Implantable Medical Device Credit Reporting for 2023 – What You Need to Know

Implantable medical device credits, a favorite target area for the OIG and RACs, ZPICs, CERT and the individual MACs, continue to be an area of potential risk for providers and an easy mark for federal auditors. Ongoing scrutiny only promises to intensify as auditing entities have laid plans to continue to target this error-filled area in 2023.

With the ever-expanding list of implantable devices, the chance for mistakes, oversights and inappropriate billing associated with device credits is greater than ever. Add to this, the “seesawing” of the CMS “Inpatient-only List” with hundreds of procedures being dropped and then added back, has led to confusion when those procedures include devices needing to be monitored, tracked, and reported by different operational teams. Recently expanded OIG audits for device credits are also targeting APC outlier payments directly related to reported device credits and Value Code “FD,” resulting in large repayment provider obligations.

Michael G. Calahan, PA, MBA, Certified Compliance Officer, will teach you how to identify, track and manage these credits, how to report them correctly, and how to implement steps for avoiding errors. He will discuss how to avoid the newly extended area of OIG focus, the APC outlier payments directly related to reported device credits and Value Code “FD” and cover the lesser-known clinical scenario of implantable medical device credits with initially-placed implantable devices (usually during clinical trials) and the mandated Condition Code 53, and ultimately empower you to take steps to prevent repayments and fines.

Why This Is Relevant:

Auditors of all kinds view the reporting of implantable device credits as low-hanging fruit. Heading into 2023 they are planning to continue efforts to rectify improper payments. In addition, they’ll be aggressively pursuing the recoupment of inappropriate outlier payments for outpatient device procedures. It’s imperative to make sure your organization is fully complying with all CMS requirements and following best practices for device credit reporting.

Learning Objectives:

• Identify which devices get reported when a credit is received and how to correctly report credits in the hospital inpatient, outpatient, and ASC settings
• Learn up-to-date 2023 rules & regulations in effect as well as Medicare Program changes for mandatory implantable medical device credit reporting
• Recognize little-known issues the OIG is targeting in 2023
• Understand the rules for newly implanted (not replacement) devices, which device credits are reported in this category, and the proper way to report CC-53
• Learn how to perform due-diligence reviews for outpatient device procedures that result in outlier payments
• Gain a “how-to” for ASC reporting, including device credit modifiers, targeted devices, and common errors
• Learn best practices and workflow processes, including authoring and refining policies and procedures for device credit reporting

Who Should Attend:

C-suite executives; HIM directors, coding managers, staff and billers; revenue cycle personnel, including directors, managers and billers; revenue integrity analysts; compliance officers and specialists; auditors; operating room directors and managers; cardiac cath lab and invasive cardiology directors and managers; vascular lab directors and managers; interventional radiology directors and managers; neurosurgical personnel; and ASC directors.