Fee Schedule Updated

The Commission has updated its medical fee schedule to include maximum reimbursement rates for codes that had been previously listed as "POC53.2."  Section 8.2 of the Workers' Compensation Act authorizes the Commission to establish fee schedule reimbursements using provider non-discounted charge data, non-Medicare relative values, and conversion factors from established fee schedule amounts. 

The Workers' Compensation Medical Fee Advisory Board voted to approve the reimbursements for 16,000 codes on the Professional Services fee schedule, all of which had been paid at 53.2% of the billed amount. 

To view the new Professional Services fees, click the new button, "2013 Professional (10-11-13)" at https://iwcc.ingenix.com/IWCC.asp

2014 Fee schedule rates will increase 1.52%; 7% lower than 2006

Medical fee schedule rates will increase 1.52% on January 1, 2014. If the fee schedule had tracked medical inflation, rates would be 30% higher than in 2006; instead, rates are 7% lower than 2006.

Section 8.2(a) of the Illinois Workers' Compensation Act provides that, each year, fee schedule rates shall increase or decrease by the percentage change in the Consumer Price Index-U (CPI-U) in the previous year.

The 2014 rates will be posted as soon as the vendor, Optuminsight, calculates them and obtains information about new and deleted codes. The rates are usually posted at the end of the year. We will give notice on our blog when the rates are online.

2013 Medical Fee Schedule: Status Update

As announced previously at its December Medical Fee Advisory Board meeting, the IWCC posted the 2013 medical fee schedule on its website; however, it pulled the schedule shortly after due to issues identified by the vendor.

The IWCC announcement:

The 2013 fee schedule was posted, but some problems were identified, and the vendor, Optuminsight, took it down to work on it. Optuminsight is working on adding code descriptions and posting the correct surgical codes to the Hospital Outpatient and ASTC fee schedules, so please view the schedule with caution. We will announce when this work has been completed.  

In the meantime, if you identify any issues with the 2013 schedule, please let us know.

The 2013 medical fee schedule is effective on January 1, 2013.  We will post additional updates when the IWCC website rereleases the schedule or Optuminsight announces any additional changes.

2013 Fee Schedule Annual Rate Adjustment

The Illinois Workers' Compensation Commission announced its annual rate adjustment for the Illinois workers' compensation fee schedule. Effective January 1, 2013, the fee schedule rates will increase 1.69%.

Section 8.2(a) of the Illinois Workers' Compensation Act provides that, each year, fee schedule rates shall increase or decrease by the percentage change in the Consumer Price Index-U (CPI-U) in the previous year.  

The IWCC's announcement includes a chart that shows the adjustment rate for each year since 2006.

The medical fee schedule rates will increase 1.69% in 2013, which is less than half the rate of medical inflation (CPI-M). As the chart below shows, the fee schedule amounts are now running 37% below medical inflation over the life of the fee schedule.

The 37% difference between the IL fee schedule and medical inflation does include HB 1698/PA 97-18's 30% fee schedule reduction effective on September 1, 2011.  The remaining 6.96% is the difference between the rate of medical inflation (CPI-M) and Consumer Price Index-U (CPI-U). 
  
As Glen Boyle reported at the IWCC Medical Fee Advisory Board's December meeting, the 2013 annual fee schedule updates and rates are currently scheduled to complete internal review and quality check by December 21, and the new 2013 rates have an anticipated posting date of December 28, 2012. The annual fee schedule updates are effective on January 1 of each year.

 

IWCC & Repackaged/Compounded Pharmacy

With the recent meningitis contamination and push for more oversight over compounding pharmacies (see these articles from Business Insurance & the Chicago Tribune),  we received several questions regarding the new IWCC repackaged pharmacy repricing methodology and compounded drugs.
 
While variations exist,

• Physician-dispensed repackaging usually involves drugs that are purchased in bulk, repackaged into smaller fill amounts, and then dispensed by a provider’s office, rather than from a pharmacy. 
• "Traditional pharmacy compounding in the United States involves the act of combining, mixing or altering ingredients to prepare a customized medication for an individual patient upon receipt of a valid prescription." (University of Southern California, Pharmacy compounding – regulatory issues)

 
Compounded drugs were on the IWCC Medical Fee Advisory Board's December meeting agenda, and the Board made a clear distinction between the new physician-dispensed repackaged pharmacy reimbursement methodology and compounded drug regulations.
 
With several state and federal agencies reviewing potential changes to the review and regulatory oversight of compounded pharmaceuticals, the Medical Fee Advisory Board stated that it will continue to monitor federal and state regulatory actions, and this issue could appear on a future meeting agenda if necessary.



 

Final Physician-Dispensed Pharmacy Rule Published

The IWCC's final repackaged drug repricing methodology was published in the December 7 edition of the Illinois Register.

 

As we covered in our 11/20/2012 post, the effective date of the change is November 20, 2012.  The Medical Fee Advisory Board did clarify at its December meeting that the pricing methodology is for dates of service of 11/20/2012 and later.  The final adopted amendment did not contain changes to the language from the previously published proposed rulemaking.
 
The implemented rules begin on page 17108 (PDF page 315) of Volume 36, Issue 39 of the Illinois Register.
 

From the IL Workers' Compensation Commission's Notice of Adopted Amendment:

Summary and Purpose of Rulemaking: The amendment implements Section 8.2(a-3) of the Workers' Compensation Act by specifying that when a prescription dispensed outside of a licensed pharmacy is repackaged, the Average Wholesale Price used to determine the maximum reimbursement shall be the Average Wholesale Price for the underlying drug product, as identified by its National Drug Code (NDC) from the original labeler.

Pursuant Section 8.2(a-3) of the Act, only prescriptions dispensed outside of a licensed pharmacy are subject to a fee schedule. The fee schedule sets the maximum reimbursement levels for these prescriptions. For prescriptions dispensed outside of a licensed pharmacy, Section 8.2(a-3) provides that the fee schedule shall not exceed the Average Wholesale Price, plus a dispensing fee of $4.18. Average Wholesale Price is determined by the NDC set forth in Medispan.   

The amendment addresses a practice known as "repackaging" which means that the prescription will be purchased and then repackaged in different quantities. It is then given a new NDC number with a higher Average Wholesale Price. Thus, the "repackaging" avoids the NDC for the drug from the original labeler. "Repackaged" drugs are typically dispensed by physicians in their offices.

IWCC Fee Schedule Updates

The Illinois Workers' Compensation Commission's Medical Fee Advisory Board met on Wednesday for its December meeting.
 
The agenda covered a range of topics, and this first post will cover a couple of those issues.
 

Physician-Dispensed Repackaged Pharmacy

Our previous update covered the changes to the reimbursement for physician-dispensed pharmacy in Illinois.  The final rule should appear in the Illinois Register tomorrow (12/7/12), and the effective date of the reimbursement modification is November 20, 2012. 
 
The Board did clarify that the modification only applies to bills with dates of service/fills on 11/20/12 and later.
 

2013 State Fee Schedule Updates

Glen Boyle, from Health Systems International, LLC, provided a written update regarding both finalized and potential updates to the Illinois state workers' compensation fee schedule.
 
The 2013 annual fee schedule updates and rates are currently scheduled to complete internal review and quality check by December 21, and the new 2013 rates have an anticipated posting date of December 28, 2012.  The annual fee schedule updates are effective on January 1 of each year.
 
In addition to the annual updates, Glen Boyle also reported out on potential methodology changes to update the POCs. 

(The IWCC defines POCs as "when the Commission is unable to calculate a fee for a procedure, there is a default payment provision. From 2/1/06 - 8/31/11, the default is POC76, meaning payment shall be 76% of the charged amount. Effective 9/1/11, all default payments are 53.2% of the charged amount (POC53.2).")
 
From his written report:

IWCC & JCAR December Meeting Schedule

With just over a month remaining in 2012, here are the remaining scheduled IWCC and JCAR meetings for December.

Illinois Workers' Compensation Commission

December 5, 2012 

Self-Insurers Advisory Board

• Thompson Center, 100 W Randolph Street, Chicago
• 10:30am in the 8th Floor Chairman's Conference Room
• Self-Insurers Advisory Board meeting agenda

Workers' Compensation Medical Fee Advisory Board

• Thompson Center, 100 W Randolph Street, Chicago
• 1:00pm in Room 9-039 (9th Floor)
• The agenda for the Advisory Board's December meeting contains several updates including
• a report from Glen Boyle
• a discussion on compounded drugs
• updates on the Rules and Commission
• WC Medical Fee Advisory Board meeting agenda

Joint Committee on Administrative Rules

December 11, 2012

• Michael A Bilandic Building, 160 N LaSalle St, Chicago
• 11:00am in Room 600C
• As of this morning, the December JCAR agenda includes
• One (1) Department of Insurance-proposed rulemaking concerning a Medical Malpractice Data Base
• Medical Malpractice Data Base (50 Ill. Adm. Code 928) proposed 7/6/12 (PDF Page 205)
• No IWCC-proposed rulemakings
• JCAR December meeting agenda

 

WC PPP: Pending Second Notice

As part of the JCAR's First Notice process for the new WC PPP rules, all interested parties were permitted to submit public comments about the proposed regulatory changes to the IDOI up until the June 11, 2012 deadline.

At this point, JCAR has not addressed the modifications to 50 Ill. Adm. Code 2051 with the IDOI at its monthly meetings, and, as of this post, the WC PPP rules are not scheduled on the agenda for the December JCAR meeting.

• Preferred Provider Programs (50 Ill. Adm. Code 2051) proposed 4/27/2012 (PDF Page 286)

2013 IWCC Board Meeting Schedule



The Illinois Workers' Compensation Commission recently posted the dates and locations for its 2013 IWCC Board meetings.  See the chart below for the scheduled locations, dates, and times.

 

As a reminder, the Self-Insurers Advisory Board and the Workers' Compensation Medical Fee Advisory Board both have a final 2012 meeting scheduled for 12/5/2012 at the Thompson Center in Chicago.

 

IWCC Dental Fee Schedule Effective Date

As previously posted, the Illinois Workers' Compensation Commission modified its dental fee schedule rates and methodology. 

The IWCC updated its website yesterday with the effective date of that schedule.  The IWCC dental fee schedule will apply for all dates of service on or after June 20, 2012. 

The full IWCC post:

The Commission has posted a fee schedule for dental services provided on or after June 20, 2012. Bills should be paid at the lesser of the actual charge or the fee schedule amount.

As part of the changes instituted by HB 1698/PA 97-18, the legislature directed the Commission to create a dental fee schedule. Thanks to the Workers' Compensation Medical Fee Advisory Board and the Illinois State Dental Society for their help in obtaining and analyzing the needed data.

IWCC Dental Fee Schedule Posted

The new IWCC Dental Fee Schedule for Non-Hospital Regions 1-4 is now posted on the Illinois Workers' Compensation Commission's website. 

As of this morning, the IWCC Instructions and Guidelines are still pending publication in the Illinois Register, but the new region-specific fee schedule reprice amounts for dental codes D0120-D9999 are available for review.

The codes are located on the IWCC's Medical Fee Schedule page, under the heading NON-HOSPITAL FEE SCHEDULES.

We will follow-up with additional posts when the IWCC publishes the effective date for the dental fee schedule and its Instructions and Guidelines.

9/19/2012 IWCC Medical Fee Advisory Board Update

An initial update from the IL Workers' Compensation Commission's Medical Fee Advisory Board September meeting...

IL Administrative Code Updates

At its September 11, 2012 meeting, the IL General Assembly's Joint Committee on Administrative Rules (JCAR) issued Certificates of No Objection for two separate IWCC updates to the IL Administrative code. The IWCC can now adopt the rules by filing them with the Secretary of State for publication in the Illinois Register. 

• Miscellaneous (50 Ill Adm Code 7110) proposed 3/2/12 and incorporates all of HB 1698/Public Act 97-18’s modifications and updates to the medical fee schedule reimbursement and methodology rules.  (See our previous post with an outline of the major updates)
• Alcohol and Drug Sample Collection and Testing [PDF page 75 of the document] (50 Ill Adm Code 9140) proposed 6/15/12 and incorporates HB 1698/Public Act 97-18’s intoxication & testing requirements.

The proposed rules set forth the process for the collection of blood, urine, breath and saliva. These proposed rules include requirements for documentation, transportation and disposal of samples collected, as well as associated records. The proposed rules also set forth the qualifications for those collecting samples.

The effective dates of the IL Administrative Codes will appear when published in the Illinois Register.

 

IWCC Dental Fee Schedule 

The Medical Fee Advisory Board finalized and voted to recommend a dental fee schedule. For a more detailed overview of the debate and formation of the dental schedule, the Advisory Board’s June meeting minutes are now available on the IWCC website.  Previously, all dental care reimbursed at the IWCC default rates:

…For treatment between 2/1/06 - 8/31/11, the default is POC76, meaning payment shall be 76% of the charged amount. Effective 9/1/11, all default payments are 53.2% of the charged amount (POC53.2). Parties are always free to contract for amounts different from the fee schedule.

As of this morning, the IWCC website did not include the updated dental fee schedule information. We will post another update when the IWCC publishes the rates and effective date of the new fee schedule.

IWCC Medical Fee Advisory Board 9/19/2012 Meeting

The IWCC Medical Fee Advisory Board is scheduled to meet at 1:00 pm on Wednesday, 9/19/2012.

The current agenda includes several IL WC state fee schedule issues, including:

• the IL dental fee schedule
• unlisted coding rules
• T-codes and Category III codes

The meeting is currently scheduled for Room 9-039 at the Thompson Center (100 W Randolph St, Chicago)

http://www.iwcc.il.gov/WCMFAB091912notice.pdf

IWCC Releases 2012 Fee Schedules

The IWCC stated at the December Medical Fee Advisory Board meeting that the Year 2012 rates would not be available until 12/31/11, but both the new rates and data specifications for downloading the rates are now available on the IWCC's website.

The IWCC updated the medical fee schedule lookup with the new 2012 hospital and non-hospital fee schedule regions.  Since the current and previous years' fee schedules are based on the geozip regions, they are still available under the Archived Fee Schedules 2006 through 2011 tab on the main screen.

Current fee schedule lookup



New fee schedule lookup

Both the IWCC's Rules and Instructions and Guidelines for treatment on or after 9/1/11 are still in process and not available at this time.  A draft version was presented at the December Medical Fee Advisory Board meeting, and at that time, the Secretary of the Commission, Kimberly Janas, requested comments on the draft version.

Arbitrator and 1/1/2012 Fee Schedule Updates

2012 Fee Schedule Region Update
The new IWCC fee schedule regions, and their recalculated fee schedule amounts, become effective on 1/1/2012.  The regions are moving from geozip-based to region/county-based. Per the IWCC Medical Fee Advisory Board's December meeting, the new fee schedule reprice amounts and finalized medical fee schedule lookup will not be publicly available until Saturday, 12/31/2011.

We are currently attempting to confirm the exact data file layout format, and if there will be any sort of geozip to region crosswalk, with Glen Boyle and the IWCC. 

Arbitrator Jutila's case reassignments
The IWCC updated its case reassignment schedule for January 2012.

Effective January 1, 2012, Arbitrator Jutila's cases will be reassigned among the three Region 6 arbitrators: Arbitrators Fratianni, Kinnaman, and O'Malley. Accordingly, the January call, scheduled for Dec. 29, has been cancelled. Corrected notices will be sent.

Send settlement contracts to either of the current Chicago arbitrators (in January, Arbitrator Fratianni or O'Malley). Arb. Williams will still hear Jutila cases during his December trial cycle.

IWCC December Updates

The IWCC's Medical Fee Advisory Board meeting is scheduled for Wednesday, December 7 at 2pm.  Currently, the only identified topic of discussion on the agenda is a status update on the changes to the medical fee schedule. 

We did send an inquiry to Glen Boyle regarding the posting of the new fee schedule regions' rates on the IWCC website.  Per his response, the anticipated release timeframe should be the end of this week.  We will verify this is still the release schedule at the Board meeting on Wednesday.

IWCC issues impairment ratings to the arbitrators
The Commission voted to provide recommendations to its arbitrators regarding the use of the American Medical Association impairment ratings in the determination of permanent partial disability awards.

Section 8.1b of HB 1698/Public Act 097-0018 included the following language:

...The most current edition of the American Medical Association's "Guides to the Evaluation of Permanent Impairment" shall be used by the physician in determining the level of impairment.

The Commission issued a memo to arbitrators regarding the use of the AMA impairment ratings. It includes the following guidance:

1. An impairment report is not required to be submitted by the parties with a settlement contract. 
2. If an impairment rating is not entered into evidence, the Arbitrator is not precluded from entering a finding of disability.

NCCI's IWCC Presentation

On Wednesday, November 30, NCCI (National Council on Compensation Insurance, Inc) presented an overview of both the Illinois and national workers' compensation markets for the IWCC Advisory Board and Medical Fee Advisory Board. 

This presentation, by Terri Robinson and Karen Ayres, was a slightly condensed version of the 2011 Illinois State Advisory Forum report NCCI released in October at its Rosemont, IL meeting. 

During Wednesday's meeting, many of the questions and comments from the audience revolved around NCCI's recommended -8.8% advisory premium rate adjustment on 9/1/2011.  HB 1698/Public Act 097-0018 required NCCI to file revised rates and loss costs by September 1, and the Illinois Department of Insurance approved that rate reduction. 

According to the presentation, while NCCI stated that many of HB 1698's modifications to the workers' comp system should lower system costs, it could only quantify a few of those changes with the information available and the required deadline to recommend a new premium rate.  The actuaries at NCCI calculated that the following reforms would reduce the overall workers' compensation costs for Illinois by 8.8%:

• the 30% fee schedule reduction                     -7.4%
• the changes to the wage differential benefits   -0.8%
• the changes to PPD carpal tunnel benefits       -0.6%  

NCCI has also filed its annual rate update, a 3.5% increase, with the IDOI for 1/1/2012.  NCCI's 1/1/2012 rate updates for neighboring states: 

• Indiana:  +2.6%
• Iowa:  +4.4%
• Missouri:  -3.0%

While the Illinois rate increase is 3.5%, that number is misleading when compared to its neighboring states.  Unlike those states, the Illinois rate increase is calculated off the 9/1/2011 rates, rather than the 1/1/2011 rates. 

Taking into account the -8.8% reduction to the rates on 9/1/2011, the recommended 3.5% increase to the Illinois rates equate to a rate reduction of -5.3% from the 1/1/2011 rates for Illinois.

The full NCCI Illinois State Advisory Forum report is available on the NCCI website.

NCCI's Illinois Insurance Market Presentation

On Wednesday, November 30, the National Council on Compensation Insurance (NCCI) will present its findings concerning the state of both the Illinois and national workers' compensation insurance markets to the IWCC's Medical Fee Advisory Board.

In response to the passage of HB 1698/Public Act 097-0018, NCCI filed, and the Illinois Department of Insurance approved, an 8.8% decrease in the voluntary advisory insurance rates effective 9/1/11.  However, in September, NCCI requested a 3.5% increase for the 2012 rates. This Business Insurance article from October provides a general overview of the two rate changes.

The NCCI presentation is scheduled for 9:00am in Room 9-040 of the James R. Thompson Center.

Next IWCC Medical Fee Advisory Board Meetings

The IWCC Medical Fee Advisory Board has two scheduled meetings in the coming weeks.

On Wednesday, November 30, the National Council on Compensation Insurance (NCCI) will provide the Board with a presentation concerning the state of both the Illinois and national workers' compensation insurance markets.  The meeting is scheduled for 9:00am in Room 9-040 of the James R. Thompson Center.

The Board will then meet one week later for its regularly scheduled meeting at 2:00pm on Wednesday, December 7. The IWCC website does not have the meeting agenda posted at this time, but this will be the last scheduled Board meeting before the implementation of the new IWCC fee schedule regions on 1/1/2012. 

1/1/2012 Fee Schedule Region Maps & Update

As covered in previous posts, there are major changes to the IWCC's fee schedule regions coming January 1, 2012. The regions, and the providers' fee schedule amounts, will change in less than 2 months.

While the Medical Fee Advisory Board initially voted to use a weighted average to collapse the geozip regions, Chairman Mitch Weisz announced at the October 18 meeting that the IWCC will utilize a straight average, without weighting, to collapse the current geozip fee schedule amounts into the four Non Hospital and fourteen Hospital regions.  Our September 20 Board Meeting update included two examples of the the geozip collapse utilizing both a weighted average and a straight average methodology. 

The current IWCC fee schedule lookup utilizes the 3 digit geozip; however, the new regions are defined by county, not geozip.  Per our latest conversations with the IWCC, the new medical fee region lookup and rates will not appear on the IWCC website until the end of the year. 

Maps of the new IWCC fee schedule regions

4 Regions: Non Hospital Fee Schedule Amounts

1. Cook County
2. DuPage, Kane, Lake, & Will Counties
3. Bond, Calhoun, Clinton, Jersey, Macoupin, Madison, Monroe, Montgomery, Randolph, St. Clair, & Washington Counties
4. All other counties in the state

14 Regions: Hospital Fee Schedule Amounts

1. Cook, DuPage, Will, Kane, McHenry, DeKalb, Kendall, & Grundy Counties
2. Kankakee County
3. Madison, St. Clair, Macoupin, Clinton, Monroe, Jersey, Bond, & Calhoun Counties
4. Winnebago & Boone Counties
5. Peoria, Tazewell, Woodford, Marshall, & Stark Counties
6. Champaign, Piatt, & Ford Counties
7. Rock Island, Henry, & Mercer Counties
8. Sangamon & Menard Counties
9. McLean County
10. Lake County
11. Macon County
12. Vermilion County
13. Alexander County
14. All other counties in the state