CMS is Coming! CMS is Coming!

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CMS is Coming! CMS is Coming!Are You Ready?
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Introduction

• So you think you are ready for an auditmaybe,
  maybe not. This presentation will discuss some
  of the lessons learned before, during and after a
  CMS audit on the Medicare Secondary Payer
  Questionnaire.

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Objectives

• At the end of this session
• Understand why an audit is necessary
• Be able to name a minimum of three things they
  will need for the audit
• Describe some of the lessons learned and how can
  that translate to your hospital.

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Why is an Audit Necessary?

• Is the hospital billing correctly?
• COB Coordination of benefits
• Is the hospital receiving the correct funding
  from the correct insurance company is Medicare
  prime?
• Ensure proper payment is received
• Ensure taxpayers funds are used for their
  intended purpose.

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Why is Audit Necessary

• Is the hospital compliant with the regulation
• Is the MSPQ completed
• Is it completed correctly

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What is Necessary for an Audit?

• Patient Records
• Any and all records requested by auditors for
  review.
• The auditors will be looking for documentation of
  the MSPQ
• Patient Billing Records
• To review the submission of MSP information using
  condition and occurrence codes on the claim.
• Learning Modules
• They may ask what is your training regarding the
  MSPQ (always better to be prepared)

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Lessons Learned

• You will be interviewed by the auditor
• If they have questions the auditor will be asking
  you.
• Know your procedures and policies
• Know your ADT registration system

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Lessons Learned

• You may need to defend your processes
• Know your hospitals policies and procedures
  regarding completion of MSPQ
• Know the requirements you must fulfill
• Know the questionnaire
• Correctly document the answers in an accessible
  manner

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Frequently Asked Questions

• How often is the hospital required to complete
  MSPQ?
• Inpatient
• Every inpatient admission
• Outpatient
• Following the initial collection, the MSP
  information should be verified once every 90 days
• Do I have to complete the MSPQ for a beneficiary
  who has enrolled in a Medicare Advantage plan?
• No, hospitals are not required to ask the MSP
  questions or to collect, maintain or report this
  information

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Frequently Asked Questions

• When completing MSPQ, what should the provider do
  when the Medicare beneficiary is unsure of his
  retirement date?
• It is acceptable to use todays date minus five
  years if on Medicare longer than that or the date
  of entitlement.

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Frequently Asked Questions

• The model questionnaire does not include a date
  field. Should the date be captured as part of
  the MSPQ process?
• Yes, hospitals must be able to demonstrate that
  they collect MSP information on the correct date.
  Acceptable documentation is the last (dated)
  MSPQ, either electronic or hard copy.

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Frequently Asked Questions

• Are providers allowed to collect co-payments
  assessed by a primary payer from Medicare
  beneficiaries in an MSP case?
• No. Medicare providers must not accept from the
  beneficiary any co-payment or coinsurance upon
  services rendered when the primary payer is an
  employer Managed Care Organization (MCO) or any
  other type of primary insurance.

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Frequently Asked Questions

• Does the MSPQ require a signature?
• No
• When should providers report occurrence code 05
  (other accident) on an MSP claim?
• Occurrence code 05 indicates the date of an
  accident not described in codes 01 through 04.
  This code is used to report that the provider has
  developed for other casualty related payers.

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• QUESTIONS

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Presenters

• Beverly Cruz, BS, CHAM
• Supervisor Patient Access Department
• New York Presbyterian Hospital Weill Cornell
  Medical Center
• 212-585-6778
• bcruz_at_nyp.org
• Brenda Sauer, RN, MA, CHAM
• Director Patient Access Department
• New York Presbyterian Hospital Weill Cornell
  Medical Center
• 212-746-4630
• bsauer_at_nyp.org

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References

• Trailblazers Health Enterprises, Part A MSP
  Audit Questions and Answers, January 2011
• Centers for Medicaid Medicare Services,
  Medicare Secondary Payer (MSP) Manual, Chapter
  8, February 2005
• Centers for Medicaid Medicare Services,
  Medicare Secondary Payer Fact Sheet for
  Provider, Physician, and other Supplier Billing
  Staff, May 2010