Jury duty

A client the other day asked for sample language to address jury duty in their human resource policy manual; here is what I provided:

 

Jury service is considered to be a community obligation except in those rare cases when such service would be an undue hardship to the practice. If it should prove a hardship to the practice for the employee to serve on jury duty, the practice may petition the court for the employee to be relieved from serving this duty. When an employee receives a notice for jury duty, he or she should provide a copy of the notice to the administrator on the next working day.

 

[COMPANY] will pay employees the difference between the regular daily payment amount and the payment received for jury duty for a maximum of five days per year. This service will not be charged against the PTO for any employee. In order to be reimbursed for this additional pay, the employee must provide to the administrator a copy of the jury duty notice and copies of the checks received from the local jurisdiction for this jury duty payment. Failure to do so will result in the days missed being taken as leave without pay.

Performing your own internal coding audit

With RACs surrounding us and lots of talk lately about fraud and abuse issues, now might be a good time to conduct your own internal audit.  When you perform an internal, you’re comparing your physician’s billing records, claims, and medical records to verify expected treatment outcomes and medical necessity of services. In addition, you’ll look for appropriate documentation to support fees and reasonable charges for services your surgeons rendered. You want to find out if there are any compliance problems before an outside auditor does. The following are a few quick steps to help you conduct your own audit:

Involve the staff. Let every member of your practice know what you’re doing and why, and remind them that you aren’t trying to get anyone in trouble. Instead, you want to determine whether they’re bringing in the right amount of reimbursement and cutting out denials.

Select the charts. Most auditing specialists I know recommend that you review 10 to 15 records per physician at a minimum. I’ve seen the sample go as high as 50 charts per physician.

Examine the chart’s documentation. Read the documentation and determine which ICD-9 and CPT codes you think apply to the chart, then check which codes were actually assigned to the services. When in doubt, engage the services of an outside auditor.

Pay special attention to time-based coding. I know many physicians who code E/M services based on time with the patient. You have to have a believable reason that you had to provide the majority of the service on counseling/coordination of care to justify basing your E/M level on time.

Use a score sheet. Many MACs offer audit tool score sheet templates that can help you when auditing documentation. For instance, High-mark Medicare offers several templates on its Web site, such as the E/M worksheet at

www.highmarkmedicareservices.com/partb/reference/pdf/scoresheets/8985.pdf.

Educate. After the audit, show your physicians, other practitioners, coders, and billers what the outcome was so you can combat any problem areas.

Remember the goals of any good compliance program are the following:

Prevent – Detect - Correct

Beyond Co-Pay: Upfront Bills at the Doctor's Office

Insured patients typically expect to make a small co-payment when they see a doctor, and later get billed for anything else they owe. But physicians no longer want to wait for their money.  The Wall Street Journal reported last month reported that medical practices and clinics increasingly are asking people to fork over their entire out-of-pocket charge as they're walking out after a visit. That could include paying amounts a patient owes toward their health plan's deductible and a percentage of the cost of care under a co-insurance requirement.

Patients who are uninsured also are being asked for money upfront, or at least signed up for a payment plan. And physician practices have started demanding patients pay in advance for outpatient surgeries and expensive imaging scans, a practice that certain hospitals have long enforced.  Doctors say they have to request their fees while patients are still at the office because bills sent later typically recover only about half of what a practice is owed.

What is your practice’s front desk collection policy in light of the current economy? Is it time to adjust?

Two-Thirds Don’t Have a Financial Plan

Despite increasing pressure to slash debt and rebuild retirement funds, nearly two-thirds of consumers do not have a written financial plan, according to the 2009 National Consumer Survey on Personal Finance. The survey, released today by the Certified Financial Planner Board of Standards, found that 64% of respondents do not have a written financial plan in place.

But those with a college degree, higher household incomes and more assets to invest are more likely to have one. Of the 284 respondents who have a written financial plan in place, 62% were motivated to have one because of retirement goals and planning. Meanwhile, 48% wanted advice on a broad range of financial matters, 41% were focused on savings goals and planning and 36% were concerned with investment goals and planning. The CFP spoke to 1,742 respondents in total.

Respondents who don’t use a financial planner are hesitant because their pecuniary situation is not complicated enough. Most are confused about what a financial planner does or believe that it’s too expensive to use one.

So take note: It’s important to develop a healthy baseline [financial plan] and not just use it in times of crisis. As the saying goes, people don’t plan to fail, they just fail to plan.

Write out your physician group's retirement policy

With a written plan in place for transitioning into retirement, you'll find it much easier to communicate jointly about that touchy issue. As always, you must consider the group's needs as a whole above the needs of the individual physician. Here are just some of the questions to address in formulating the retirement policy:

• Spacing retirements. If two physicians retire at the same time, it may effectively kill the small- to mid-sized group. If a practice requires no fewer than two years between each physician's retirement, it enables the integration of new doctors.
• Forcing retirement. Sometimes the partner who refuses to retire really needs to retire; for example a partner who doesn't keep up the necessary skill level. Such an issue is a valid reason for forcing a partner into retirement for the good of the group.
• Succession planning. Will you replace the retiring partner with another doctor? A nurse practitioner or physician assistant? Or will a subspecialist now best meet the practice's needs?
• Financial issues. What about accounts receivable for that partner's work? Do they belong to the practice or to him/her? Will you pay them out directly, or as part of the separation agreement? Consider these payout issues long before any retirement occurs.
• Referral patterns. Many senior partners provide their group's major referral sources. Have a plan in place to nurture those referrals so they stay with the practice. The same goes for the retiring doctor's patients-slowly transition them over to other group members.

HIPAA acknowledgments

Reprinted with permission by HcPro. Please check out their premium monthly newsletter Briefings on HIPAA (BOH).

Do HIPAA acknowledgements need to be renewed by patients every year? No. The HIPAA privacy rule requires covered entities to obtain an acknowledgment when they first give their notice of privacy practices to patients. Covered entities do not have to reissue the notice or obtain a new acknowledgment on subsequent visits unless there are material (significant) changes to the notice. If there are significant changes to the notice, the covered entity should provide the new notice to patients as they return for care and obtain a new acknowledgement.

Covered entities that are health plans face an additional requirement every three years to notify individuals covered by the plan of the availability of the notice and how to obtain it.

p.s. I’m headed to Phoenix today to speak at the AICPA National Healthcare Conference. Check out my tweets from the conference at www.twitter.com/rtacpa.

Can a managed care contract really be negotiated or renegotiated?

Absolutely! The problem is that most medical practices don’t even try to negotiate a managed care contract. Most feel it would be a waste of time and resources since it appears managed care companies hold the upper hand most of the time. However, many medical practices will find that they do have hidden negotiation leverage that they don’t realize exists. Perhaps even more surprising for some is that this “hidden” leverage is especially true for smaller medical practices and can result in a measurably more successful contract negotiation.

 

Managed care reimbursement isn’t going to get any better so you better start developing a strategic negotiation strategy to address this issue.

Musings on billing, collection, and profitability

So you’ve got a handle on your accounts receivable (A/R) and you know roughly how long it takes to get paid once you submit a bill. Congratulations — now you’re ready to get started.

 

Getting a handle on your days in A/R is only half the battle. You can’t have any A/R unless you actually bill something. So you need to know how long it takes your practice to bill for services after you provide them. You also need to measure whether you’re billing all the services you provide.

 

That’s why you need to measure your “gross charges,” which are the total amount of money you bill every month. You should be figuring out that number every month and comparing it against the previous year’s number for the same month. If the doctor looks busy, but the charges are going down or are stagnant, you may have a problem. Sometimes this means you’re not billing all the services your doctor provides due to a coding problem.

 

But also, you may not be getting out the charges adequately. A healthy standard is to post all office visits or charges within 24 hours after the date of service, and all other services within five working days. Any practice that can’t get an office visit claim out the next day has something terribly wrong. It’s that simple.

 

Many practices either don’t measure things like days in A/R or gross charges, or else they don’t know what to do with those numbers once they have them.

 

The next thing to track is collections. If your charges are going up but your collections are going down, you need to investigate why (Can you say the word “reimbursement”?). If your practice has declining profitability, don’t succumb to the temptation to cut staff. If anything, this may be a signal that you need to hire an extra person to speed up billing or work on collections. When you start cutting out overhead as a knee jerk reaction to profitability, you are harming the practice. You can nickel and dime overhead but you can’t significantly cut it without harming the practice. The whole focus of management should be how to grow the top line.

 

Create a long-term plan to address the issue of declining profitability by identifying the real issues your practice is facing and creating ways to tackle them — rather than using “Band-Aid solutions.”

Practice costs are the No. 1 worry

Healthcare Finance News reports that the 2009 Medical Group Management Association survey reveals the three top challenges of running a group practice remain the same as in 2008, with money worries at the top.

According to "Medical practice today: What members have to say," the top three concerns are:

1.    Dealing with operating costs that are rising more rapidly than revenues;

2.    Maintaining physician compensation levels in an environment of declining reimbursement; and

3.    Selecting and implementing a new electronic health record.

The organization also asked how the recession is affecting their medical groups and how they are responding. Ranked by average score, the most probable effects of the recession on practices are:

· An increase in uninsured patients;

· Improved billing and collections and/or denial management processes;

· Decreased revenues;

· Postponed capital expenditures;

· Operating budget cuts; and

· Staff hiring freezes.

On the positive side, nearly 82 percent of respondents said there is a zero probability that their group will file for bankruptcy protection, and nearly 80 percent said there is a zero probability their practice will close because of the poor economy.

OIG targeting incident-to billing

In the midst of healthcare reform debates and new HIPAA mandates, the Office of the Inspector General (OIG) has released a new study^* of 'incident to' billing.  This study found that unqualified staff rendered 21% of all procedures and services. Specialties at greatest risk include:

 

ﾷ Ophthalmology

ﾷ Physical medicine and rehabilitation

ﾷ Orthopaedics, particularly those practices that provide physical therapy

ﾷ Cardiology

ﾷ Radiology

ﾷ Any practice that provides diagnostic imaging

ﾷ Any practice that uses nonphysician staff to provide E&M services

As a result of this August 2009 study, OIG and CMS will be working together to scrutinize nonphysician billing and to establish new credentialing guidelines for nonphysician providers.  

 

The Medical Group Management Association is holding a seminar on this subject on September 22^nd; click here for more details:

 

http://www.mgma.com/solutions/landing.aspx?cid=22714&id1=30187&mid=30187&kc=GAMC