December 22, 2014

Payer insurance analysis report

Every physician practice should be looking at and analyzing the payer insurance analysis report each and every month. This report tracks collections, payments and CPTcodes from a practice’s top ten carriers. This lets practices compare reimbursement across carriers, an important way to monitor the financial health of a practice in terms of its top revenue sources. Also use this report to identify payments that do not agree with your contracted rate(s) with the payer. Next, this report can also be a useful tool in negotiating contracts with payers. I you identify a carrier that is paying significantly less than others for the same CPT codes, you may even choose to drop that carrier. Though this is option seems unattractive to many practices, experts suggest dropping under-paying carriers can save a practice as much as $50,000 per year.



December 16, 2014

HIPAA and patient portals

I recently wrote an article about the importance of physician offices having a patient portal and how to implement such a portal. An attorney wrote me the following email reminding me about a HIPAA issue relating to patient portals; thought you might be interested in his reponse:

Just a quick note to compliment you on the patient portal item.  I’ve had recent communications with several health care attorneys and there is one HIPAA issue that I think you need to emphasize when your clients ask you about patient portals.  HIPAA requires a “security assessment” when a patient portal is implemented and, if that is not done and PHI is lost (even inadvertently), the feds could impose a hefty fine.

A recent case against an Anchorage provider reiterates the HHS position on updating training, security assessments and policies and procedures on a routine basis.

Scott Chase
Law Offices of J. Scott Chase
Board Certified, Health Law, Texas Board of Legal Specialization
Dallas, Texas

December 12, 2014

Coding for ICD-10-CM: More of the Basics

In this MLN Connects™ video on Coding for ICD-10-CM: More of the Basics, Sue Bowman from the American Health Information Management Association (AHIMA) and Nelly Leon-Chisen from the American Hospital Association (AHA) provide a basic introduction to ICD-10-CM coding. The objective of this video is to enhance viewers’ understanding of the characteristics and unique features of ICD-10-CM, as well as similarities and differences between ICD-9-CM and ICD-10-CM. Run time: 36 minutes.

  • How to assign a diagnosis code using ICD-10-CM
  • ICD-10-CM code structure
  • Coding process and examples: Combination codes, 7th character, placeholder “x,” excludes notes, unspecified codes, external cause codes
  • Resources for coders

Links to the slide presentation, audio recording, and written transcript are available on the video detail web page. Visit the Medicare Fee-For-Service Provider Resources web page for a complete list of MLN Connects videos on ICD-10.

December 11, 2014

Are you living your medical practice mission statement?

Many physician medical practices havve a mission statement. A mission statement will incorporate what your practice core values and goals are.  It doesn’t have to be long, doesn’t have to be profound…….it does have to be realistic and attainable.  A mission statement is more than a slogan, less than a strategic plan; but should incorporate both ideals and commitment.

Once you have mission statement, do you LIVE the mission statement? How you put that mission statement to work in your practice, how you incorporate both the ideals and values into every interaction, every transaction, every encounter defines your culture.

Sounds pretty simple doesn’t it? The problem however is that most physician practices I see do not live their mission statement. Want proof? It's very easy - all mission statements can be turned in to a questionnaire. You can create this questionnaire and give it all employees and providers to complete. For example, part of your mission statement may say "We treat all of our patients with compassion, empathy, and respect." This can be turned in to a simple question: Do we treat our patients with compassion, empathy, and respect on a daily basis?

If you  have a mission statement, I challenge you to turn it into a questionnaire and give it out to everyone to complete. Hopefully the answers won't surprise you.

December 10, 2014

Reminder about charitable contribution documentation

This is a reminder that individuals and businesses making year-end charitable contributions of several important tax law provisions and the substantiation requirements to deduct the contributions. Some of the reminders to consider include (1) obtaining a written acknowledgement from the charity for gifts worth $250 or more, (2) having a bank record or written statement from the charity, regardless of the amount, (3) ensuring that the charity is eligible, (4) mailing checks before year-end to deduct them in 2014 (credit card donations charged in 2014 but paid in 2015 are deductible in 2014, though), (5) for most donations of cars, boats, and airplanes valued at more than $500, limiting the deduction to the grossproceeds from their sale, and (6) filing Form 8283 with the tax return for all noncash ontributions over $500.

December 05, 2014

Medicare “Complying With Medical Record Documentation Requirements” Fact Sheet — Released

The “Complying With Medical Record Documentation Requirements” Fact Sheet (ICN 909160) was released by CMS and is now available in downloadable format. This fact sheet is designed to provide education on proper medical record documentation requirements. It includes information and resources to help Medicare providers understand how to provide accurate and supportive medical record documentation. This Medicare Learning Network publication was developed in conjunction with the Comprehensive Error Rate Testing (CERT) Part A and Part B and Durable Medical Equipment (DME) Medicare Administrative Contractor (MAC) Outreach & Education Task Forces in an effort to provide nationally-consistent education on topics of interest to health care professionals.

December 04, 2014

Is your physician practice in HIPAA compliance with your business associates?

Under the HIPAA Omnibus Final Rule published last January, the deadline for compliance with the new HIPAA rules was essentially Sept. 23, 2013. However, there was an exception built in to the rule for physician practices and other covered entities (CEs). This exception stated that for CEs with vendor business associate agreements (BAAs) entered on or before Jan. 25, 2013, these BAAs must be brought into compliance with the Omnibus Rule by Sept. 23, 2014.

Here are three steps practices should take to comply with the requirements of this final Omnibus Rule:

Identify your business associates. A helpful tip on how to identify your practice's business associates: Pull up accounts payable to access your list of vendors. With this list in front of you, identify vendors that have access to your PHI. These vendors may include IT companies, transcription companies, coding and billing companies, consultants, collection agencies, and shredding companies.Note: Under the Omnibus Rule, the definition of business associated was reworded. A business associate now includes any vendor that creates, receives, maintains, or transmits PHI on behalf of a CE — even those that do not access PHI. Business associates can now include organizations involved in patient safety activities, health information organizations, and PHI data storage companies.

Review and collect Business Associate Agreements. Once you have identified which vendors qualify as business associates, you should review the latest BAA they signed with your practice. If the most current BAA you have on file with a vendor is signed on or before Jan. 25, 2013, you should immediately amend or replace this BAA and have a vendor sign a new BAA that complies with Omnibus Rule requirements.

Lastly, audit your business associates. If your practice delegates duties to a vendor, a practice has a responsibility to confirm — to the best of its ability — the business is handling those duties in conformity with HIPAA rules. This can be accomplished through an auditing process in which your practice asks business associate representatives a number of questions and then assesses the answers.

December 02, 2014

CMS to require use of new 855R Medicare enrollment form

The   Centers for Medicare & Medicaid Services (CMS) recently finalized a new 855R form, which is used to   reassign an individual physician's Medicare billing privileges to an   organization. The revised form will become available on the websiteon Dec. 29, 2014 and can be   found by searching "855." Once available, Medicare administrative   contractors may accept both the current and revised versions of the form   through May 31, 2015, after which only the revised CMS 855R application will   be accepted. The online Medicare Provider Enrollment, Chain and Ownership   System (PECOS) will be updated to include the revised Medicare reassignment   information.

November 28, 2014

Webinar: Effectively Marketing Your Ancillary Services

Medical practices, just like other businesses, have the opportunity to grow their business in a number of service lines and product or service offerings. As more physicians and clinics differentiate their business offerings, marketing strategies and business development goals must adjust accordingly.  

Click Here to Register

Join Jamie Verkamp, Managing Partner and Chief Speaking Officer at (e)Merge, December 16th at 1:30 Eastern, who  will discuss how to specifically grow the ancillary services and travel medicine offerings related to your medical practice.  

You'll hear examples of other healthcare organizations who are reaching out to their community to develop and further foster profitable referral relationships. Strategies to further promote and grow these unique healthcare offerings will be shared and discussed to guide you in creating a plan for your ancillary service line or travel medicine book of business.  

November 26, 2014

The future: Be open to the development of new and innovative relationships with your colleagues

Here are some random thoughts I have regarding small medical practices and their future:

  • I believe small practices will continue to lose any ability to negotiate rates with payers.
  • As costs rise and reimbursement remains flat, the incentive to join hospital system networks will continue.
  • I think the demise of the small practice can be avoided through the development of either clinically integrated practice networks or the development of flexible merger models such as groups without walls.
  • Even small groups need to look beyond the fee-for-service mentality of "do more, make more" and embrace patient management and cost-effective care. Historic investments in EHRs can pay dividends in supporting these initiatives.

CMS reported that the fasted growing alternative payment model is bundled payments. Under this model, a lump sum is paid to the sponsor of the program and they divide the money among care providers, including hospitals. Early adopters of this approach were hospitals who then got to influence how the money is paid and that included physicians. Again, the small practice will have limited bargaining power in this setting. If physicians were the sponsor, like the California examples, they would purchase needed services from the hospital without caring what it cost the hospital to deliver the service.

So what's the bottom line message in this blog post? I believe physicians that want to remain in private practice need to be exploring collaborative models that will allow them to move up the financial food chain. This can’t wait until tomorrow because the speed with which payment models are evolving will eliminate the fence-sitters from playing a meaningful role in care management. While reports of the death of small practices are premature it is possible that critical care will be necessary unless those practices are open to the development of new and innovative relationships with their colleagues.