Wednesday, May 25, 2016

Medicare 'Comparative Billing Report' Letters Go to 4,300 Psychiatrists

This month, 4,300 psychiatrists will receive a “Comparative Billing Report” regarding their billing for psychotherapy and evaluation and management (E/M) services (CBR 201607). These seven-page letters from eGlobalTech on behalf of the Centers for Medicare and Medicaid Services (CMS) have alarmed many APA members, and APA plans to share your concerns with CMS. But first, here are some facts to help you understand why you might receive one of these reports and what to do if you do.

Who should expect to receive these CBR letters?

  • Psychiatrists who had Medicare claims for services for psychotherapy (CPT® codes 90832, 90833, 90834, 90836, 90837, 90838) billed concurrently with E/M services (CPT codes 99211-99215) that were provided in 2015 “in the office” (site of service code 11)
  • and
  • were found to have “different billing patterns when compared to their peers.” (“Peers” were apparently defined at both the state and national levels.)

What information is contained in the CBR letter?

Each letter reviews your percentage of psychotherapy visits billed concurrently with E/M services, average minutes of psychotherapy per visit, average psychotherapy services per beneficiary, and total charges per beneficiary for E/M services. A sample CBR letter can be accessed on the eGlobalTech website.

What action should you take? Will you be audited?

The CBR letters and related resources encourage psychiatrists to check with their Medicare administrative contractor (MAC) to ensure they are meeting its billing and documentation standards and to perform a “self-audit.” But the sample CBR letter clearly states that CBRs are only “for educational and comparison purposes and do not indicate the identification of overpayments.” The eGlobalTech “Frequently Asked Questions” (FAQs) also state that the “CBR does not alter, change, or negate any of the documentation and billing requirements established by the MACs.” Above all, the FAQs say that “the CBR team does not conduct any audits.” APA believes a “self-audit” may be helpful for some psychiatrists, as it’s always good practice to check regularly for changes in MAC payment or documentation policies. Medicare audits are extremely unpredictable, but it would be unlikely for all 4,300 psychiatrists receiving CBRs to be audited.

Are psychiatrists being targeted?

No. Since 2010, MACs have released 59 different CBRs that focus on multiple physician specialties and other Medicare providers and services. These include internal medicine, orthopedic and general surgery, ophthalmology, cardiology, and dermatology. According to the sample CBR letter, 28.7 percent of 2014 payments for psychiatry and psychotherapy services were “improper,” as determined by Medicare’s “Comprehensive Error Rate Testing” (CERT) contractor. But “[n]early all the errors were the result of insufficient documentation” regarding the length of session, modalities of treatment, progress to date, and updated treatment plan. The sample CBR letter also cites 2001 and 2010 reports by the Department of Health and Human Services Office of Inspector General that found improper payments for psychiatry and psychotherapy services, but those reports predate the revised CPT® coding structure that was adopted in 2013.

Where can you get more information?

Psychiatrists who receive a CBR letter may want to register for the related CMS webinar on Wednesday, June 8, from 3 p.m. to 4:30 p.m. EDT. There will be an opportunity to ask questions, and a recording will be available in five days. Additional CBR resources include the following:

You may call the Practice Management Helpline at (800) 343-4671 with CBR questions or other queries about coding, reimbursement, or practice management.


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