002 one-inch laceration suture

• CDT® and HCPCS codes, too!

Document the Visit in Patient Progress Notes

Subjective:

“I was gardening and noticed my wrist was swollen and itched like crazy”

Objective:

A 4 inch linear red rash with circular oozing papules and swollen skin is present. Patient is wearing a small tennis bracelet which was tight.

Assessment:

Rule out rues dermatitidis versus nickel allergy.

Plan:

Soap soaks, with OTC calamine lotion with Rx oral diphenhydramine or [benadryl].

Submit the “Super Bill”

Not a “big bill” or expensive medical invoice; just an invoice

• Official standard billing form used by doctors submitting MC/MD claims.

• Also used by some private insurers and managed care plans.

• Contains patient demographics, diagnostic codes, CPT®, HCPC codes, etc.

• Generic billing form, like the generic HCFA 1500 claim form.

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Diagnostic and Statistical Manual of Mental Disorders

Coding Classification

By Staff Reporters

The classification and coding systems used by mental health insurers both diagnosis-related groups (DRGs) and current procedural terminology (CPT®) are still being defined through historical methodologies and are vague compared to the medical classification coding structure.

As an example, mental health insurers classify Tourette Syndrome (TS) as a “mental disorder.” In fact, TS is an inherited, neurobiological disorder, and both neurologists and psychiatrists treat TS with the same medications. If TS were reclassified under the medical coding structure, TS would not only receive potentially a better reimbursement but public perception of TS as a “mental disorder” would be changed.

The DSM-IV

The Diagnostic and Statistical Manual of Mental Disorders (4th edition, text revision), also known as the DSM-IV-TR, is a manual published by the American Psychiatric Association (APA) that includes all currently recognized mental health disorders. The coding system utilized by the DSM-IV is designed to correspond with codes from the International Classification of Diseases, commonly referred to as the ICD. Since early versions of the DSM did not correspond with ICD codes and updates of the publications for the ICD and the DSM are not simultaneous, some distinctions in the coding systems may still be present.

Assessment

For this reason, it is recommended that users of these manuals consult the appropriate reference when accessing diagnostic codes. For more information, contact the APA at (800) 368-5777.

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Medical Coding and Billing Vocabulary

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Basic HIT Nomenclature and HIPAA

[By Richard J. Mata; MD, MIS, CMP™ [Hon]

For the Health Information Technology [HIT] department of a hospital, clinic or medical practice and its coders, the following medical vocabularies are mandated by the Health Insurance Portability and Accountability Act [HIPAA].

Diseases 

For diseases: the 9th or 10th International Classification of Diseases (ICD) Clinical Modification should be used.  ICD9-CM is maintained by the Centers for Disease Control National Center for Health Statistics, while ICD-10 is maintained by the World Health Organization.

Procedures

For medical procedures: a combination of ICD-9-CM, Current Procedural Terminology maintained by the American Medical Association, the Current Dental Terminology maintained by the American Dental Association, and Healthcare Common Procedure Coding System (HCPCS) maintained by CMS, which is also used for medical devices.

Pharmaceuticals

For drugs: these should be coded according to their National Drug Code classification.

Assessment

“A recent change to Medicare policy made by the Centers for Medicare & Medicaid Services (CMS) helps ensure claims processing isn’t delayed when the only missing information on the CMS-1490S form is the provider or supplier’s National Provider Identifier (NPI).

CMS Transmittal 1747, Change Request 6434, issued May 22, notifies A/B Medicare Administrative Contractors (MAC) and carriers of editorial changes to Medicare policy in Pub. 100-04, Medicare Claims Processing Manual, chapter 1 regarding the monitoring of claims submission violations and the handling of incomplete or invalid claims.

In either case, as stated in the transmittal, “If the beneficiary furnishes all other information but fails to supply the provider or supplier’s NPI, the contractor shall not return the claim but rather look up the provider or supplier’s NPI using the NPI registry.”

http://www.aapc.com/news/index.php/2009/06/missing-npi-no-reason-to-deny-says-cms/

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Physician [Fee] Schedule Augmentation

Organizing and Analyzing Financial Data

[By Christy Clodwick; MHA]

biz-book1After all medical practice management data has been gathered, organize it onto a spreadsheet or chart.  This analysis report will help to determine the codes and/or health plans that should be targeted for process improvement.

Focus … Focus … Focus

The focus should be on the highest volume and dollar value codes. Does this mean patients with unusual conditions or low dollar value codes are not treated? Hopefully it will not; but it will push this process forward and the practice will see the greatest benefit from these categories. When you review the report and find that a fee is being paid at a much lower rate, this would be indicative of a necessary negotiation with the payer for an increase for that procedure. Most health plans are committed to preventing disease. Maybe, but they are still actually aimed at treating diseases; not preventing them. If this is true of many payers then they should be willing to provide the incentives for those services to be carried out. You will find that some payers’ fee schedules are very much out of line with a percentage of Medicare payments, therefore the practice administrator should focus on those payers and bring evidence of the inadequacies to their attention.

The Specialists

Specialists are, for the most part, paid at a higher rate than primary care physicians not usually for the same service! And, with GPs as gatekeepers, the specialty doc incomes may have actually decreased in some instances, while the GPs may have increased. There was a time when Medicare had two conversion factors, and this was the result. This inequity could also be used as a tool for better reimbursement rates.

Finalizing the Fee and Revenue Analysis

When the final preparations of the fee analysis have been completed, it is time to react to the results of the findings. There are several options to choose from when it has been determined that a health plans fee schedule is not in tune with the practice’s financial growth. The practice should act on these results as soon as they are discovered, to avoid the loss of any more revenue.

No longer Accepting Health Plans

During the analysis phase, you may determine that a health plan’s payment levels are extremely low. You will have to determine whether the plan is worth negotiating or the practice administrator should consider dropping out of the plan altogether at the end of the contract period. It will have to be carefully determined by the local market. If the practice is in a highly competitive market, this process should not be considered as first choice. However, if the market is very slim, the health care purchaser will be responsible for complaining to the health insurance plan provider that there is simply not enough physician coverage for their employees for the area. This could be a very effective way to force a negotiation with the health care company. If this were the case, the area would have less managed care and more MC/MD.

Not Accepting New Patients from Low Paying Health Plans

One option would be to not accept any more patients from the health plan that is reimbursing the practice with low rates. Although this may initially lower your patient count, over time the practice will benefit from new patients with health plans that have a better reimbursement policy. Include snapshot of what the final analysis or report should look like and the details of what it should include. This can be used in any specialty to assist in putting together the individual practice analysis to achieve the same results. But is it noble or ethical? What about any willing provider laws?

dhimc-book1The Future for Health Care Reimbursement

The health care purchasers who pay most of the bills, such as employers and the government, will soon be challenging the annual increase and the overall cost of health care. The cost increases of the hospital and pharmacy sectors of healthcare are far higher than that of the physician. However, the pressure for cost containment is being felt across the board. This will eventually depress future reimbursement for all healthcare providers.  In the future it will be hard for practices to keep up with the demands of labor, malpractice and supply cost increase. All medical providers need to plan for this future paradigm. To offset this trend, physicians will need to get the most out of the work that they are doing today as well as look to new revenue generating procedures for their practice that will be cheaper and more convenient to the patient.

Process Improvement

The biggest benefits will come from continually improving the process of the daily operations of the practice, as well as ensuring accurate diagnostic coding. This will enable a practice to keep up with charge capturing through the explanation of benefits (EOB) when the charge has been processed and paid by the health insurance provider. When this process identifies that there is room for negotiation, the provider should proceed for a better reimbursement rate. If the provider is in a dominant market, the payers will be more likely to issue sweeping fee increases and so can you give me an example of this ever happening? By completing a Practice Fee Analysis, any practice should be able to use this tool to demonstrate the inequities and negotiate a better reimbursement rate for the practice.

Assessment

The first step in the negotiation process would be to contact a representative of the health insurance company that is in question. If you can produce compelling evidence to the representative, the negotiation process should be the next meeting. These folks may be fired if they do what you suggest, too frequently. Continually updating the practice fee schedule will help the practice stay on top of the contracts that it practices under. Practices that present a well-documented argument may (almost never) be rewarded with positive payer response. Again, proper planning will make for great future performance in any health care practice.

Conclusion

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Defining Current Procedural Terminology [CPT®] Codes

What they are – How they work

By Staff Reportersdhimc-book

The American Medical Association’s Physicians’ Current Procedural Terminology® is contained in the CPT user guide. The maintenance of these codes is the responsibility of the American Medical Association with consultation from the AMA CPT Editorial Panel, Advisory Committee, and the AMA CPT Health Care Professionals Advisory Committee. Procedure codes in the CPT user guide are reviewed and revised annually. The Health Care Financing Administration’s – now CMS – Common Procedure Coding System [HCPCS] lists three levels:  

Level I National Codes

CPT codes are five-character, all numeric configurations (e.g., 99215). Contact the American Medical Association to obtain a current copy of the CPT® Users Manual.

Level II National Codes

The HCPCS Level II National codes are contained in the HCPCS user’s guide and are published in the Federal Register. The maintenance of these codes is the responsibility of the Health Care Financing Administration [CMS]. Procedure codes in the HCPCS user guide are reviewed and revised annually. HCPCS codes are five characters with one alpha and four numeric configurations (e.g., A0042). Contact any publishing company that provides medical coding reference books to obtain a current copy of the current HCPCS User Manual.

Level III Medicare Local Codes*

Historically, local Medicare carriers developed local procedure codes which were published in the local Medicare Newsletters. The maintenance of these codes was the responsibility of the local Medicare carrier. Medicare local procedure codes were all five-character configurations with the following alpha/numeric configuration: one alpha, (W, X, Y or Z) with four numeric configurations (e.g., Y5523); and two alphas, (W, X, Y or Z) same character with three numeric identifiers (e.g., XX001). Contact your local Medicare carriers to obtain their Medicare Newsletters.

* Note: Due to HIPAA (Health Insurance Portability and Accountability Act) requirements, Medicare Local codes and the Office of Medicare Assistance Program Unique [OMAPU] codes were replaced with national standard procedure codes. 

Assessment

For more terminology information, please refer to the Dictionary of Health Economics and Finance.

Conclusion

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