Every Spring and Fall I reorganize my closet.  Although I do get some satisfaction from the chore it doesn’t change the content of the closet. It is the same stuff I had in there the last time this season rolled around. It just makes it feel new and easier to find things. Next time I am ready to reorganize my closet; I am going to have CMS do it. That way not only will it be all new and easier to find things, I think it might very well have new things in there that were never there before.

On January 31, 2013 CMS published an MLN Matters article about CR 7824. It was titled merely “Reorganization of Chapter 13”. By Chapter 13, CMS was referring to the Medicare Benefits Policy Manual for RHCs and FQHCs. This is our bible for Medicare billing in an FQHC. In the “What you need to know” section this article simply stated;

This article is based on Change Request (CR) 7824, which updates and reorganizes Chapter 13 of the “Medicare Benefit Policy Manual.” a.k.a. MBPM. This chapter deals with Medicare RHCs and FQHCs. Chapter 13 is reorganized for easier use and updated to include more comprehensive information. There are no new policies contained in the manual.

I have added the bold font to the last sentence. When I read this, as I read all the MLN Matters articles, I said to myself, “this is great, I love reorganization”….a little Sheldon Cooper-like but still true.   Then I read the newly reorganized chapter.

While it is reorganized, CMS has reused numbering for completely different topics. Section 40.1 was always one of my most used sections. Previously, 40.1 defined FQHC Primary Preventive Services. The new 40.1 describes the locations in which an FQHC visit may occur. The publications do not give any roadmap about where to find the information previously in 40.1. So I went on a scavenger hunt.

I found what I was looking for in the newly minted section 210.2.1 – Preventive Health Services in an FQHC; General. When I compared the sections, I got confused. Section 40.1 (in the previous manual) stated in part (bold emphasis added by me):

The following preventive primary services may be covered and billed to the intermediary when provided by FQHCs to Medicare beneficiaries:

● Medical social services;

● Nutritional assessment and referral;

● Preventive health education;

● Children’s eye and ear examinations;

● Prenatal and post-partum care;

● Prenatal services;

● Well child care, including periodic screening;

● Immunizations, including tetanus-diphtheria booster and influenza vaccine;

The new 210.2.1 section states:

FQHCs must provide preventive health services on site or by arrangement with another provider. These services must be furnished by or under the direct supervision of a physician, NP, PA, CNM, CP, or CSW. Other services that must be provided directly by an FQHC or by arrangement with another provider include: preventive dental services, mental health and substance abuse services , transportation services necessary for adequate patient care, hospital and specialty care.

Section 330(b)(1)(A)(i)(III) of the Public Health Service (PHS) Act required preventive health services can be found at http://bphc.hrsa.gov/policiesregulations/legislation/index.html, and include:

• prenatal and perinatal services;

• appropriate cancer screening;

• well-child services;

• immunizations against vaccine-preventable diseases;

• screenings for elevated blood lead levels, communicable diseases, and cholesterol;

• pediatric eye, ear, and dental screenings to determine the need for vision and hearing correction and dental care;

• voluntary family planning services; and

• preventive dental services.

NOTE: The cost of providing these services may be included in the FQHC cost report but they do not by themselves constitute a billable visit.

Do you understand my confusion? By way of an example, previously Preventive Well Child Care, including periodic screening when performed in an FQHC was billed to the intermediary (Part A). Now this manual states that although we are required to provide “well-child services” they do not constitute a billable visit. These are services provided by a core provider, usually an MD but sometimes an NP. Yet they are not billable visits? These statements are contradictory to each other. I needed help. We sent a question to CMS regarding the changes in the MBPM. The reply was “What exactly do think has changed?” Yikes. I guess we need to be more specific with our questions. This will take some more conversations with CMS. We will keep you posted about our progress with this new manual.

But in the meantime, my closet needs some “reorganization”, I could use some new shoes for spring.