Thursday, May 19, 2022

Responsed To: Paperwork for Medicare Secondary????

Melissa A. Bolton, Admin. Dept.

Here are the responses I received — thanks everyone:

1. We follow the CMS standard across the board at our office regardless of
insurance Company for consistency and continuity in information and document
gathering. We call it CYA- it is easier than trying to remember which patient
is which and who requires what.

2. We just received a RAC audit on a 2010 claim for a patient who had Medicare
as secondary. The review came back as “no further action required” when I sent
physician and practitioner notes justifying the need ( no k level noted in
physician file). I’d recommend following their doc requirements, especially for
codes that require a K3.

3. I feel it is better not to assume. Use and follow only the directions the
individual insurance company requires. Excess materials will confuse them.

4. We’ve received K3 prepayment reviews on Medicare secondary claims – we had
good medical docs and were paid.
So I’d recommend documentation on all Medicare beneficiaries, no matter what
level payer Medicare is.

5. Medicare policies are the same irregardless of the sequence of payers. If
you are billing Medicare for a service, then you must meet the documentation
requirements whether Medicare is primary or secondary. For services which
require a KX for payment, you cannot include the KX if you have not met the
documentation requirements and when you omit the KX your claim will be denied.

6. We were subjected to a pre-payment audit on a patient who had Medicare
Secondary. The same rules applied and we had to sent in the same amount of
paperwork to get paid.

7. I recommend that you treat EVERY amputee like a Medicare patient, requiring
the documentation, physician notes, etc.
before providing the services or devices.

8. We received a pre-payment audit on a K2 patient with Medicare secondary so
now we are meeting documentation standards on all Medicare, Medicare HMOs,
Medicaid, and Medicaid HMOs whether they are primary or secondary.

9. Saying that it does not stipulate either way is actually not correct.
Medicare’s documentation requirements apply to any claim made with them, even
as secondary. It is true that it does not specifically say that they are still
required if Medicare is secondary, secondary is still a claim on the coverage.
The only differences are that you are far less likely to get audited when
Medicare is the secondary, and even if you did, and did not have the necessary
documentation, you are out a lot less money.

10. If the primary isn’t paying 100% of the claim, and if you use the KX
modifier and you filed the claim with medicare, then you must have the
documentation because you stipulated with the “KX” that you had it. If you put
the KX on there and you don’t have it, you will lose the payment and possibly be
accused of fraud. If the primary payer is covering 100% of the claim, then you
don’t have to worry about medicare’s requirements.
Our classes on business principals (they get CEU’s) are soon to be
on Many good suggestions and practices are in the
classes, if the practitioners need CEU’s. For your department, aopa offers
classes in billing practices that have a great reputation for being very useful.

11. As far as I know Medicare secondary is the same as Medicare primary. We
treat them the same.

12. We have been audited for Medicare secondary, so we now treat them all the
same. And sometimes, Medicare becomes primary & no one tells you!

13. We follow Medicare guidelines with even private payers, getting all
documentation, etc. We treat every insurance as if they were Medicare now. The
more documentation, the better!

14. Follow the same rules as if Medicare was parimary. Already been audited
on Medicare secondary payor.

15. In the case that Medicare is secondary for any of our patients, we do still
require the same documentation because regardless of whether Medicare is primary
or not, their policy guidelines apply the same to the coverage of products.
We’ve been audited several times where Medicare was not the primary payer and
we were still required to provide the detailed documentation that the LCDs &
NCDs outline. I definitely think that it’s better to be safe than sorry, even
in the case of Medicare secondary payments. The primary insurance documentation
requirements never trump the Medicare requirements according to our experiences.

> On April 11, 2013 at 2:28 PM “Melissa A. Bolton, Admin. Dept.”
> wrote:
> Hey Everyone,
> How is everyone handling the documentation requirements when Medicare is
> Secondary Payer? Are you still requiring all of the copious amounts of
> documentation or are you assuming since another insurance such as BCBS is
> primary, you follow their documentation standards and Medicare’s don’t apply?
> We have had multiple discussions in our office and I can’t find anything that
> stipulates either way so we thought we would see what others are doing.
> Thanks!
> Melissa Bolton
> Funding Assistant


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