Medicare Blog

what is the defintion of medicare pass thru

by Gregory Ortiz Published 2 years ago Updated 1 year ago
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A pass through payment for a drug is Medicare reimbursement paid in addition to an ASC's facility fee, however, CMS

Centers for Medicare and Medicaid Services

The Centers for Medicare & Medicaid Services, previously known as the Health Care Financing Administration, is a federal agency within the United States Department of Health and Human Services that administers the Medicare program and works in partnership with state government…

limits the eligibility for a pass-through payment established under this section to a period of at least 2 years, but not more than 3 years beginning on the date that CMS establishes a category of devices, therefore the pass through status cannot be maintained for over 3-years.

For drugs and biologicals, the pass-through payment is the amount by which 95 percent of the average wholesale price exceeds the applicable fee schedule amount associated with the drug or biological.

Full Answer

Are Medicare payments regulated by federal law?

Regulations implement laws passed by Congress and are published in the Federal Register. There are a variety of regulatory actions, some involving public comment. Although the types of actions can vary, generally CMS publishes a notice of proposed rule-making, solicits and considers public comments, and issues a final rule.

What term explains Medicare payments and denials?

Medicare denial code and Description A group code is a code identifying the general category of payment adjustment. A group code must always be used in conjunction with a claim adjustment reason code to show liability for amounts not covered by Medicare for a claim or service.

What does Medicare mean on my paystub?

What Does Medicare Mean on my Paycheck? When Medicare was enacted as a federal law in 1965, the funds to support the program became a payroll tax on earned income. The payroll taxes required for the Federal Insurance Compensation Act (FICA) are to support both your Social Security and Medicare benefits programs.

What are pass through payments?

Pass-through payment definition. Pass-through payments are amounts paid to Medicaid managed care plans as supplemental payments or “add-ons” to the base capitation rate. The plans are required to pass through the add-on payment to designated contracted providers.

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What is Medicare pass through?

Medicare makes “pass-through” payments under Medicare Part B when hospital outpatient departments use certain new, high-cost drugs. These temporary payments are in addition to Medicare's payments for the procedures using the drugs.

What is a pass through status?

A pass-through status is a business structure that takes away the obligation to pay corporation tax. An entity usually pays tax twice — one for the income generated by the firm's shareholders and another at a corporate level, which is corporation tax.

What is a pass thru code?

Pass Through Code means the issuance by Medicare for BIODExcel or AmnioMatrix of a transitional designation HCPCS C-Code provided for certain “new” drugs, devices and biological agents that were not being paid for as a hospital outpatient department service as of December 31, 1996, and whose cost is “not insignificant” ...

Which drugs have pass through status?

Products qualifying for pass-through status include orphan drugs; drugs and biological agents used to treat cancer; certain new drugs; and, as clarified in the 2018 final OPPS 340B rule, biosimilar drugs.

How do I report a pass through income?

The pass-through deduction is a personal deduction you may take on your Form 1040 whether or not you itemize. It is not an "above the line" deduction on the first page of Form 1040 that reduces your adjusted gross income (AGI). Moreover, the deduction only reduces income taxes, not Social Security or Medicare taxes.

What is the main difference between APC and DRG?

The unit of classification for DRGs is an admission while APCs utilize a visit. The initial variable used in the classification process is the diagnosis for DRGs and the procedure for APCs. Only one DRG is assigned per admission, while APCs assign one or more APCs per visit.

What is the state responsible for?

A6: A state is responsible for ensuring that the approved state plan is fully funded, consistent with the terms and conditions for an approved waiver. A pass-through funding amount higher than estimated may reduce the level of funding required by the state to implement the waiver . States that receive more pass-through funding than estimated must use all federal pass through funds to implement their state waiver plan, or return unused funds to the Treasury. In this situation, a state may not have to use all the state funds it anticipated.

How is section 1332 funding determined?

A2: The pass-through funding amount is determined by the Departments. When applying for a section 1332 waiver and seeking pass-through funding, a state must explain why, under its state plan, the state anticipates that individuals would not qualify for, or would qualify for a reduced amount of, PTC or SBTC for which they would otherwise be eligible. The state must also provide analysis and supporting data to inform the Departments’ estimate of the pass-through funding amount. This may include information about enrollment, premiums and other information as may be required by the Departments. The state’s application must also explain

What is a 1332 waiver?

A1: If a State Relief and Empowerment Waiver (also referred to as a section 1332 waiver or a State Innovation Waiver) eliminates or reduces the amount of premium tax credit (PTC) or small business tax credit (SBTC) that individuals and employers in the state would otherwise receive, the savings are paid from the federal government to the state. This payment is referred to as “federal pass-through funding” or “pass-through funding.” The Centers for Medicare and Medicaid Services (CMS) in the U.S. Department of Health and Human Services (HHS) and the Department of the Treasury (Treasury) (collectively, the Departments) are responsible for calculating the amount of pass-through funding. This calculation currently includes PTC and SBTC, as applicable, provided under the Patient Protection and Affordable Care Act (PPACA) that would have been paid on behalf of participants in the Exchange in the state in the absence of the waiver (referred to as the baseline), but will not be paid as a result of the waiver. This includes any amount of federal financial assistance under the PPACA not paid due to an individual not qualifying for financial assistance or qualifying for a reduced level of financial assistance resulting from a waived provision as a direct result of the waiver plan. The pass-through funding amount does not include any savings other than the reduction in PTC or SBTC. The pass-through funding amount will be reduced to account for any other increase in spending or decrease in revenue to the extent necessary to ensure deficit neutrality.1

When will states receive federal pass through funding?

A9: Generally, states will receive an initial estimate of the federal pass-through funding amount in the fall of each year (before the beginning of the plan year). The initial federal pass-through funding amounts estimated in the fall of each year are informational and may be adjusted by the Departments as necessary to reflect subsequent developments such as changes in Federal or State laws. For example, if a state newly expanded Medicaid, the pass-through funding amount could change. The final federal pass-through funding amount or final administrative determination will be shared in a letter prior to the payment of the pass-through funding amount as provided in the specific terms and conditions of the approval letter (typically before the end of April of the plan year).

Can a state suspend a waiver?

A7: A state may only suspend or request withdrawal of all or portions of a waiver plan consistent with the requirements specified in the Specific Terms and Conditions (STCs) of the waiver approval.

What is the purpose of the FDA Medica provision?

The provision is intended to encourage the use of newly FDA-approved medical devices, drugs, and biologics across all fields of medicine and to boost Medicare patients’ access to these innovative therapies by temporarily paying more than established facility fees.

Does Medicare Part B cover pass through?

For pass-through products used in a hospital setting , CMS reimburses 100% of the cost for Medicare Part B patients , and no copayment applies. When a pass-through drug or device is used in an ASC, however, the statutory 20% copayment does apply, although it is typically covered by a patient’s supplemental insurance.

Is Dextenza a J code?

CMS has included Dextenza on its list of products preliminarily recommended for a dedicated HCPSC J-code, which would become effective January 1, if approved. Among products for which pass-through status has expired is Mitosol (mitomycin 0.2 mg, Mobius Therapeutics).

Is Omidria a pass through drug?

Several ophthalmic products currently have or are expected soon to receive pass-through status: Omidria. For the first time in relation to a new drug, CMS extended pass-through status for this product after it had expired.

Why do states use pass through payments?

Historically, states have used pass-through payments to ensure funding to specific providers who serve a significant number of Medicaid recipients. An example of this is funding safety-net providers, who largely focus on providing care to low-income and uninsured populations.

What is Medicaid managed care?

1. A specific service or benefit provided to a specific enrollee covered under the contract. 2. Permissible provider payment methodologies outlined in §438.6 (c) (1) of the final Medicaid managed care regulations. 3.

What is CMS's conceptual framework?

Under CMS’s conceptual framework, payments to providers should be directly related to services provided to beneficiaries under the contract or value-based payment structures for such services . Further, CMS maintains that managed care plans should maintain the ability and responsibility to utilize the full value of the capitation payment for delivery of services and associated administrative costs.

Does higher mandated reimbursement reduce supplemental payments?

Although higher mandated reimbursement may mitigate the loss of supplemental payments for healthcare providers, a source of funding must also be found. For states that already have provider assessments in place, funding may already be adequate to support mandated minimum reimbursement.

Is Medicaid supplemental payment subject to the new regulations?

Currently, supplemental payments made for Medicaid members under a fee-for-service arrangement with the state are not subject to the new regulations. Therefore, the new regulations do not represent a level playing field and may dis-incentivize the use of managed care. CMS responses to state concerns.

How much does a drug have to be to be eligible for pass through payments?

To be eligible for pass-through payments, a drug’s estimated cost must: Exceed 10% of the ambulatory payment classification (APC) rate. Exceed the portion of the APC rate associated with packaged drugs by at least 25%. In addition, the difference between the estimated cost of the drug and the portion of the APC rate associated with ...

What drugs did the GAO review?

GAO also reviewed four of the drugs (Choline C11, Omidria, the contrast agent Lumason and the skin substitute PuraPly) to discern patterns in utilization based on pass-through status. For three of the four drugs, hospital use decreased when payment was packaged.

What is the GAO for Medicare?

The 2018 federal budget included a provision for the Government Accountability Office (GAO) to review the impact of Medicare’s policy of packaging payment for high-cost drugs with related procedures after their pass-through payment eligibility expires.

What are some examples of factors other than payment structure that affect utilization?

The report notes that factors other than payment structure may affect utilization. Examples include: Hospital formulary processes, especially for new drugs. Specific benefits of the drug for certain populations. Specific challenges of the drug that limit use.

Does Medicare pass through increase APC?

However, the removal of pass-through status might raise the APC payment rate for a drug’s related procedure. The Medicare pass-through payment policy that applies to certain drugs drives higher spending and utilization in the outpatient setting, according to a new report from a U.S. government agency. The 2018 federal budget included ...

Does APC increase after pass through?

APC rates tend to increase after pass-through payments expire. The end of a drug’s pass-through status actually may lead to higher payments in some situations. Namely, associated APC rates tend to go up, in which case Medicare pays more for the procedure when the drug is not used compared with what it paid in that scenario when ...

Does Lumason increase when packaged?

Although use of Lumason increased when payment was packaged, “The financial incentives for that drug appeared minimal because the total payment for it and its related procedure was about the same when it was eligible for pass-through payments and when packaged.”.

What is level 1 CPT?

Level 1 is the American Medical Association’s CPT code set; Level 2 consists of alphanumeric codes that include nonphysician services; and. Level 3 includes local codes developed by state Medicaid agencies, Medicare contractors, and private insurers for use in specific programs and jurisdictions.

What is a pass through ophthalmic device?

Several ophthalmic drugs and devices currently have pass-through status, including but not limited to the following: Omidria (Omeros): used during cataract surgery and IOL replacement surgery to maintain pupil size by preventing intraoperative miosis and reduce postoperative ocular pain.

What happens to a pass through drug after it expires?

After a drug or device’s pass-through status expires, it may be packaged and reimbursed as part of the facility fee for which the hospital or ASC would otherwise receive payment. This fee does not always cover the cost of the drug or device.

What is the C code for Dextenza?

Dextenza was issued the C-code C9048 effective July 1, 2019, but was granted the J-code J1096 effective October 1, 2019.

What is 20% copayment?

When a drug or device with pass-through status is used in an ambulatory surgery center (ASC), however, the statutory 20% copayment applies, although it is typically covered by a patient’s supplemental insurance.

Which is better, C code or J code?

J-codes are more advantageous than C-codes because J-codes are permanent codes that may be used across all government and third-party insurers nationwide. In contrast, C-codes are temporary and valid only for Medicare coverage of OPPS services and procedures claims. 1.

Does Medicare cover ophthalmic surgery?

CMS has not developed a policy that provides separate Medicare Part B coverage and payment for drugs that are administered at the time of ophthalmic surgery and have FDA-approved indications for the treatment/prevention of postoperative issues.

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