Bill Finerfrock, Pam Jackson, Zhaneta Mansaku, and Hannah Tuke

Washington Report – April, 2012

HHS Proposes ICD-10 Delay But Wait, There’s More… ACOs – Coming to a Neighborhood Near You Medicare Stable – For Now As goes Massachusetts, So Goes the Nation? CMS suspends controversial ED data collection initiative Bi-Partisan Group of Senators Solicit Ideas on Combating Medicare Fraud Pay For Performance/Value Based Purchasing Initiative Heats Up CMS Transmittals

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HHS Proposes ICD-10 Delay

On April 17th, the Department of Health and Human Services formally recommended that the effective date for mandatory use of the ICD-10 coding system be delayed from October 1, 2013 to October 1, 2014. The Notice of Proposed Rulemaking (NPRM) gives the public 30 days in which to comment on this proposed change. The HBMA ICD-10 Committee, under the leadership of Chair Holly Louie, is in the process of drafting the Association’s response to this proposed change.

HHS Secretary Kathleen Sebelius had previously announced that she intended to seek a delay in the effective date but it was not until the release of the NPRM that the Department announced its formal recommendation.

According to the NPRM, the agency was motivated to seek the change following significant problems within the healthcare provider community with implementation of the 5010 standards. Adoption and implementation of 5010 is an essential component to being able to move to ICD- 10.

Some provider groups, most notably the American Medical Association, have expressed grave concerns about the ability of their members to meet the October 1, 2013 deadline. The announcements states,

“…some provider groups have expressed strong concern about their ability to meet the October 1, 2013 compliance date and the serious claims payment issues that might then ensue. Some providers’ concerns about being able to meet the ICD–10 compliance date are based, in part, on difficulties they have had meeting HHS’ compliance deadline for the adopted Associated Standard Committee’s (ASC) X12 Version 5010 standards (Version 5010) for electronic health care transactions.

Compliance with Version 5010 and ICD–10 by all covered entities is essential to a smooth transition to the updated medical data code sets, as the failure of any one industry segment to achieve compliance would negatively impact all other industry segments and result in returned claims and provider payment delays. We believe the change in the compliance date for ICD–10, as proposed in this rule, would give providers and other covered entities more time to prepare and fully test their systems to ensure a smooth and coordinated transition by all industry segments.”

Ironically, in 2009, when HHS first asked the industry for recommendations on an ICD-10 compliance date, HBMA recommended October 1, 2014.

Once the deadline for submitting comments passes, HHS will review all of the recommendations from the industry and then make a determination on whether to keep October 1, 2014 or change the date to address any additional industry concerns.

In conversations with HHS officials, HBMA has been told that there is no chance the Department will go back to the original October 1, 2013 date. In addition, for a variety of technical reasons, the implementation must be on October 1 in whatever year is chosen. So if, for some reason, HHS concludes that 2014 is not appropriate, the next option would be October 1, 2015.

HHS is expected to announce the new compliance date before the end of August.

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But Wait, There’s More…

Although much of the public and stakeholder attention has been focused on the proposed change in the implementation date for ICD-10, the April 17th NPRM also announced two other proposed policy changes that could have a significant impact on healthcare providers.

CMS announced the proposed standards for creation of a “Health Plan ID” or HPID. This is the health plan equivalent of the National Provider Identifier (NPI) that was adopted several years ago. In addition, CMS also asked for feedback on the idea of creating an “Other Entity ID” or OEID for any entity that had reason to be involved in electronic healthcare transactions that was neither a plan nor a provider. Examples of entities to whom this might apply would be clearinghouses, health plan administrators, vendors, billing companies, etc.

Currently, numerous “entities” beyond health plans and providers are involved in the electronic transaction process, and they are often assigned multiple identifiers that differ in length and format. For example, billing companies often are assigned “submitter numbers” by health plans and there can be tremendous variability on the length and format of these submitter numbers. Presumably the OEID would standardize this process and assign one OEID to a billing company or other entity, eliminating the necessity for maintaining multiple numbers in differing formats.

Similarly, many providers and billing companies have expressed frustration with the multiple identifiers they must use to identify the appropriate health plan. According to the Center for Medicare and Medicaid Services (CMS), there has been a general view that the lack of standard identifiers for health plans has led to various problems, such as: “improper routing of transactions; rejected transactions due to insurance identification errors; difficulty in determining patient eligibility; and, challenges resulting from errors in identifying the correct health plan during claims processing.”

CMS believes that the adoption of both the HPID and the OEID will increase standardization within HIPAA standard transactions and provide a platform for other regulatory and industry initiatives. Further, CMS argues, “… adoption will allow for a higher level of automation for health care provider offices, particularly for provider processing of billing and insurance related tasks, eligibility responses from the health plans, and remittance advice that describes health care claim payments.”

As with the ICD-10 proposed change, the public was given 30 days to comment on both the HPID and OEID initiatives. HBMA will be submitting formal comments on both the HPID and OEID proposals.

The original HIPAA law mandated the creation of both an NPI and an HPID, however, the law did not mandate creation of an OEID.

HHS believes the OEID can serve as an identifier for entities that are not health plans, health care providers, or ‘‘individuals’’ that need to be identified in standard electronic transactions. If this proposal is adopted as drafted, health plans will be required to obtain an ID, however, “other entities” will not be required to obtain an ID.

According to the NPRM, HHS believes that, “The most significant benefit of the HPID and the OEID is that they will increase standardization within HIPAA standard transactions by establishing uniform identifiers.”

Due to the relative infancy of the OEID concept, CMS is seeking more of an industry reaction to this idea because this initiative has not been fully developed. Whereas the HPID is not a new proposal in terms of the concept, the proposed implementation/assignment criteria are fairly well developed.

One of the key questions about the HPID has been at what level of granularity would a plan be required to be identified: Corporate/parent company level (Aetna, United, BCB, etc.); the Plan Level (i.e. HMO, Indemnity, PPO, etc.); or, the benefit level (Gold, Silver or Platinum plan, etc.). In addition, many employer sponsored plans are administered by insurance companies creating confusion as to who actually owns the plan and to whom claims should be sent. Since HIPAA was enacted in 1996 providers and other stakeholders have offered extensive input to HHS on the appropriate level of health plan enumeration. According to the NPRM, suggestions ranged from requiring health plans to enumerate at the highest level (that is the parent company), to numerating every health plan benefit package (for example ‘‘HMO Gold’’).

Who will use the HPID and When?

HHS proposes two type of Health Plan levels that would require enumeration:

1. A Controlling Health Plan (CHP) 2. A Sub-Health Plan (SHP)

Controlling Health Plan

A Controlling Health Plan is a health plan that controls its own business activities, actions, or policies; or is controlled by an entity that is not a health plan but exercises sufficient control over a sub-health plan(s) to direct its/their business activities, actions, or policies.

The following factors would need to be considered when determining if an entity is a CHP:

A. Does the entity itself meet the definition of a health plan? B. Does either the entity itself or a non health plan organization control the business activities, actions, or policies of the entity?

If the answer to both questions is ``yes,'' then HHS would consider the entity to be a CHP.

Sub-health Plan (SHP)

A SHP would be a health plan whose business activities, actions, or policies are directed by a CHP. In making this determination, the following questions would be asked:

A. Does the entity meet the definition of a health plan? B. Does a CHP direct the activities, actions, or policies of the health plan entity?

If the answer to both questions is ``yes,'' then the entity meets the definition of SHP. HHS proposes that a SHP would not be required to obtain an HPID, but may choose to obtain an HPID, or its CHP may obtain an HPID on its behalf.

In the NPRM, HHS proposes HPID usage requirements for all covered entities. They propose that all covered entities use an HPID wherever a covered entity identifies a health plan in a covered transaction. Covered entities would obtain the HPIDs of health plans from the health plans themselves or from the Enumeration System which will be established under this initiative.

If, for example, a physician or group practice uses a billing company to conduct standard transactions the physician/group must require that its billing company use an HPID in each field where the billing company identifies a health plan. The HPID may also be used for any other lawful purpose that requires the identification of health plans. Below are some examples of possible uses for the HPID:

* A health plan may use an HPID on a health insurance card. * Health care clearinghouses may use HPIDs in their internal files to create and process standard and non-standard transactions, and in communications with health plans and health care providers. * HPIDs may be used in patient medical records to help specify patients' health care benefit package(s). * HPIDs may be used to identify health plans in electronic health records (EHRs).. * HPIDs may be used to identify health plans in Federal and State health insurance exchanges. * HPIDs may be used to identify health plans for public health data reporting purposes.

CHPs could obtain HPIDs from the Enumeration System on behalf of their SHPs or direct their SHPs to obtain HPIDs directly from the Enumeration System. Any SHP would be eligible to obtain an HPID regardless of whether or not its CHP directs it to obtain an HPID. A CHP could only obtain one HPID for itself.

Each health plan would be required to disclose its HPID to any entity, upon request, that needs the HPID to identify that health plan in a standard transaction.

The public comment period on both the OEID and HPID initiatives ends on May 17th.

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ACOs – Coming to a Neighborhood Near You

CMS has announced the approval of the first Medicare Accountable Care Organizations (ACOs). According to a press release announcing the newly minted ACOs, over 1.1 Million Medicare beneficiaries will be served by these ACOs. The 27 organizations approved in this round join the 32 “Pioneer Model” ACOs approved in December, 2011.

CMS believes that these organizations, “will help physicians, hospitals, and other healthcare providers work together to improve care for people with Medicare.” These organizations have agreed to take greater clinical and financial responsibility for the care furnished to the Medicare beneficiaries that have been “assigned” to these ACOs.

Acting CMS Administrator Marilyn Tavenner said this as part of the announcement, "We are encouraged by this strong start and confident that by the end of this year, we will have a robust program in place, benefiting millions of seniors and people with disabilities across the country."

The ACO/Shared Savings Program was created by the Affordable Care Act. The ACOs approved in this round include more than 10,000 physicians, 10 hospitals, and 13 smaller physician-driven organizations. CMS is reviewing more than 150 applications for ACO status and expects to make decisions on these applications by the end of July.

Participation in an ACO is purely voluntary for providers and beneficiaries and people with Medicare retain their current ability to seek treatment from any provider they wish.

The organizations approved during this round and the areas they serve are:

Name of ACO Service Area Accountable Care Coalition of Caldwell County Lenoir, NC Accountable Care Coalition of Coastal Georgia Ormond, FL (Serving parts of GA and SC) Accountable Care Coalition of Eastern North Carolina New Bern, NC Accountable Care Coalition of Greater Athens Georgia Athens, GA Accountable Care Coalition of Mount Kisco Mount Kisco, NY Accountable Care Coalition of the Mississippi Gulf Coast Serving the Mississippi Gulf Coast area Accountable Care Coalition of the North Country Canton, NY Accountable Care Coalition of Southeast Wisconsin Milwaukee, WI Accountable Care Coalition of Texas Houston, TX AHS ACO Morristown, NJ (Serving parts of NJ and PA) AppleCare Medical ACO Buena Park, CA Arizona Connected Care Tucson, AZ Chinese Community Accountable Care Organization New York, NY

CIPA Western New York IPA doing business as Catholic Buffalo, NY Medical Partners Coastal Carolina Quality Care, New Bern, NC Crystal Run Healthcare ACO Middletown, NY (Serving parts of NY and PA) Florida Physicians Trust Winter Park, FL Hackensack Physician-Hospital Alliance ACO Hackensack, NJ (Serving parts of NJ and NY) Jackson Purchase Medical Associates Paducah, KY Jordan Community ACO Plymouth, MA North Country ACO Littleton, NH (Serving parts of NH and VT) Optimus Healthcare Partners Summit, NJ Physicians of Cape Cod ACO Hyannis, MA Premier ACO Physician Network Lakewood, CA

Primary Partners Clermont, FL RGV ACO Health Providers, Donna, TX West Florida ACO Trinity, FL Return To Top

Medicare Stable – For Now

On April 23rd, the Medicare Trustees released their annual report on the financial status of the Hospital Insurance (HI) Trust Fund. According to their report, the Trust Fund “is expected to remain solvent until 2024, but action is needed to secure its long-term future.”

The Medicare Trustees are:

Treasury Secretary Timothy F. Geithner Health and Human Services Secretary Kathleen Sebelius Labor Secretary Hilda L. Solis Social Security Commissioner Michael J. Astrue Charles P. Blahous III – Public Trustee Robert D. Reischauer – Public Trustee

The four government Trustees serve by virtue of the titles they hold in the federal government. These Trustees change when the occupant of the office changes.

The public trustees are appointed by the President and are subject to confirmation by the Senate. Both Blahous and Reischauer began serving on September 17, 2010. Acting CMS Administrator Marilyn Tavenner is a non-voting Board member and is designated as Secretary of the Board.

In releasing the report, Tavenner said, “The Trustees Report tells us that while Medicare is stable for now, we have a lot of work ahead of us to guarantee its future.” “The Affordable Care Act is giving CMS the ability to do this work, with tools to lower costs, fight fraud, and change incentives so that Medicare pays for coordinated, quality care and not the number of services.”

Unlike the Part A Trust Fund which relies exclusively on beneficiary/employer premiums to finance the Part A benefits, Part B funds come from a combination of beneficiary premiums and funding from the general treasury of the federal government.

The report projects that the Supplementary Medical Insurance (SMI) Trust Fund (Part B) is financially balanced. However this conclusion is based upon the assumption that Congress can and will authorize general revenue spending necessary to cover the shortfall between beneficiary premiums and the cost of the program. Or, failing to authorize the necessary funds, Congress would change the program to reduce provider payments sufficient to close any funding gap.

According to the report, HI (Part A) expenditures have exceeded income every year since 2008 and are projected to continue doing so well into the future. Interest earned on unspent Trust Fund deposits and asset redemptions (cashing on Treasury Bonds) will be required to cover the shortfall. The report indicates that the HI assets (reserves) will be depleted in 2024. If asset depletion were to occur and Congress took no action to prevent a shortfall, the Trustees project that the Part A Trust Fund revenue would only have sufficient funds to cover 87 percent of expected expenditures in 2024. In an effort to quell any fear these projections may have on the Medicare population (or those nearing Medicare eligibility) the Trustees point out that Congress has never allowed the Medicare trust fund to exhaust its assets. But as they say in the investment world - past performance is no guarantee of future returns.

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As goes Massachusetts, So Goes the Nation?

The Healthcare reform legislation adopted by Massachusetts back in 2006 is often cited as the model for the federal healthcare reform legislation adopted by the Congress and promoted by President Obama in 2010. With the ascension of former Massachusetts Governor Mitt Romney (the Governor at the time the legislation was enacted) as the presumptive GOP Presidential nominee the comparisons between “Obamacare” and “Romneycare” will continue for the next several months.

But the Massachusetts legislature appears on the verge of enacting Phase II of the Massachusetts healthcare reform legislation and many are wondering whether this next phase portends future federal action in the healthcare arena?

The landmark healthcare reform legislation enacted in 2006, mandates that nearly every resident of Massachusetts obtain a state-government-regulated minimum level of healthcare insurance coverage and provides free health care insurance for residents earning less than 150% of the federal poverty level who are not eligible for Medicaid. While the legislation had the desire effect of significantly increasing the number of individuals in Massachusetts with health insurance (latest estimates are 97% insured) the legislation did nothing to tackle rising healthcare costs. And since the Massachusetts legislation was enacted, the cost of healthcare in Massachusetts has risen faster than the national average.

Now, in Phase II, the Governor is proposing changes in the way healthcare is paid for as a means of trying to control costs. Under a plan being promoted by current Massachusetts Governor Deval Patrick (D-MA), fee-for-service payments for healthcare would be outlawed and instead, providers would be compensated using a “global payment” system that would bundle outpatient payments.

Earlier this year, in preparation for this move to bundled payments, the Massachusetts Division of Health Care Finance and Policy released the first in a series of technical assistance reports that are intended to, “assist providers and payers seeking to develop bundled payment programs.”

The federal government has announced a series of “demonstration” projects to test the idea of bundled payments as an alternative to fee-for-service. To date no legislation has been considered to mandate the use of bundled payments at the federal level. Return To Top

CMS suspends controversial ED data collection initiative

On April 2nd, the Centers for Medicare and Medicaid Services (CMS) announced it was suspending a project it established to collect certain quality data from Emergency Departments throughout the United States.

OP-19, the Transition Record with Specified Elements Received by Discharged Patients for the Hospital Outpatient Quality Reporting (Hospital OQR) Program was adopted for the CY 2013 payment determinations with data collection beginning with January 1, 2012 encounters. However, almost from its inception, the program encountered problems.

According to the memo announcing the suspension, CMS officials stated, “Since data collection for this measure began, concerns have been raised about the current measure specifications, including potential privacy concerns.” After careful consideration of these issues and after review of the measure specifications, CMS decided to suspend public reporting and validation of hospital- reported data for OP-19 until further notice.

The memo went on to state that CMS will neither publicly report nor validate these data until all concerns are resolved and measure specifications refined as necessary.

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Bi-Partisan Group of Senators Solicit Ideas on Combating Medicare Fraud

A bi-partisan group of Senators sent a letter to “Members of the Healthcare Community” soliciting ideas and suggestions for how to combat Medicare fraud. In the letter, the Senators cite a recent General Accounting Office (GAO) report estimating that Medicare fraud amounts to anywhere from $20 Billion to $100 Billion annually.

The Senators are seeking input from the healthcare community because, “we believe federal efforts would be strengthened by input from members across the healthcare community. Drawing on the collective wisdom and accumulated insights of thousands of professionals and individual experiences could offer a fresh perspective and potentially identify solutions that may have been overlooked or underutilized.”

The general areas in which they seek input are:

 Program Integrity Reforms to Protect Beneficiaries and Prevent Fraud and Abuse  Payment Integrity Reforms to ensure Accuracy, Efficiency and Value  Fraud and Abuse Enforcement Reforms to Ensure Tougher Penalties Against Those who Commit Fraud.

HBMA is in the process of organizing a workgroup to determine whether the organization will develop a “Combating Medicare Fraud” White Paper in response to the request. The Senators who are participating in this initiative are:

Max Baucus (D-MT) Orin Hatch (R-UT) Ron Wyden (D-OR) Tom Coburn (R-OK) Tom Carper (D-DE) Chuck Grassley (R-IA)

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Pay For Performance/Value Based Purchasing Initiative Heats Up

Thousands of physicians received a sneak-peek at their future recently when CMS sent them quality reporting data that could be used to determine Medicare payments.

Each physician received a report titled, “Confidential 2010 Quality And Resource Use Report Medicare Fee-For-Service” from Medicare providing information about the quality of care provided to Medicare fee-for-service (FFS) patients he/she treated in 2010; the amount that Medicare paid the provider for that care; and, how the individual provider compared to other Medicare providers within the same specialty.

The report notes that it is for informational purposes only. It does not affect the provider’s Medicare payment or his/her ability to participate in the Medicare Program.

Eventually, CMS intends to send similar reports to every provider who sees Medicare patients. More importantly, the information contained in these reports will be used to determine provider payments in the future.

Physicians in Kansas, Missouri, Iowa and Nebraska received the initial reports. The purpose is to allow these physicians to:

 Highlight the degree of involvement with patients treated by the provider.  Identify possible components of a payment modifier that would be used to establish a “payment differential” based upon quality of care.

In published reports, former CMS Administrator Don Berwick, a strong proponent of this type of value based purchasing, said, “It may be the most difficult measurement challenge in the whole world of value-based purchasing. We do have to be cautious in this case. It could lead to levels of gaming and misunderstanding and incorrect signals to physicians that might not be best for everyone.”

In fact many health policy analysts who agree with the principle of value based purchasing also believe that it may be impossible to actually design a system that is both fair and accurate and that is not subject to provider gaming. Although this particular report is exclusively about care and cost of care relative to Medicare beneficiaries, several private insurers have expressed interest in developing similar reports for providers caring for their commercially insured patients. Return To Top

CMS Transmittals

Centers for Medicare & Medicaid Services uses transmittals to communicate new or changed policies or procedures that will be incorporated into the CMS Online Manual System. The following transmittals were released in the month of April.

Transmittal Subject Effective Date Number

R1079OTN New Occurrence Code to Report Date of Death 2012-10-01 Implementation of the HIPAA Version 5010 276/277 Claim R1066OTN 2012-10-01 Status Edits October 2012 Release Revisions of the Financial Limitation for Outpatient Therapy R2457CP Services – Section 3005 of the Middle Class Tax Relief and Job 2012-10-01 Creation Act of 2012 FISS update for Clinical Laboratory Fee Schedule upload to R1082OTN 2012-10-01 include Kansas Payment Locality Structure Temporary Direction to Accommodate Organ Donor R1083OTN 2012-10-01 Complication Billing on 8371 Claims Part 1, Chapter 14, Reasonable Cost of Therapy and Other R452PR1 N/A Services Furnished by Outside Suppliers New Physician Specialty Code for Sleep Medicine and Sports R209FM 2012-10-01 Medicine Expansion of the Laboratory National Coverage Determination R1071OTN 2012-10-01 (NCD) Edit Software Request to Require Hours for Research and Conference Calls R1070OTN with Maintainers, MACs, and EDCs and Additional 2012-10-01 Requirements for IDR Shared Systems Contractor and Common Working File (CWF) Additional Instructions Related to Change Request (CR) 7633 - Screening R2454CP 2012-10-01 and Behavioral Counseling Interventions in Primary Care to Reduce Alcohol Misuse R2446CP New Influenza Virus Vaccine Code 2012-10-01 American Recovery and Reinvestment Act of 2009 Electronic R1073OTN Health Record (EHR) Incentive Program: Financial Information 2012-10-01 File Transfer Modifications for Eligible Hospitals Fiscal Intermediary Shared System (FISS) System Enhancement for Including Line Level Rendering Physicians/Practitioners R1072OTN 2012-10-01 National Provider Identifier (NPI) and Name Information in the Comprehensive Error Rate Testing (CERT) Resolution Record Health Insurance Portability and Accountability (HIPAA) R1076OTN 2012-10-01 5010/D.0 Fixes - October 2012 R1077OTN Update to the Fiscal Intermediary Shared Systems (FISS) 2012-10-01 Transmittal Subject Effective Date Number Outpatient Provider Specific File (OPSF) for Children’s Hospitals Modification to CWF, FISS, MCS and VMS to Return Submitted R2449CP Beneficiary Information when there is a CWF Name and Health 2012-10-01 Insurance Claim Number (HICN) Mismatch. Hospital Dialysis Services for Patients with and without End R2455CP 2012-10-01 Stage Renal Disease (ESRD) Anesthesiologist Services with a Modifier GC in a Method II R2452CP 2012-10-01 Critical Access Hospital (CAH) CY 2012 OPPS Payment Adjustment for Certain Cancer R2453CP 2012-05-29 Hospitals Fee for Service Common Eligibility Services Conference Calls R1067OTN 2012-10-01 and Research Common Edits and Enhancements Module (CEM) and Receipt, R1084OTN 2012-10-01 Control, and Balancing Updates – October 2012 Health Insurance Portability and Accountability Act (HIPAA) R1064OTN 5010 837 Institutional (837I) Edits and 5010 837 Professional 2012-10-01 (837P) Edits - October 2012 Additional fields added to the Outlier Reconciliation Lump Sum R2447CP 2012-10-01 Utility Ensuring Hospice Certifying Physician Identifiers Are Fully R2448CP 2012-10-01 Processed Addition of a New Common Working File (CWF) Medicare Secondary Payer (MSP) Error Code for CWF to Send the Shared R1065OTN Systems When the Trauma Diagnosis Code on the Claim is Considered a Match with the Family of DX Codes in CWF for Non-Group Health Plan (NGHP) MSP Claims. Section 905.6, Inflation Factor, provides for calendar year (CY) R451PR1 inflation factors to update previous years’ reasonable compensation ranges. Overpayment Recovery from Suppliers of Durable Medical R208FM 2012-05-20 Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) General Update to Chapter 15 of the Program Integrity Manual R415PI 2012-05-14 (PIM) - Part V Implementation of the Award for the Jurisdiction H Part A and Part B Medicare Administrative Contractor (JH A/B MAC) R1060OTN Including New Workload Numbers for Arkansas, Colorado, 2012-07-02 Louisiana, Mississippi, New Mexico, Oklahoma, and Texas as well as for the J4 WPS Legacy Part A Workload General Update to Chapter 15 of the Program Integrity Manual R416PI 2012-02-27 (PIM) - Part III Notice of New Interest Rate for Medicare Overpayments and R207FM 2012-04-18 Underpayments - 3rd Notification for FY 2012 Transmittal Subject Effective Date Number Healthcare Common Procedure Coding System (HCPCS) Codes R2441CP Subject to and Excluded from Clinical Laboratory Improvement 2012-07-02 Amendments (CLIA) Edits Claim Adjustment Reason Code (CARC), Remittance Advice R2442CP Remark Code (RARC), and Medicare Remit Easy Print (MREP) 2012-07-02 and PC Print Update R2443CP Clinical Laboratory Fee Schedule - New Waived Tests 2012-07-02 General Update to Chapter 15 of the Program Integrity Manual R414PI 2012-05-07 (PIM) – Part IV Health Insurance Portability and Accountability Act (HIPAA) R1062OTN 2012-05-07 5010 and D.O Annual Re – Certification Program R2439CP New Waived Tests 2012-07-02 July 2012 Quarterly Average Sales price (ASP) Medicare Part B R2440CP 2012-07-02 Drug Pricing Files and Revisions to Prior Quarterly Pricing Files R17QIO QIO Manual Chapter 5 – “Quality of Care Review” 2012-05-07 Pharmacy Billing for Drugs Provided "Incident To" a Physician R2437CP 2013-01-01 Service. This CR rescinds and fully replaces CR 7109. R2438CP Revised Editing for Hepatitis B Administration Code G0010 2012-07-02