Q: Is QMS prepared to meet the various regulatory changes that are coming in 2012?

A: Yes we are ready for all new regulatory changes effective 1/1/2012 . We are also ready to support your staff to ensure that you will have the most complete and up to date tools in the industry that are fully compliant with new regulations and provide our clients with a highly competitive system in the ever changing renal marketplace.

Q: What's the latest on CROWNWeb?

A: QMS is committed to enabling QCS clients to electronically submit their CROWNWeb data to CMS. Historically CMS has promoted manual entry by ESRD provider, effectively putting an enormous burden on clinical staff. QMS is working closely with the National Renal Administrators Association (NRAA) contractor who is spearheading the use of a Health Information Exchange (HIE) for electronic submission of these data. This methodology will eliminate both manual entry and extra staff involvement because data will flow directly from QCS to CROWNWeb. The hope is that with the HIE implemented and tested CMS will de-emphasize their manual entry approach.

Q: Do you have an update on the Quality Incentive Program (QIP)? What do I need to know?

A: QMS is ready for the QIP changes that will take effect in 2012.

QMS Focus has been fully modified for the reimbursement changes to be launched in 2012. These capabilities were discussed at the 2011 QMS Users' Meeting in October. January 2012 is the initiation point for reduced payment to providers based on quality indicators. These quality indicators – two monitoring correction of anemia based on hemoglobin (Hgb) values; one dialytic adequacy (currently URR) – have been evaluated based on 2010 performance values and clinics have been given their “scores” and expected payment reduction for 2012. The maximum amount of reduction is 2%. (This program does not provide for incentives in the form of increased payments for maximum scores.) With individual clinic scores entered into QMS Focus accurate AR projections will be made for submitted claims and accurate expected collection amounts will be displayed.

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Q: Will QMS be ready for 5010?

A: We are ready and compliant for the 5010, effective March 31, 2012 .

Testing has been completed for all MACs that have allowed testing to date. This 5010 vendor testing started in April 2011 and initial testing finalized as of October, 2011. Version 7.1.05 was released in July, 2011 for client testing to begin. We continue to vendor test as we are informed of new edits, such as a recent notification from Cahaba requesting treatment item description for procedure codes listed as Not Otherwise Classified (NOC) Unlisted; Unspecified; Unclassified; Miscellaneous; Prescription Drug, Generic; or Prescription Drug, Brand Name.

CMS is underway with implementation activities to convert from Health Insurance Portability and Accountability Act (HIPAA) Accredited Standards Committee (ASC) X12 version 4010A1 to ASC X12 version 5010A1; and National Council for Prescription Drug Programs (NCPDP) version 5.1 to NCPDP version D.0. The ASC X12 version 5010 format includes structural and content oriented changes. These changes incorporate more than 500 requests and provide more consistency across transactions by requiring more specific requirements of transmitted data. The updated format also allows for upcoming implementation of the ICD-10 code sets.

This change will affect suppliers/providers, health plans, clearinghouses, billing services, and software vendors.

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Q: What is QMS doing to address ICD-10 changes?

A: We are currently in the design phase of the ICD-10 project that is effective October 1, 2013 . As this date approaches (still 22 months into the future) and we have more information available, we will pass it along to the clients.

It is important to understand that changes from ICD-9 (currently used diagnoses) to ICD-10 are unlikely to be an automated process because one ICD-9 would be expected to translate to a number of ICD-10s. Consequently, providers will have to evaluate their diagnoses to populate QMS Focus and QCS with new, appropriate ICD-10s to accurately reflect justification for clinical actions. Also, the change to ICD-10s is a HHS mandate and will have to be followed by all payors. Finally, QMS systems will retain both ICD-9s and ICD-10s as long as ICD-9s are actively used by any payor; they will also be retained in affected versions of our software for the possible need of having the correct diagnoses for claim regeneration for different service periods. ICD-9s will also be retained for archive requirements.

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Q What is CR7460? Is QMS ready for these changes?

A: We are fully prepared and ready for these changes.

One of the regulations changes the reporting requirement for KT/V for patients prescribed with more than 3 hemodialysis treatments per week. A value of 8.88 shall be entered on the claim if the situation exists that a patient is prescribed and receiving more than three hemodialysis treatments per week for a medically justified and documented clinical need. The 8.88 value is not to be used for patients who are receiving “extra” treatments for a temporary clinical need (e.g., fluid overload).

Another change is the reporting requirement for access modifier. Modifier V5 must be entered if a catheter is present even if it is not being used for the delivery of hemodialysis. In this instance 2 modifiers should be entered, V5 (Any Vascular Catheter (alone or with any other vascular access) for the vascular catheter and either V6 (Arteriovenous Graft (or other Vascular Access not including a vascular catheter in use with two needles) or V7 (Arteriovenous Fistula Only (in use with two needles) for the access that is being used for the delivery of hemodialysis

Lastly, CMS requires the submission of the most recent hemoglobin or hematocrit lab value taken prior to the start of the billing period on all ESRD claims irrespective of ESA administration. If a hemoglobin or hematocrit value is not available the value 99.99 shall be entered.

Still Have Questions?

QMS hopes that the above information is useful as you address the future. We would like to remind you not to hesitate to contact us if you have any questions or concerns. We can be reached at 1-800-752-4600 or you can e-mail us at qms@qms-us.com.

Also, we would like to wish everyone a Happy Thanksgiving!