Reed Tinsley, CPA

Office manager embezzles from Texas physician office

In Texas, a 28-year-old woman has been charged with felony theft after police say she stole nearly $60,000 over several months at the doctor’s office where she was once employed as its office manager.

According to the arrest affidavit, the office manager between May 2010 and Nov. 2011 used a credit card meant for medical practice purchases on personal expenses, racking up about $16,000 in charges, the affidavit said. The abuse of the credit card was discovered in November, and the office manager was immediately fired, the affidavit said.

When a new office manager took over, she discovered the fired office manager siphoned money from the paychecks of a doctor and three employees intended for 401(k) retirement accounts. Those thefts totaled over $40,000. The physician owner repaid the employees’ 401(k) funds out of his own pocket.

My question to you is: How good are your internal controls? I believe there is a lot of embezzling going on within physician practices and it's not getting caught.

10 requirements of the perfect (physician practice) manager

Jamie over at (e)merge (http://emergewithus.com/) turned me on to this list at TechRepublic - review it - how many of these traits do you or your practice admininstrator possess?

1. Be a “people person”

2. Be visionary

3. Be a good communicator

4. Be technically proficient

5. Put your employees’ needs first

6. Encourage teamwork

7. Lead by example

8. Treat your staff like professionals

9. Encourage professional growth

10. Do something special

Satisfying all the above criteria is not enough. You are also required to do something special for your employees that:

Will be remembered fondly decades from now.
Can be shared by the entire group.
Won’t break the budget.

To read commentary to each of these traits, go to

http://m.techrepublic.com/blog/10things/10-requirements-of-the-perfect-manager/3157

The most common coding abuses by a physician practice

I was watching a special on CNBC about healthcare fraud and it reminded me again about the most common coding abuses by physicians and their billing staff. Compliance in coding and documentation are crucial in today's enforcement enviroment. Don't get yourself in trouble by being ignorant or complacent:

Upcoding Billing using a more expensive code that the service or item that was actually provided.

Unbundling Billing separately for services that are properly grouped together in a global code.

Lack of Medical Necessity Billing items or services to patients that they do not need.

Billing for Services Not Rendered Billing something that was not actually provided to the patient.

Billing for Worthless Services Billing for items or services that are of such low quality as to render them virtually worthless.

Duplicate Billing Billing two or more times for the same item or service.

Lack of Documentation The medical record cannot support the claim.

27 ACOs began work April 1

CMS's 27 Shared Savings Program ACOs, which began on April 1, will serve an estimated 375,000 beneficiaries in 18 states. The group has collectively more than 10,000 physicians, 10 hospitals and 13 physician-driven organizations.

21 of the 27 ACOs are physician-run. The American Medical Association also noted that five of the approved groups will participate under an advance payment model, which provides up-front funding from Medicare to cover the costs of establishing the infrastructure needed to coordinate patient care. Only two of the 27 approved ACOs agreed to be held accountable for a share of any losses if Medicare costs for the patients receiving coordinated care exceed projections. The rest of the groups will not be exposed to possible penalties, but they will be eligible for a lower share of potential savings compared with the two ACOs exposed to risk.

Under the current model, which is different from the true capitation model, it will be interesting to see if savings can really be achieved. I'm personally skeptical. We'll just have to wait and see on this one.

For details about the 27 ACOs, check out this link

http://www.vcpi.com/Portals/96686/docs/ACO%20-%20selected%20for%20start%20up%204-1-12.pdf

Physician practice gets into HIPAA hot water

Phoenix Cardiac Surgery, P.C., of Phoenix and Prescott, Arizona, has agreed to pay the U.S. Department of Health and Human Services (HHS) a $100,000 settlement and take corrective action to implement policies and procedures to safeguard the protected health information of its patients.

The settlement with the physician practice follows an extensive investigation by the HHS Office for Civil Rights (OCR) for potential violations of the Health Insurance Portability and Accountability Act of 1996 (HIPAA) Privacy and Security Rules.

The incident giving rise to OCR’s investigation was a report that the physician practice was posting clinical and surgical appointments for its patients on an Internet-based calendar that was publicly accessible. On further investigation, OCR found that Phoenix Cardiac Surgery had implemented few policies and procedures to comply with the HIPAA Privacy and Security Rules, and had limited safeguards in place to protect patients’ electronic protected health information (ePHI).

“This case is significant because it highlights a multi-year, continuing failure on the part of this provider to comply with the requirements of the Privacy and Security Rules,” said Leon Rodriguez, director of OCR. “We hope that health care providers pay careful attention to this resolution agreement and understand that the HIPAA Privacy and Security Rules have been in place for many years, and OCR expects full compliance no matter the size of a covered entity.”

OCR’s investigation also revealed the following issues:

• Phoenix Cardiac Surgery failed to implement adequate policies and procedures to appropriately safeguard patient information;
• Phoenix Cardiac Surgery failed to document that it trained any employees on its policies and procedures on the Privacy and Security Rules;
• Phoenix Cardiac Surgery failed to identify a security official and conduct a risk analysis; and
• Phoenix Cardiac Surgery failed to obtain business associate agreements with Internet-based email and calendar services where the provision of the service included storage of and access to its ePHI.

Under the HHS resolution agreement, Phoenix Cardiac Surgery has agreed to pay a $100,000 settlement amount and a corrective action plan that includes a review of recently developed policies and other actions taken to come into full compliance with the Privacy and Security Rules.

Medicare moves to tie doctors’ pay to quality and cost of care

Interesting article in the Washington Post - can Medicare really move this way? I doubt it - very hard to make an elephant dance.

http://www.washingtonpost.com/national/health-science/medicare-moves-to-tie-doctors-pay-to-quality-and-cost-of-care/2012/04/14/gIQAFq3IIT_story.html?wpisrc=nl_headlines

Medicare moves to tie doctors’ pay to quality and cost of care

Interesting article in the Washington Post - can Medicare really move this way? I doubt it - very hard to make an elephant dance.

http://www.washingtonpost.com/national/health-science/medicare-moves-to-tie-doctors-pay-to-quality-and-cost-of-care/2012/04/14/gIQAFq3IIT_story.html?wpisrc=nl_headlines

National Practitioner Data Bank reporting requirements

The National Practitioner Data Bank (NPDB) is an electronic repository of all payments made on behalf of physicians in connection with medical liability settlements or judgments as well as adverse peer review actions against licenses, clinical privileges, and professional society memberships of physicians and other health care practitioners.

The NPDB collects and disseminates certain information, including:

- Professional liability payments made on behalf of a physician or other health care practitioners.

- Adverse action reports based on a physician or other health care practitioner’s professional competence or conduct that adversely affects privileges for more than 30 days. These actions include reducing, restricting, suspending, revoking, or denying privileges, and also include an entity's decision not to renew a physician's or other health care professional’s privileges if the decision was based on competence or professional misconduct. It also includes voluntary surrender of license or restriction of privileges either while under investigation or in lieu of an investigation.

- Voluntary surrenders relating to retirement, nonpayment of licensure renewal fees, and change to inactive status, if there is not an investigation in progress, are not reportable.

- Disciplinary actions related to competence or professional misconduct taken against a physician's license, including revocation, suspension, censure, reprimand, probation, and licensure surrender.

- Professional society review actions taken for reasons related to competence or professional misconduct that adversely affect membership in the professional society.

- Medicare and Medicaid exclusion reports containing sanctions against a practitioner from the Medicare program or the Medicaid program due to fraud and abuse.

A complete list of reportable information is maintained in the NPDB.

http://www.ama-assn.org/resources/doc/washington/npdb-hipdb-comparison-chart.pdf

Any quick and simple way to reduce payment denials?

Consider the following:

1. Flag all denied charges, usually my making a copy of the related EOBs and placing them in a manilla folder.

2. Hold a staff meeting of the billing and collection personnel either twice a month or at a minimum, once a month. You should discuss these denials, why they occurred, and how to make sure they don’t happen in the future.

3. Communicate the resolutions to the appropriate individuals. This could include front desk personnel and even the physicians. For example, maybe a denial is occurring because the physician is filling out the patient charge ticket incorrectly

Don't Ignore These Special Insurance Coverages For Your Medical Practice

These five comparatively unknown insurance coverages can save you thousands (or more) of dollars. And they aren't very expensive.

Almost everyone recognizes the need for certain basic kinds of insurance protection like automobile, fire and malpractice. Many doctors, though, overlook other coverages that may be just as important. Here are five kinds you should check.

1. Accounts Receivable Insurance. This is basically fire insurance extending to the value of your receivables. If a fire wipes out your financial ledger cards or your computer data (unless you have back-up stored elsewhere), the coverage is a godsend.

2. Business Interruption Policy. Basic fire insurance does not compensate you for lost income after a burnout leaves you with no office in which to practice. We know doctors who were financially rescued by a special business interruption policy covering this loss until they could work in temporary quarters.

3. Non-Owner Auto Coverage. When a staff member drives a personal car on practice business to the hospital, for instance you may be liable for any damages suffered in an accident. With an inexpensive rider to your auto or general liability policy your
practice can avoid potentially huge losses above your employee's personal auto coverage.

4. Excess Liability Policy. Most auto home-owners and office liability policies have a maximum exposure of $100,000 or $200,000 per incident. Lawsuits these days often involve claims running into seven digits. A relatively inexpensive "umbrella" policy adds
$1,000,000, $2,000,000 or more of protection on top of your normal policies.

5. Fidelity Bond. Embezzlement occurs far more often than doctors like to believe. If it happens to you, the odds of recovering upon discovery are slim. A fidelity bond covering employees handling finances helps you recoup the loss. It's also helpful because the insurer handles dealing with the wrongdoer.