The top takeaway from the CMS January 29 Listening Session on MAC Opportunities to Enhance Provider Experience call focused on stakeholder input on ways CMS and MACs could improve the provider experience, and reduce burdens on the provider.
Call participants pointed to the following as concerns or opportunities for improvement:
- Requiring MACs to work together and create identical policies is extra work and is no longer transparent. Discussions regarding Local Coverage Determinations (LCDs) are no longer held in face-to-face meetings and often, LCDs are written in different jurisdictions and are not always applicable across the board.
- Currently, various MACs have not implemented the October 1, 2019 LCD updates. MAC Customer Service Representatives (CSR) do not know the answers to many questions regarding the LCD updates, or they give contradictory answers.
- There should be more timely update and implementation of LCDs. There are often inconsistent redetermination results, when claims have been appealed.
- Merit-based Incentive Payment Systems (MIPS) payment adjustments are being applied to some codes and not to others.
- It does not always appear that claim reviewers know the coverage policies associated with the claims they are reviewing, but the providers are expected to know the LCD intimately. This often leads to a first level appeal denial, requiring a second level appeal. This creates more work for the providers.
- The Provider Enrollment, Chain, and Ownership System (PECOS) and a few of the MACs Enrollment Departments are not on the same page. When providers add a second location to their profile in the system, there is no button in the system to add a new location.
- Increased accountability of the nurse reviewers who write and review these policies. More transparency in the education the MACs receive would be beneficial because it would allow providers and office staff to learn the same things the MACs are learning for more consistency. A shared dialogue is imperative as we make this transition from Fee-For-Service (FFS) to alternative payment models.
- LCDs sometimes say diagnostic tests must be covered by physicians. However, nurse practitioners (NPs) are allowed to do diagnostic tests based on applicable state and federal law. Please update LCDs with the proper language
This was the third in a series of listening sessions CMS has held to allow providers, specialty societies, office staff, and other stakeholders to offer feedback to improve the provider experience. CMS plans to hold additional listening sessions in the future.