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August 26, 2020

Notification of Service Specific Post Payment Review for Drugs: Eylea/Aflibercept (J0178), Orencia/Abatacept (J0129), Krystexxa/Pegloticase (J2507)

The goal of CGS's Medical Review (MR) program is to reduce errors through claims reviews and education on Medicare's coverage, coding, payment and billing policies. To achieve this goal, we conduct data analysis to identify provider billing services of CPT/HCPCS codes that pose the greatest risk to the Medicare program.

The considerable high dollars involved (compared to other Part B services) creates the potential for significant risk. To mitigate potential risks to the Medicare program, in August 2020, CGS initiated service-specific post payment reviews to address potential insufficient documentation issues.

The reviews will involve ophthalmologists billing codes J0178, rheumatologists billing J0129, and/or rheumatologists and other providers billing J2507. Documentation will be reviewed for compliance with Medicare rules and regulations such as: medical necessity; appropriate orders and signatures; administration/deliverance of the service; as well as correct coding and billing of the drug as administered per medical necessity.

Additional Documentation Request (ADR) letters will be sent.  Please submit requested documentation within 45 days of receipt of the ADR letter. Please include a copy of your ADR letter and cover sheet with each claim documentation submission.  Failure to respond by the 45th day will result in denial for non-response and recoupment of dollars paid in error.

Documentation Necessary to Process the Claim

We expect the documentation submitted with each ADR letter to include a copy of the following legible and signed documentation from each patient's medical record:

  1. Beneficiary's name
  2. Date of service
  3. Patients weight for doses requiring calculation
  4. Signed Progress Notes which establish:
    • Medical necessity and relevant history
    • Signed order for the drug administration
  5. Purchase order for the drug.
    • Information regarding single use vs. multi use vials
    • Generic name (if applicable)
  6. Drug Administration Record, which supports:
    • The deliverance of the order
    • Name of drug
    • Amount of drug administered
    • Route
    • Location
    • Amount of drug wasted and by whom
  7. A copy of any mandatory ABNs
  8. Appropriate signatures
    • Signature and credentials of person performing the service do not meet CMS signature requirements
    • Amendments/corrections/delayed entries are properly identified
    • Amendments/corrections/delayed entries are initialed and dated by Author within 30 days of the billed service.
    • For more information regarding signature requirements, please visit our website at:

Guidelines regarding signature requirements are located in the CMS Medicare Program Integrity Manual (Pub. 100-08), chapter 3, section 3.3.2.4External PDF, "Signature RequirementsExternal PDF." Information is also available in CMS MLN Matters article MM6698External PDF, "Signature Requirements for Medical Review Purposes."

Notification of Results

Providers will be notified via results letter for denied claims with an estimated overpayment. You will receive a letter from Overpayment Recovery with the final overpayment amount. If you disagree with the decision, you may request a redetermination within 120 days of the date of your demand letter.

References:

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