CMS Delays JW Modifier and Tells QIOs to Re-Review Denials

Operational issues recognized

jw modifier

Interpretations galore, hopefully the latest round of “education” will make a difference.

A representative of CMS stated that the July 1 2016 deadline for required use of the JW Modifier to report drug wastage is being moved to January 1 2017, on an Open Door Forum Conference Call, today. A transmittal is forthcoming to confirm the change, they also stated.

Find relevant audio clips, below, as well as a recording of the complete call.

Providers are cautioned that while the statements are clear and unambiguous, CMS does not consider these calls to be “on the record” and hence should not be taken as official language. Indeed, any answer or ruling from CMS, its representatives or contractors should be absolutely confirmed in writing, hopefully in answer to a direct question.

QIOs Must Now Re-Review All Submitted Denials

bfcc-qio

CMS appears to have learned from the RAC program: don’t start the clock before you’re sure it won’t blow up in your face.

Presumably in an effort to reduce the number of improper denials and unnecessary appeals caused by the confusion, and to avoid another ticking time-bomb ala the appeals backlog at OMHA, CMS has instructed both the BFCC-QIOs to revisit all the denials they have issued since the beginning of this program on October 1, 2015. The call today included a description of how CMS wants to handle existing appeals, and hopefully, there will be more transmittals forthcoming to provider proper guidance.

CMS also posted a new flow-chart, in their effort to provide consistent guidance for contractors and providers alike. Hats off to them for fitting it onto a single page. It is not difficult to follow and will hopefully be a help to all parties.

Policy Decision Guideline - CMS Draft dated 05.20.2016

Below are audio clips of the relevant statements by CMS, and a recording of the complete call.

Audio Clips of Important Points

Complete Recording

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