Crosswalk

Burden Change

Reason for Change

Type of Change

2013 (new version)

2011 (old version)
p. 2, one hour per response

one hour per response for each Part

Add clarification

no

pp. 4, 8, 12 - 14, NCCI edits

Procedure-to-Procedure (PTP) edits

Rev update to Medicaid NCCI terminology

no

pp. 4 -5, This type of request must be submitted by a State to its
CMS Regional Office no later than March 1, 2011, if it wishes to
deactivate, or continue to deactivate, NCCI edits or MUEs by
April 1, 2011.
- if it does not pay its Medicaid claims on the basis of Healthcare
Common Procedure Coding System (HCPCS) and Current
Procedural Terminology (CPT) codes;
- by February 1, 2011, information on the edits that the State has
deactivated from October 2010 through January 2011;
- information on the edits that the State has deactivated after
March 31, 2011, for the remaining three calendar quarter in 2011;
and
- information on other correct coding methodologies and edits
that the State has added to its MMIS for each calendar quarter
until the end of 2011.

Del out of date, no longer required

p. 6, over the time period from March 23, 2010, to March 31,
2011
p. 6, If this is the case, please identify the edits being added and
describe the rationale, as this is helpful and useful information.
p. 9, The period of the FFP should cover March 23, 2010, to
March 31, 2011.

Del out of date, enhanced FFP available
indefinitely
Del out of date, no longer required

p. 12, five Medicaid NCCI methodologies

five (now six) Medicaid NCCI methodologies

yes, reduced

no
yes, reduced

Del out of date, enhanced FFP available
indefinitely

no

Add update

no

Type of Change: Rev = Revision, Del = Deletion, Add = Addition, and Red = Redesignation.

Burden Change

Reason for Change

Type of Change

2013 (new version)

2011 (old version)
p. 12, A State must have submitted this Part of this APD to its
CMS Regional Office by March 1, 2011, if it wishes to deactivate,
or continue to deactivate, NCCI edits and / or MUEs by April 1,
2011. If a State submits this Part of this APD after March 1,
2011, CMS may not approve deactivation of the requested NCCI
edits and / or MUEs until after March 31, 2011. If this is the case,
then the State must have the requested edits activated as of April
1, 2011, and cannot deactivate the edits unless and until CMS
approval is received.

Del out of date

p. 16, REIMBURSEMENT OF STATE MEDICAID CLAIMS NOT
BASED ON HCPCS AND CPT CODES
The NCCI edits and MUEs contained in the NCCI methodologies
are based on the Healthcare Common Procedure Coding System
(HCPCS) and Current Procedural Terminology (CPT) codes.
However, some States do not reimburse their Medicaid claims on
the basis of HCPCS and CPT codes. For example, some States
reimburse their Medicaid claims on the basis of “revenue code”.
A State that does not reimburse its Medicaid claims on the basis
of HCPCS or CPT codes is required to report to its CMS
Regional Office the basis that it uses (e.g., “revenue code”) to
reimburse its Medicaid claims.

Del no longer required

p. 16, until the end of calendar year 2011

Del requirement now indefinite

yes

Add clarification

no

p. 16, the savings in Medicaid claims payments

the estimated savings in Medicaid claims payments

Type of Change: Rev = Revision, Del = Deletion, Add = Addition, and Red = Redesignation.

no

yes, reduced

Del out of date

Type of Change: Rev = Revision, Del = Deletion, Add = Addition, and Red = Redesignation.

Burden Change

Reason for Change

Type of Change

2013 (new version)

2011 (old version)
pp. 16 - 17, STATE DEACTIVATION OF EDITS
A State which has deactivated edits before February 1, 2011, is
required to report to its CMS Regional Office the following
information for the period October 1, 2010, to January 31, 2011:
- the number edits that were deactivated;
- the types of edits that were deactivated;
- the rationale for deactivating the edits;
- the process and the workload for State staff that deactivating
edits created;
- the number and dollar amount of claims that would have been
denied, if the edits were not deactivated;
- the number and dollar amount of claims that would have gone
to appeal, if the edits were not deactivated;
- the number and dollar amount of claims that were paid as a
result of the deactivations;
- the total number of providers that would have had denied
claims, if the edits were not deactivated; and
- any additional information that is necessary in order to
determine the impact that deactivation of the edits has had on
both providers and the State.
A State which receives CMS approval for deactivating Medicaid
NCCI / MUE edits after March 31, 2011, must report the same
information to its CMS Regional Office for each calendar quarter
until the end of calendar year 2011.

yes, reduced

Del no longer required

Type of Change: Rev = Revision, Del = Deletion, Add = Addition, and Red = Redesignation.

Burden Change

Reason for Change

Type of Change

2013 (new version)

2011 (old version)
p. 17, ADDITIONAL CORRECT CODING METHODOLOGIES
AND EDITS INCORPORATED INTO A STATE’S MMIS
The CMS encourages States to develop and incorporate
additional correct coding methodologies and edits that go beyond
those contained in the Medicaid NCCI methodologies to promote
correct coding and to control improper coding leading to
inappropriate payment of Medicaid claims. For example, a State
may want to extend Medicaid NCCI methodologies to claims for
additional types of services (e.g., managed care) and claims from
additional sites of services (e.g., long-term care facilities, Critical
Access Hospitals (CAHs), Comprehensive Outpatient
Rehabilitation Facilities (CORFs), etc.).
If a State’s Medicaid managed care program uses managed care
organizations (MCOs), then the Medicaid NCCI methodologies
generally would not apply to the extent that the MCOs generate
no claims for Medicaid reimbursement. However, if a State’s
Medicaid managed care program uses Primary Care Case
Management (PCCM), in which the provider receives a small
capitation fee, but bills the State’s Medicaid program for services
provided, then the Medicaid NCCI methodologies would be
applied to those claims. A State may incorporate additional
correct coding methodologies and / or edits into its MMIS that go
beyond the Medicaid NCCI methodologies and edits without prior
CMS approval. However, if it does so, these additional correct
coding methodologies and edits will not be part of the Medicaid
NCCI methodologies. If a State believes that these additional
correct coding methodologies or edits should be part of the
national Medicaid NCCI methodologies, the State should submit
its rationale to CMS’ technical contractor for the NCCI, Correct
Coding Solutions, LLC, for review by the CMS Medicaid NCCI
Workgroup.

yes, reduced

Del no longer required

Type of Change: Rev = Revision, Del = Deletion, Add = Addition, and Red = Redesignation.

Burden Change

Reason for Change

Type of Change

2013 (new version)

2011 (old version)
pp. 17 - 18, The CMS requests that a State which incorporates
additional correct coding methodologies and / or edits into its
MMIS that go beyond the Medicaid NCCI methodologies and
edits report to its CMS Regional Office what these additional
correct coding methodologies and edits are and the reason or
rationale for adding them to its MMIS.
A State’s MMIS may contain edits for processing Medicaid claims
from a variety of sources, e.g., the Medicaid NCCI
methodologies, additional State-specific correct coding
methodologies and edits, edits from commercial off-the-shelf
(COTS) software used by the State to process Medicaid claims,
and edits from the vendor the State contracts with to process
Medicaid claims. Denials for payments of Medicaid claims that
are due to edits from these other sources that are not contained
in the Medicaid NCCI methodologies should not be attributed to
the Medicaid NCCI methodologies.
A State which has incorporated additional correct coding
methodologies and edits into its MMIS is required to report to its
CMS Regional Office for each calendar quarter until the end of
calendar year 2011 the following information:
- a description of the additional correct coding methodologies and
edits the State has incorporated into its MMIS and
- the savings in Medicaid claims payments that the State
achieved as a result of using the additional correct coding
methodologies and edits in processing its Medicaid claims.

yes, reduced