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Each day, we hear from concerned rheumatologists and administrators about issues impacting their practices and how CSRO is working to address those challenges.
This afternoon, CMS alerted CSRO to its newly published transmittal #R12397OTN that makes public the substance of its August 12, 2022, technical direction letter (TDL) language to the Medicare Administrative Contractors (MACs).
CSRO has repeatedly requested that CMS publish the substance of the TDL that directs the MACs to process and pay complex drug administration claims for rheumatologic drugs or to withdraw their “down coding” articles altogether while a long-term solution is identified. Clarification has been requested regarding the implementation date listed in the transmittal, and an update will be sent as soon as a response is received from CMS.
CSRO continues to press CMS for guidance on use of the new complex care add-on code, G2211, that is payable starting January 1, 2024. We know practices want to avoid program integrity audits based on use of the new code, and understand from CMS staff that the Agency is in the midst of working on Medicare Learning Network (MLN) articles and other educational resources to assist with coding and billing, as well as needed medical record documentation.
We understand the challenges related to the Self-Administered Drug (SAD) Exclusion List, and CSRO's request for a by-pass mechanism to ensure these are covered under Part B in key circumstances, will require rulemaking and may take additional time.
Updates will continue to be shared as we receive more information on these issues.
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