Friday, August 09, 2013

NC Medicaid 'forgot' to Include Wrap-around Codes to Medicare When LME's took over Medicaid Management


Marsha V. Hammond, PhD, Licensed Psychologist, NC

Address: ______________________ cell: 828 772 5197


NC Mental Health Reform blogspot: http://madame-defarge.blogspot.com/

                                                 Date: August 9, 2013

RE: NC Medicaid ‘forgot’ to include wrap around to Medicare CPT 96152, Health &          Behavior code, for psychologists, when LME’s took over management of Medicaid 1.1.2013

Dear Dr. Diane Pedulla of the American Psychological Association Practice Directorate:

I am writing to you  about a very pressing practice matter which concerns NC psychologists. 

Thanks to the American Psychological Association, beginning in 2000, psychologists were allowed by CMS to utilize the Health & Behavior CPT code 96152 which allows more effective integration of health care.  Prior to the LME’s completely managing Medicaid in NC (in my practice area, it is Smoky Mountain Center LME, about to become the largest LME in NC as Western Highlands Network LME is to be incorporated into SMC LME 10.1.2013), this Medicare CPT code, 96152, paid appropriately and it automatically wrapped around to a DIFFERENT outpatient therapy code via NC Medicaid.  There were no payment issues prior to the LME’s taking over NC Medicaid.  For the past 8 years, I have been paid on time and appropriately for my dually eligible clients, those people being insured primarily by Medicare, w/ a wrap-around to Medicaid.

Prior to 1.1.2013, Value Options and HP Enterprises managed authorizations and payment of NC Medicaid.  Since the LME’s have taken over the complete management of NC Medicaid, utilizing a system known as “NC Tracks”, there is no wrap around available.  I have spoken, at length, to people working at NC Tracks.  I spent an hour today on the phone with an employee there, going over the 288 page Medicaid manual and there is NO MENTION ANYWHERE of 96152 ‘cross-walking’ to any Medicaid code: nada; nothing; does not exist.  I received a ‘number’ which creates a complaint which hopefully will be addressed by the Claims department associated w/ NC Tracks/ NC Medicaid.  

Undoubtedly, when the CPT codes changes and when Value Options and HP Enterprises exited the picture---and the LME’s and NC Tracks via NC DHHS took over the management of NC Medicaid, the ball was dropped re: including the wrap-around for psychologists re: this Medicare code, 96152.  As I stated, prior to 1.1.2013, NC Medicaid AUTOMATICALLY CHANGED THIS OUTPT CODE in order to facilitate wrap-around.  I do not have my old Remittance paperwork indicating what I was paid and since there is no more HP Enterprises or NC Webclaims, where I could view the information online, I cannot pass that to you.  All I can tell you is that the employee at NC Tracks and I were startled to find out that there was so little mention in the NC Medicaid 288 page manual re: psychologists.  That should have been addressed by NCPA, IMO.

Please do not advise me to contact NC Psychological Association.  I already have. Many times over the past 13 years I have complained loudly about the lack of involvement of NCPA re: public mental health e.g., Medicare/ Medicaid.

Today  I left Executive Director Sally Cameron (ncpasally@mindspring.com) a very clear message.  I have joined and un-joined NCPA twice over the past 13 years as they pay no attention to public mental health.  If you have any leverage re: NC Medicaid via NCPA, perhaps you could utilize that. I know that Dr. Tony Puente, who lives in Wilmington, NC, has done a great deal of work re: psychologists’ reimbursement vis a vis CMS (as well as his colleague George, whose Greek last name I cannot spell).  Perhaps you can pass this to him or another pertinent party. 

Every practice day I utilize the appropriate 96152 CPT code.  Every day psychologists in NC undoubtedly use it.  Why? Because it pays at the 80% ‘medical rate’ and because it is an ‘integrative’ CPT code, if you will.  Doctoral level psychologists, such as myself, do doctoral level work and that includes integration with primary care practitioners, etc.

I am looking forward to hearing some information about this.  Feel free to pass this to any pertinent party.  Thanks for your hard work over the years.

Sincerely,

Marsha V. Hammond, PhD, Licensed Psychologist, NC

Cc: Sally Cameron, Executive Director NCPA; Mr. Tax, Claims Director Smoky Mountain Center LME; other employees associated w/ Claims at SMC LME

Bert Bennett, PhD, Psychologist (Behavioral Health Division NC DHHS)

 

Thursday, August 08, 2013

(About to Be) Largest LME in NC unable to manage fine points of Medicaid re: payment to providers

This is a long series of e mail exchanges between myself and the head of Claims at Smoky Mountain Center LME which, as a reminder, will be taking over Western Highlands Network LME 10.1.2013.  It will be---by far---the largest LME in the state.  There is nothing confidential in these e mails and so I am publishing them on my blog so that other providers can see that the LME's continue to not be able to 'manage' Medicaid.  It is not acceptable. 
 
Sorry to continue to be the pain in the arse to these LME's but someone should do it. 
 
Start at the end and you will see just what a mess NC Tracks is.  NC Tracks is some weird thing that took over Value Options and HP Enterprises who were doing just fine until the LME's took over 'managing' Medicaid.  Do I smell consulting by former Secretary of DHHS, Lanier Cansler, "Mr Revolving Door", in and out of government/ in and out of consultation... here?  I wonder if Lanier Cansler has anything to do with these entities that took over, specifically "CSC is Computer Sciences Corporation, the entity that NC DMA contracts with to deliver and administer the NC Tracks MMIS Claims Processing system."
 
 
 
                          **********************************
 
Dear Mr. Tax: thanks again for your suggestions.  As re: professional organizations, I have joined----and unjoined---- the NC Psychological Association x2 over the past 13 years and will not join again because they give not a fig about public mental health.  I will be contacting Tony Puente PhD over in Wilmington and his colleagues who interface w/ CMS and American Psychological Association.  "Forty day roll-out" means very little to me re: NC Tracks.  I am losing money every minute re: the non-continuation of a link between Medicare and Medicaid as associated w/ SMC 'managing' Medicaid.  And as I explained, NC Medicaid did not have this problem re: no ability to 'pass' if you will, the 96152 Medicare code over into Medicaid prior to the LME's 'managing' Medicaid.  I will call Vicki at NC Disability Rights.  And maybe you know a good attorney?  There is a Medicaid appeals attorney over in Charlotte who was doing a lot of work re: appeals as associated with public legal defense system.  Its not OK that SMC LME is not finding an answer to my very legitimate question.  If you have some more ideas, then let me know.  Have a good day.  Sincerely, Marsha V. Hammond, PhD 
--- Originally sent by paul.tax@smokymountaincenter.com on Aug 8, 2013 12:42 PM ---
This message was sent securely using ZixCorp.


My final suggestions:
 
Ø  You’ll find ample references to CSC and the NC Tracks system in the NC Medicaid Bulletins (monthly) and any posted Communications Bulletins.  See: http://www.ncdhhs.gov/dma/bulletin/index.htm
 
Ø  Use the published Customer Services contacts for phone, email, etc. that are provided for CSC, NC Tracks, and NC DMA.  Know that the lines/ queues may be long as we are not yet at the 40-day mark for the new system roll-out. 
 
Ø  Confer with any Provider Groups, Licensing Boards or advocacy group to which you may belong.  They are often tracking issues for their memberships…
 
Best wishes.  Thank you again for your consideration.
 
Paul
 
Paul Tax, Claims Director
Smoky Mountain Center
paul.tax@smokymountaincenter.com
828.586.5501 x. 1170
 
From: chomskysright@gmail.com [mailto:chomskysright@gmail.com]
Sent: Thursday, August 08, 2013 12:37 PM
To: Brian Ingraham; Sonia Eldridge; Paul Tax
Cc: Julia Sinclair; Patty Wilson; Donald Reuss; bert.bennett@dhhs.nc.gov; Lisa Slusher
Subject: RE: (cont'd) re: 96152 coding wrap-around

Mr. Tax: Thanks for the information.  Here is the webpage for CSC: http://www.csc.com/.  It appears to be a gigantic corporation and there is absolutely no information re: anything associated w/ NC Medicaid evident there.  Moreover, in maintaining my role as chief complainer as associated with both WHN LME and SMC LME (although SMC has improved greatly over the years) the NC Tracks is a barrier also.  Just who do I call in NC Tracks? Oh for the days of HP and VO. I find it very vexing that I have to spend so much time putting back into place a system which worked well prior to the LME's taking over Medicaid.  I have now telephoned Dr. Bennett, a psychologist within Behavioral Health at DMA, x2, leaving very specific messages; I have seldom caught him at his desk.  I have sent him all the information you have sent to me in two e mails today. If you have any other suggestions, please do pass them on to me. Thank you.  Again, 96152 is the most correct code for me to use given what I am doing which is pertaining to integrating health care between myself and the medical providers of my clients.  Moreover, it pays me at the medical rate, specifically, 80%, rather than the mental health pay of 50%.  I think you can understand why I am being so persistent here, particularly in light of having successfully used this code FOR YEARS as associated my dually eligible Medicare/ Medicaid clients.   Sincerely, Marsha V. Hammond, PhD


--- Originally sent by paul.tax@smokymountaincenter.com on Aug 8, 2013 12:17 PM ---


CSC is Computer Sciences Corporation, the entity that NC DMA contracts with to deliver and administer the NC Tracks MMIS Claims Processing system.  In an earlier period, I would have referenced HP.
 
Hope that clarifies.
 
Thank you
 
Paul
 
Paul Tax, Claims Director
Smoky Mountain Center
828.586.5501 x. 1170
 
From: chomskysright@gmail.com [mailto:chomskysright@gmail.com]
Sent: Thursday, August 08, 2013 12:09 PM
To: Brian Ingraham; Sonia Eldridge; Paul Tax
Cc: bert.bennett@dhhs.nc.gov; Lisa Slusher; Patty Wilson; Julia Sinclair; Donald Reuss
Subject: RE: (cont'd) re: 96152 coding wrap-around

Mr. Tax: 

Thank you for your reply. What is CSC that you refer to accordingly: "I would advise you to confer with Dr. Bennett or others to determine if there is an option for you to bill secondary claims to NC DMA via CSC for the dual eligible consumers that you referenced, as this is a non-covered service with SMC. "

 I note your NC DMA doc below.  It does not pertain to me.  As a Medicare enrolled psychologist, for the past 8 years, I have reliably used 96152 for MEDICARE ONLY .  

96152, was never and undoubtedly never will be a Medicaid code for use by psychologists.  It is a MEDICARE CODE as per psychologists. That is not the issue here.  

For dually eligible clients ONLY e.g., those w/ Medicare as primary and Medicaid as secondary----until 1.1.2013----when SMC took over Medicaid for its catchment area----I reliably submitted and was paid, via my biller, Compuclaims Plus, 96152 for Medicare FIRST----as it is primary----and then NC Medicaid, via Value Options.  NC Medicaid, via Value Options, upon Medicare payment, would then wrap around WITH A DIFFERENT CODE that was a psychotherapy code.  It was an automatic wrap-around.  I submitted nothing.  I only had to submit to NC Webclaims for Medicaid ONLY clients.   

And as I stated before, since there is no more NC Webclaims and no more Value Options paying me, I cannot get access to any Remittance Advice statements to reveal that NC Medicaid automatically wrapped around once Medicare was 'engaged', so to speak, for these dually eligible clients . 

I will call Dr. Bennett in the Behavioral Health Section of NC DMA again now.  I left him a message earlier.  I have consulted w/ him intermittently over the years re: vexsome issues. 
--- Originally sent by paul.tax@smokymountaincenter.com on Aug 8, 2013 11:38 AM ---

Dr. Hammond:
 
I am providing you with couple pieces of information that are the basis for our decision as an MCO to not recognize the 96152 code.  Attached is an excerpt from the Behavioral Health Databook that governs our covered services, as established by NC DMA.  The 96152 code is not included in that table.
 
The second reference is a recapitulation of the June 2010 Medicaid Bulletin which references the services that fall under the original waiver pilot (Cardinal Innovation, f.k.a. Piedmont Cardinal, PBH).
Note that while 96152 is referenced, it is only included when provided by a Psychiatrist.  As a Licensed Psychologist, you would not be considered an eligible provider of this service to the MCO(s).
 
I would advise you to confer with Dr. Bennett or others to determine if there is an option for you to bill secondary claims to NC DMA via CSC for the dual eligible consumers that you referenced, as this is a non-covered service with SMC. 
 
Thank you for your consideration.
 
Paul
 
 
 
FYI
 
From June 2010 Medicaid Bulletin
 
Attention: All Providers
N.C. Mental Health, Developmental Disabilities, and Substance Abuse
Services Health Plan Waiver (Formerly, Piedmont Cardinal Health Plan)
Effective July 1, 2010, additional services will be added to the N.C. Mental Health, Developmental Disabilities
and Substance Abuse Services (MH/DD/SAS) Health Plan Waiver. The MH/DD/SAS Health Plan currently
operates in Cabarrus, Davidson, Rowan, Stanly, and Union counties and is administered by the area Local
Management Entity, Piedmont Behavioral Healthcare (PBH). Except for emergency services, all MH/DD/SAS
providers must obtain prior authorization from PBH to qualify for reimbursement of services provided to
Medicaid recipients who, for Medicaid purposes, are residents of the PBH five-county catchment area.

The services listed in the table below will be included in the MH/DD/SAS Health Plan beginning with dates of
service July 1, 2010, when
· the service is provided by a psychiatrist;
· the Medicaid recipient is a resident, for Medicaid purposes, of the PBH catchment area; and
· the Medicaid recipient’s primary diagnosis is in the 290 through 319 range.
If the conditions listed above are met, psychiatrists must obtain prior authorization from PBH to qualify for
reimbursement for these services.
Narcosynthesis for Psychiatric Diagnostic and Therapeutic Purposes
90865
Evaluation of Implanted Neurostimulator
95970 95971 95972 95973
95974 95975 95978 95979
Standardized Cognitive Performance Testing
96125
Biopsychosocial Assessment/Intervention
96150 96151 96152
Outpatient and Other Visits
99201 99202 99203 99204 99205
99211 99212 99213 99214 99215
Facility Observation Visits: Initial and Discharge
99217 99218 99219 99220
Inpatient Hospital Visits: Initial and Subsequent
99223 99231 99232 99233
Observation/Inpatient Visits: Admitted/Discharged
99234 99235 99236
Inpatient Hospital Discharge Services
99238 99239
Consultations
99241 99242 99243 99244 99245
99251 99252 99253 99254 99255
Emergency Department Visits
99281 99282 99283 99284 99285
Nursing Facility Visits
99304 99305 99306 99307 99308
99309 99310 99315 99316 99318
Domiciliary Care, Rest Home, Assisted Living Visits
99321 99325 99326 99327 99328
99334 99335 99336 99337
Care Plan Oversight: Domiciliary Care, Rest Home, Assisted Living and Home
99339 99340
Home Visits
99341 99342 99343 99344 99345
99347 99348 99349 99350
Prolonged Services Outside Customary Services
99354 99355 99356 99357 99358 99359
Alcohol and/or Substance Abuse Structured Screening
99408
Injections: Diagnostic/Preventive/Therapeutic
96372 96373 96374 96375 96379
Telehealth Originating Site Facility Fee
Q3014
All services provided in emergency rooms to Medicaid recipients residing in the PBH catchment area with a
primary diagnosis in the 290 through 319 range will be included in the MH/DD/SAS Health Plan beginning with
dates of service July 1, 2010. Providers of emergency room services must contact PBH for reimbursement.
These services are currently billed under the following revenue codes:
Emergency Room
RC450 RC451 RC452 RC456 RC459
Behavioral Health and Waiver
 
 
Paul Tax, Claims Director
Smoky Mountain Center
828.586.5501 x. 1170
 
From: Marsha Hammond,PhD [mailto:chomskysright@gmail.com]
Sent: Thursday, August 08, 2013 10:16 AM
To: Paul Tax; Sonia Eldridge; Brian Ingraham
Cc: Bert Bennett
Subject: (cont'd) re: 96152 coding wrap-around

I am sorry, Mr. Tax.  The e mail that you just received fired off before I could finish it.  Please discard that as it is incomplete.  Below is that e mail finished up.  thank you.  

                                         ********************************

Marsha V. Hammond, PhD, Licensed Psychologist, NC
cell: 828 772 5197
 
RE: MEDICARE code 96152 which wrapped around to NC Medicaid psychotherapy code e.g., 90806, etc.
 
Date: August 8, 2013
 
Dear Mr. Tax: 
 
Thank you for contacting me.  I KNOW that 96152 is not in my SMC contract.  It has NEVER been a Medicaid code.  It is a Health & Behavior code, put into use by the American Psychological Association in conjunction w/ discussions w/ CMS in 2000.  I have used it for years without the issues that are plaguing me as associated w/ SMC LME. 
 
If I could turn up my old Medicaid RA's, which are now unavailable as Value Options no longer manages any part of NC Medicaid, via the NC webclaims site, I could print them out and send them to you.  I do not keep my RA's from previous years.  
 
As I stated before, prior to the LME's taking over Medicaid, this is what would happen when I submitted a 96152 MEDICARE code for dually eligible clients.  NOTE: This is not what took place re: MEDICAID ONLY clients.  For those clients, I would simply go to NC Medicaid webclaims, submit the (then) 90806 or whatever applicable code and be paid. 
 
NC MEDICAID VALUE OPTIONS AUTOMATICALLY WRAPPED AROUND for the dually eligible Medicare/ Medicaid clients utilizing the 96152 Medicare code.  HOWEVER, a different psychotherapy code was applied.  I never asked why.  I simply got paid.  
 
I have contacted as per this e mail Dr. Bert Bennett of NC Medicaid, a psychologist working in Raleigh w/ Behavioral Health to see if he can advise you about this matter.  I have no idea how to contact Value Options and reobtain my RA's so you understand that this is how things occurred for years prior to the LME's taking over NC Medicaid.  
 
96152 is the most appropriate code for me to use as I interface w/ physicians, psychiatrists, etc., to provide integrated care for my patients who commonly have overlapping medical and mental health issues. 
 
I left you a voice mail a moment ago.  Thank you for continuing to look into this matter.  

Sincerely, 
Marsha V. Hammond, PhD

Continued Problems w/ Using Health & Behavior Codes 96152 under New NC Medicaid Management Assoc w/ LME's

Here is a letter to the head of Claims at Smoky Mountain Center LME.  If anyone has any information about how to hack through this, given that there is no more Value Options managing NC Medicaid, please let me know.  Thank you: chomskysright@gmail.com

                         ***********************************************
Marsha V. Hammond, PhD, Licensed Psychologist, NC
e mail: chomskysright@gmail.com

RE: MEDICARE code 96152 which wrapped around to NC Medicaid psychotherapy code e.g., 90806, etc.

Date: August 8, 2013

Dear Mr. Tax, head of Claims at SMC LME: 

Thank you for contacting me.  I KNOW that 96152 is not in my SMC contract.  It has NEVER been a Medicaid code.  It is a Health & Behavior code, put into use by the American Psychological Association in conjunction w/ discussions w/ CMS in 2000.  I have used it for years without the issues that are plaguing me as associated w/ SMC LME. 

If I could turn up my old Medicaid RA's, which are now unavailable as Value Options no longer manages any part of NC Medicaid, via the NC webclaims site, I could print them out and send them to you.  I do not keep my RA's from previous years.  

As I stated before, prior to the LME's taking over Medicaid, this is what would happen when I submitted a 96152 MEDICARE code for dually eligible clients.  NOTE: This is not what took place re: MEDICAID ONLY clients.  For those clients, I would simply go to NC Medicaid webclaims, submit the (then) 90806 or whatever applicable code and be paid. 

NC MEDICAID VALUE OPTIONS AUTOMATICALLY WRAPPED AROUND for the dually eligible Medicare/ Medicaid clients utilizing the 96152 Medicare code.  HOWEVER, a different psychotherapy code was applied.  I never asked why.  I simply got paid.  

I have contacted as per this e mail Dr. Bert Bennett of NC Medicaid, a psychologist working in Raleigh w/ Behavioral Health to see if he can advise you about this matter.  I have no idea how to contact Value Options and reobtain my RA's so you understand that this is how things occurred for years prior to the LME's taking over NC Medicaid.  

96152 is the most appropriate code for me to use as I interface w/ physicians, psychiatrists, etc., to provide integrated care for my patients who commonly have overlapping medical and mental health issues. 

I left you a voice mail a moment ago.  Thank you for continuing to look into this matter.  

Sincerely, 
Marsha V. Hammond, PhD

Sunday, August 04, 2013

How Does Humana Change from a 'Medicare Advantage' Company to a 'Private Company' w/o Advising Providers?

This is associated w/ a conversation w/ an aide in Senator Burr's office:  Cooke, Jason (Burr) <Jason_Cooke@burr.senate.gov> wrote:

                      ****************************************************************

FROM: Marsha V. Hammond, PhD 
Clinical / Health Psychology
NC Licensed Psychologist

DATE: June 28, 2013


RE: request for policy paper from CMS as re: agreement w/ Humana that professional providers must go onto the Humana Panel


Hi Mr. Jason Cooke of Senator Burr's office: 

Thank you for speaking w/ me on the phone the other day. 

We spoke about the matter associated with some kind of contract or agreement which has obviously been created between CMS and Humana causing Humana to require professional mental health providers, such as myself, to move 'onto panel' when this was not an issue prior to 1.1.2013.  Humana did not tell providers that they had to do this.  Only after bugging NC Insur Comm office, a higher up woman stated that yes, it was her understanding also that providers had to apply to be on the panel.  I did this about a month ago. 

This is yet another barrier to health care.  As you know, Humana purports to be a 'Medicare Advantage' company which causes its insured or those considering jumping from regular Medicare to a Medicare Advantage company to believe there is no impact upon providers.  I have lost thousands of dollars re: Humana's management of its mental health services.  As I advised you, I have talked w/ a CMS representative, specifically the gentleman at this number: 410 786 1047) and have e mailed him.  The only thing he was able to do was to link BACK to Humana who, of course, had no answers.  

I want a copy of the policy paper or policy change that created the necessity of me, a PhD psychologist, long utilizing Medicare, to go onto the Humana Network.  As of this date, I have not been approved.  Humana indicated to me----after a dozen phone calls from my end----that it would 'take months' for this to take place.  So, meantime, I am paid at a lesser rate and less than what I was being paid last year.  Additionally, Humana is bothering me for a 'pay back'  as re: one of my clients as their system did not 'catch' that I continued to be paid at the same rate as last year for that client.  I advised them that as they had not advised me of the change in rates and that I therefore had no opportunity to decide whether I was going to continue to see the client or not.  I advised them  that I had no intention of paying them back. 



SMC LME Cannot Figure Out How to Use Main CPT Code for Dually Eligible Clients


Well its week three as associated with Smoky Mountain Center LME being unable to figure out how to do what used to be done automatically before the LME's took over NC Medicaid.  Specifically, the matter is this: 96152, a CPT code known as the 'Health & Behavior' codes, which was put into play by the American Psychological Association in 2000, is billed in 15 minute increments.  It is intended to be the code utilized by a mental health practitioner who is providing overlapping services in conjunction w/ other providers e.g., physicians/ psychiatrists, etc.  

PRIOR to the LME's taking over NC Medicaid, I simply submitted to my biller the following information: 
name of client; CPT code (96152 is NOT a Medicaid code; thus NC Medicaid PRIOR to the LME's understood how to wrap around when the Medicare code, 96152, was assigned); Place of Service; Date of Service.  I did not have to interface AT ALL with NC Medicaid as Medicare and Medicaid were interlinked PRIOR TO THE LME'S TAKING OVER NC MEDICAID.  It was a seamless system.  Now we have bits and pieces laying all over the place.  

Now, not only do I need to submit to my biller information to bill Medicare, but I then have to take my RA's or Remittances which outline what Medicare has paid me, and then submit that to my biller so she can submit to SMC LME that information.  So, now I am charged twice by my biller.  Lose/ lose situation across the board for me. 

Under Medicare, since 1.1.2013, Place of Service is no longer required, thankfully.  This frees me up to see patients while they are in psychiatric hospitals, etc.  This was an advance.  

Will no one rid us of this troublesome mess? Does anyone know how this is fixable?