January 30, 2015

Compliance tip - Enable EMR tracking mechanism

Most EMR software programs include a tracking mechanism to help ensure patients have completed recommended tests and consultant referrals. However many physician practices do not use these systems or have yet to discover they even exist. These tracking systems can minimize exposure to allegations of failure to diagnose and can lead to better patient care. Specifically, these systems can provide a way for you to:

  • Verify that the patient keeps the appointment or completes the test;
  • Confirm receipt of a report;
  • Prompt a call to the consultant, imaging center, or lab if a report is not received;
  • Make sure the physician reviews the report;
  • Communicate results to patients;
  • Arrange for follow-up if needed; and
  • Document all these steps with dates and electronic signatures.

January 28, 2015

How is your medical office's communications with your patients?

Physician and patient communication is at the heart of empowering positive outcomes. As payment models shift from payment for activity to payment for outcomes how to be a more effective at communication should be at the top of physician lists to improve.

The basics of communication continue to consume the priorities of writers, and old books about “how to” like How to Win Friends and Influence People continue to be best sellers. Regardless of how language and thought about communication has changed; the basics have remained.

Between physician and patient, there has never been a more important time to get communication right. While visiting a physician with my 88 year old father recently, several things struck me about communication and how it played a significant role in the visit.  The advent of the EHR has changed the patient visit dynamics.  During this particular visit, a nurse came in to get a full history.  The lap top was placed on a counter and the nurse with her back to the patient, my father, began to ask questions.  Repeatedly, my dad used non-verbal communication in reaction to a question……which of course the nurse did not see nor react to.  Like the question  “describe your pain”......there was a pause as my dad shrugged his shoulders …….the  nurse asked again, “describe your pain…on a scale of 1-10 1 being no pain And 10 being unbearable.”  Again a shrug of the shoulders and a numeric response.  The nurse was in her 20’s and while technically proficient, didn’t realize she was speaking to the “no pain” generation patient. She could have gotten a significantly more realistic answer if she has been watching and reacting to the non-verbal communication.

Hint number 1:  You can’t really communicate with a person you are not looking at.

As the nurse quickly ran through a list of diseases asking was there history, dad looked at me as she was going so fast, he really didn’t have time to answer before asking a second time.  

Hint number 2: Don’t rush conversations especially with elderly patients, give patients time to absorb the questions and to answer in their language.

Frequently, the nurse who was looking at the computer screen missed answers and had to ask for them to be repeated.  Now of course, giving the nurse the benefit of the doubt, learning to work with an EHR is no simple task and requires concentration and organized thoughts.  New technology brings new challenges and work flow changes that must be learned over time.  But….

Hint number 3:  Pay attention to the patient. Actively listen.

This may also require one to ask clarifying questions. Actively try to understand not only what the patient says, but what they mean. At the conclusion of the nurse interview, she said to dad…..”I’m going to repeat back what I heard you say was your chief reason for being here today, you tell me if you agree.”   That was right on…..right out of how to effectively communicate 101.

Hint number 4: Repeat back what you believe you heard.

All this takes time and a focused effort to hear and be heard.  But with outcomes depending upon patients understanding their roles and responsibility in this patient provider dance, and revenue streams increasingly dependent on outcomes, isn’t it worth it?

January 26, 2015

Taking your EHR to the next level in your physician practice

Your practice has bought an EHR system.  Although you have struggled with implementing, providers and staff are now familiar with the product and you are using daily in your practice.  What’s the next step?  How can you use digital records to decrease cost and improve clinical outcomes? Here are some ideas:

  • Have patients fill out forms online instead of paper forms in the office.  This will decrease wait times, give the patient to complete all the requested data without feeling rushed, allow patients to answer all the questions without skipping sections not having access to information.  Some practices are even charging for not using on-line forms.  While this may seem over-bearing, providers have found that creating a digital expectation of patients serves both the patient and the practice well.
  • Lab and x-ray results can be posted in the digital record.  Upon review, the provider can email (via a secure patient portal) patient with instructions or changes in medications.  This will require patients and staff to use the EHR on a regular basis and may present a learning curve for both; but using on a regular basis will dramatically reduce phone calls and time on phone.  This may provide opportunity to reduce front-end staff.
  • No more paper charts mean a more organized and instantly retrievable chart.  No more time spent hunting down pieces of paper, reading someone’s writing, or waiting for someone to finish with chart so others can chart or look at data.  Multiple persons can both look at chart and record in chart at the same time.
  • Downloading data from patients with similar conditions can help a provider more easily identify efficacy of treatments and medications. From data collection to treatment options now becomes a realized practice.  Data manipulation and analysis will be the next big step for practices.

January 21, 2015

Medicare claims for post-op care being denied as a billing error

When reporting claims for post-op care, the date of surgery is the date of service. Also, if there is a range of dates of service, report the range of dates in block 19 of the 1500 claim form or the electronic equivalent. Be sure to report an appropriate modifier to indicate that you are billing for post-op care.

January 20, 2015

Large HIPAA Fine: Feds Reiterate Importance of Updated HIPAA Protocols and Security Assessments

The U.S. Department of Health and Human Services, Office for Civil Rights (HHS-OCR), has recently entered into another HIPAA settlement, emphasizing yet again the government's focus on the HIPAA Security Rule.  The settlement highlights that health care entities cannot merely adopt HIPAA policies but that they must actually implement and follow those policies in practice on an ongoing basis.  In early December 2014, HHS-OCR confirmed that Anchorage Community Mental Health Services (ACMHS), a nonprofit organization providing behavioral health care services, had agreed to pay a $150,000 fine and adopt a corrective action plan to correct deficiencies in its HIPAA compliance program and to report to HHS-OCR on the state of its compliance for two years.  The settlement was based on a HHS-OCR investigation regarding ACMHS’s breach of unsecured electronic protected health information (ePHI).  The breach was the result of a malware that compromised the security of ACMHS' information technology (IT) resources and affected 2,743 individuals.

During its investigation, OCR-HHS found that ACMHS had adopted sample HIPAA Security Rule policies and procedures in 2005, but these policies and procedures were not followed and/or updated.  Thus, ACMHS could have avoided the breach (and not be subject to the settlement agreement), if it had followed its own policies and procedures and regularly assessed and updated its IT resources with available patches. The settlement with ACMHS is just one of several recent settlements arising from an HHS-OCR investigation, either because an organization self-reported a breach of ePHI or because HHS-OCR investigated an organization's HIPAA compliance program after receiving a complaint or as part of its annual audit protocol.  No matter how the investigation begins, HHS-OCR will expect an organization to have fully implemented and updated its HIPAA compliance program and/or policies and procedures.  Compliance with the HIPAA Security Rule requires organizations (among other things) to assess risks to ePHI on a regular basis, including whenever new software, e.g., a patient portal, is implemented.  Organizations cannot simply adopt HIPAA policies and procedures, conduct training and then ignore HIPAA.  All organizations subject to HIPAA, both “covered entities” and “business associates” (regardless of size), must devote ongoing resources to protect personal health information from security threats.

January 13, 2015

Miscellaneous ACA health care tax subjects

Consumer-friendly Tools for the 2015 Tax Filing Season: Individuals with health coverage obtained through the Marketplace and those that chose not to enroll in health coverage will have additional steps to complete in filing their returns. Marketplace enrollees will receive Form 1095-A that they will use to reconcile their upfront financial assistance. Individuals who could afford coverage but chose not to purchase it will pay a fee. The Health and Human Services and Treasury Departments recently announced they are proving tax filers with information and other resources to answer questions regarding the changes to the 2014 Form 1040 . General resources are located at www.IRS.gov/ACA or https://www.healthcare.gov/taxes/ and more will be made available in the coming weeks.

New IRS Publication on Reporting Individual Health Care Coverage: Tax year 2014 is the first year individuals will be required to report whether they satisfied the Individual Shared Responsibility (ISR) provisions of the Affordable Care Act (ACA). The IRS issued a new publication on how individuals are to report their health care coverage on their tax returns. Publication 5187 (Health Care Law: What's New for Individuals and Families), covers some of the tax provisions of the ACA and explains how taxpayers satisfy the ISR provision by enrolling in minimum essential coverage. Additionally, the publication explains how individuals qualify for an exemption or how they are to make a shared responsibility payment, as well as information about the new premium tax credit. Publication 5187 is available at http://www.irs.gov/pub/irs-pdf/p5187.pdf .

January 09, 2015

How can a health care provider apply for and obtain a National Provider Identifier (NPI)?

A health care provider may apply for an NPI in one of three ways:

1. Apply through a web-based application process. The web address to the National Plan and Provider Enumeration System (NPPES) is https://nppes.cms.hhs.gov.

2. If requested, give permission to have an Electronic File Interchange Organization (EFIO) submit the application data on behalf of the health care provider (i.e., through a bulk enumeration process). If a health care provider agrees to permit an EFIO to apply for the NPI, the EFIO will provide instructions regarding the information that is required to complete the process.

3. Fill out and mail a paper application form to the NPI Enumerator.  Health care providers may wish to obtain a copy of the paper NPI Application/Update Form (CMS-10114) and mail the completed, signed application to the NPI Enumerator located in Fargo, ND, whereby staff at the NPI Enumerator will enter the application data into NPPES.  This form is now available for download from the CMS website (http://www.cms.gov/cmsforms/downloads/CMS10114.pdf) or by request from the NPI Enumerator.  Health care providers who wish to obtain a copy of this form from the NPI Enumerator may do so in any of these ways:

Phone:  1-800-465-3203 or TTY 1-800-692-2326
E-mail:  customerservice@npienumerator.com
Mail: NPI Enumerator
P.O. Box 6059  
Fargo, ND  58108-6059

January 08, 2015

A simple business model for a physician practice

Lest we forget............

1. Generate a charge;

2. Collect for services;

3. Manage cost (overhead); and most importantly

4. Live within your means!!

January 06, 2015

Begin the new year with focus on employees

The physician medical practices are focused on reducing turnover costs, but more importantly, they are focused on keeping top performers - They accomplish this goal by taking positive steps to engage their employees.

According to the Gallup organization, employers have three types of employees:

Engaged employees work with passion and feel a profound connection to their employer. They drive innovation and move the organization forward.

Not-Engaged employees are essentially "checked-out." They're sleepwalking through their workday, putting in time - but not energy and passion - into their work.

Actively Disengaged employees aren't just unhappy at work - they're busy acting out their unhappiness. Every day, these workers undermine waht their engaged co-workers accomplish.

I have observed that leaders in many physician medical practices fail to implement initiatives that go a long way in supporting and retaining their engaged employees (top talent). Many physician practices also lack the commitment to outplace the actively disengaged employees. Remember this - your best performers EXPECT YOU to get your poor performers out of the way.

So as you start this new year as yourself: Does it make sense to get rid of the deadwood?

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.