Review and Update Non-Monetary Compensation
Laboratories need to review and update many compliance issues at the beginning of each calendar year. Often overlooked is the update to the amount allowed under the Stark non-monetary compensation and medical staff incidental benefits provisions. Non-monetary compensation includes items such as gifts, entertainment, dinners, in-office luncheons etc. — anything but cash or cash equivalents […]
Laboratories need to review and update many compliance issues at the beginning of each calendar year. Often overlooked is the update to the amount allowed under the Stark non-monetary compensation and medical staff incidental benefits provisions. Non-monetary compensation includes items such as gifts, entertainment, dinners, in-office luncheons etc. -- anything but cash or cash equivalents such as gift cards. Medical staff incidental benefits include meals, parking and other items that are used while the physician is on the hospital's campus. The allowed amount is updated annually to reflect changes in the Consumer Price Index-Urban (CPI-U) which was +1.7 percent for the fiscal year ending Sept. 30, 2014. The result of the annual update is $392 for non-monetary compensation and less than $33 per occurrence for the medical staff incidentals. Laboratories should have a tool or tracking system to monitor the money spent on non-monetary items they have provided during the calendar year, particularly if they give a lot of gifts or they are a department of the hospital and must share the allowance with other hospital departments. For more information, see the Federal regulations at 42 CFR 411.357. Congressman Eric Paulsen (R–MN) Introduces Medical Device Tax Repeal: A bill titled Protect Medical Innovation Act of 2015 introduced in the House of Representatives on Jan. 6 would repeal a medical device tax. The bill is similar to a 2013 bill that died in the Democrat-controlled Senate. The tax, enacted by the Health Care and Education Reconciliation Act of 2010, took effect Jan. 1, 2013, and imposes a 2.3 percent excise tax on the sale of certain "taxable medical devices." Taxable medical devices are defined as any devices that are intended for humans. Excluded items would include devices such as eyeglasses, contact lenses, hearing aids, and medical devices generally purchased by the general public at retail for individual use. The bill to repeal that tax has received support from more than 250 co-sponsors including 17 Democrats. Repeal of the tax is a legislative priority for Republicans. Laboratories are unlikely to see any benefit from the repeal of the tax, however, because device manufacturers are not expected to pass any savings on to their customers. CMS Transmittal Updates Reason and Remark Codes: Program transmittal R3161CP, Change Request 9004, updates the Claims Adjustment Reason Code (CARC) and Remittance Advice Remark Code (RARC) lists. Reason and remark codes must be used along with a group code to report payment adjustments and denials and provide information to explain the adjustments or denials to the entity submitting the claim. According to the transmittal, there are seven new CARC codes and two codes with modified narratives. There were no deactivated CARC codes. The RARC list includes six new codes, three codes with modified narratives and two codes that were deactivated. The transmittal has an effective date of April 1. However, effective dates for individual code changes may be different because the lists are updated only three times a year. The Centers for Medicare and Medicaid Services updates its computer software four times a year. Medicare Administrative Contractors are responsible to make sure that the individual codes are not activated until the appropriate date as provided in this transmittal. A complete list of CARC and RARC codes can be found on the Washington Publishing Company website at http://www.wpc-edi.com/.