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For
example, Louisiana was the first state to publish a policy,
with a requirement for Medicare Part B studies that became effective
on January 1, 1998 requiring the RVT or RVS credentials for
laboratory personnel or ICAVL laboratory accreditation. Since
that time, the ICAVL is aware of implementation of similar policies
by 32 other states, one region (Washington, DC) and one territory
(Puerto Rico). These include a recommendation, rather than a
requirement, set forth by Noridian Mutual Insurance Company,
the carrier for Arizona, Alaska, Colorado, Hawaii, Nevada, North
Dakota, Oregon, South Dakota and Wyoming. The most recent payment
policy, which will become effective June 6, 2002 for Medicare
Part B studies in Illinois and Michigan, was announced by the
carrier, Wisconsin Physicians Service, in November 2001. Because
of this particularly short implementation time, the ICAVL, as
a service to the vascular community, sent a mailing to vascular
laboratories in the ICAVL database and to credentialed technologists
and sonographers alerting them to this new policy and providing
a link to the carrier’s Web site where the payment policy
is published.
THE
BIG QUESTION: PART A OR PART B
While
the majority of the policies described above are in effect for
Medicare Part B, the ICAVL is also aware of a limited number
of policies for Part A. When determining whether the noninvasive
vascular studies performed in your laboratory are impacted by
a specific policy, the fact that the study is performed in a
hospital does not necessarily mean the entire study is billed
to Part A. Part A usually covers the technical component of
studies performed in hospitals while Part B covers the professional
component—the interpretation. In general, studies performed
in private offices and clinics are reimbursed entirely under
Part B, however, this information should also be confirmed with
laboratory administrators to determine whether the studies performed
by your laboratory are impacted by a specific payment policy.
HOW
ARE MEDICARE REIMBURSEMENT POLICIES ENFORCED?
Medicare
payment policies are enforced through post-payment audits. This
means that at any time after a policy’s implementation
date, an audit can be conducted by Medicare to ensure compliance.
This includes audits brought about by a complaint regarding
compliance from employees, past or present, competitors or patients.
Laboratory records, including log books, are reviewed to ascertain
compliance. Providers found to be noncompliant with payment
policies must repay the provider for past claims and are often
assessed a penalty for each past claim.
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