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.

November 24, 2014

Simple steps to improve time-of-service collections in your physician office

  1. Be sure to verify insurance before the visit.
  2. Be sure to identify any outstanding balances, the co-pay amount, or a co-insurance/deductible status. If a high dollar procedure is to be performed in the office, figure out patient responsibility.
  3. Advise the patient on the phone or through e-mail via a patient portal of the anticipated amount due at the time of service. Do this at least five days before they arrive for their appointment if possible and verify in detail their method of payment.
  4. Always collect outstanding balances, co-pays and deductibles at check-in and non-covered services and unmet deductibles at check-out.
  5. You must have a clear policy on collecting co-pays and balances on the account at each visit.
    If the balance is large, how much is an acceptable payment if payment in full is not going to be made? Avoid payment plans if at all possible. They do not work.
  6. Reschedule the appointment when patients fail to follow through on their promise of payment (so long as it is medically, ethically and legally permissible).
  7. Reconfigure the front desk with a phone center away from the front desk duties, a meet and greet section, a private Care Share area, and a check¬out station for making follow-up appointments and collecting any other balances that need collecting.
  8. Put the right individuals in the right positions to assure success.

November 21, 2014

"Incident to" and the Initial Visit - Evaluation & Management (E/M) Service Guidelines

The Novitas Solutions Medical Review (MR) Department has observed a continued trend of the utilization of non-physician practitioners to perform initial office visits as "incident to" services. Documentation reviewed by the MR Department indicates that a non-physician practitioner performs the initial visit and the supervising physician documents a note in the medical record similar to the following:

"I have reviewed the Physician Assistant's note, examined the patient and agree with..."
“Nurse practitioner performed the history and physical and I was present for the entire encounter and my treatment plan is as follows……”

This is incorrect use of the non-physician practitioner and incorrect billing under the "incident to" guidelines. This article from Novitas explains the Medicare definition of "incident to" services and the criteria that must be met to properly bill "incident to" services.

An initial history and physical performed by a non-physician practitioner, although the physician is documented as being present or in the office suite and immediately available, is not covered under the "incident to" guidelines. As outlined below, the physician MUST perform the initial service. This includes the history and physical, examination portion of the service, and the treatment plan. It is expected that the physician will perform the initial visit on each new patient to establish the physician-patient relationship.

Novitas Solutions MR (and I'm sure other Medicare Intermediaries) states that it will deny or down code claims for initial office visits billed as "incident to" when a non-physician practitioner performs the initial history and physical .

CMS defines "incident to" services as “services or supplies furnished as an integral, although incidental, part of the physician’s personal professional services in the course of diagnosis or treatment of an injury or illness.”

In order to be covered as "incident to" the physician’s service, the following criteria must be met:

  • Services must be an integral, although incidental, part of the physician’s professional service;
  • Commonly rendered without charge or included in the physician’s bill;
  • Of a type that are commonly furnished in physician’s offices or clinics, and
  • Furnished by the physician or by auxiliary personnel under the physician’s direct supervision

"Incident to" services must be performed under the direct supervision of the physician. CMS directs that “Direct supervision in the office setting does not mean that the physician must be present in the same room with his or her aide. However, the physician must be present in the office suite and immediately available to provide assistance and direction throughout the time the aide is performing services.”

CMS further indicates, under direct supervision, “This does not mean, however, that to be considered "incident to", each occasion of service by auxiliary personnel (or the furnishing of a supply) need also always be the occasion of the actual rendition of a personal professional service by the physician. Such a service or supply could be considered to be "incident to" when furnished during a course of treatment where the physician performs an initial service and subsequent services of a frequency which reflects his/her active participation in and management of the course of treatment.” Hospital and skilled nursing facility services cannot be billed as "incident to" at any time.

For more information and direction on "incident to" services, refer to CMS’ Internet-Only Manual (IOM) Publication 100-02, Chapter 15, Section 60.

November 20, 2014

Are you spending too much time “doing” the work instead of “managing” the work

Are you too busy to take a hard look at your operations to be able to make the changes needed to make the impact your physician practice needs to be really financially and operationally robust?  Are you putting off inevitable decisions because daily routines do not give you the thinking time you need?  Are you keeping a “warm body” on payroll because of the hassle?  Do you know what changes need to be made but don’t have the determination to really make them?

Take a deep breath… are not alone.  Many practice managers suffer from simply being stuck and unable to free themselves from the daily “muck” long enough to take a hard look at practice operations, software needs, employees and financials.  

Too many managers spend too much time “doing” the work instead of “managing” the work.  Here are some hints to help managers who really want to manage better processes instead of fixing the same problems day after day.

  • Define Some Goals – you basically know what they are; you want to decrease AR days, you want to focus on AR greater than 120 days, you want to better train staff on EHR, you want all providers to comply with standards, you want to can Sally, you want to do a better job of front end collections, you want to tell your physician his niece is not working out, you are behind the curve on ICD 10, you want to reduce patient wait times, and many others. Now write them down. Then prioritize them.  That means you need to make time to do this.
  • Do Some Analysis – wait, shouldn’t this come first?  Not necessarily, since you really know what your goals are, you just haven’t formalized them.  What is your business needs to meet the above goals?  What is really keeping you from achieving the goals? What are the external and internal barriers to meeting goals?  Take a really hard look at AR, can you prioritize that work efficiently?  What process needs to be implemented to meet goals?  What will each person’s role be in meeting goals?
  • Plan Implementation – you know what your goals are, you have analyzed what and where changes need to be made to reach goals. Now “plan your work and work your plan.”  Planning is critical, a step by step written down implementation plan is necessary for two reasons.  (1) to keep you focused on the goal (2) to provide a clear pathway to meeting those goals.

The hard work of taking your practice to the next level of excellence requires management commitment, provider by-in and the whole practice focused on results.

Now close your office door, get out some paper and start writing goals…..the process needs your undivided attention to succeed.

November 18, 2014

Good physician practice customer service focuses on these things

In the time it takes you to read this blog, many of your patients will be asked a question about what doctor they use….why they like or dislike.  Do you know what they are saying?  If you don’t then you are not listening.

Expectations are high, patients are smarter, the internet can answer any question they have, and your practice is either effectively managing the healthcare of your patients or they are finding another provider to do so.

There are 5 things your practice should be focused on:

  1. It’s about the patient – have you ever walked into a doctor’s office and they are absorbed in private conversation…..they are sharing a private joke…they are celebrating a staff members birthday or they are just sitting there oblivious?  From the moment the patient calls for an appointment (remember they are calling because they need help) until they get their final bill your focus should be them.  If it isn’t, nothing else you do will matter.
  2. Create an environment that welcomes – Patients are not visiting your practice because they have nothing else to do.  They have carved time out of their busy schedules because they need your expertise.  Welcome them with the décor, the lighting, the efficiency of staff, the minimal wait time, and that free water or cup of coffee.  Little things mean a lot.
  3. Be Prepared – part of the staffs schedule today should be focused on who is coming tomorrow.  What their insurance requirements are, did they have the lab work done, do you have the results, did they receive bad news the last visit and need some extra care, do they have special needs that you are aware of and can help with, is the flow of patients through the office such that they can get in and out with minimal hassle, do they understand what your expectations are of them?
  4. Use your web site to inform and instruct – more and more patients spend time on the internet.  They look up their symptoms, their drugs, and their diagnosis.  Provide answers they are looking for on your web site. Give them the answers you need them to hear on your web site.  Give them clear instructions (written) on how to access web site and patient portal.  Give them a sense that you are concerned about them, their needs, their questions, their concerns.  You can only do that by focusing on them.
  5. Use the EHR efficiently – everyone knows that electronic medical records are the future.  Let them see you using it, speak positively about the benefits, print out for them a visit summary.  They are not interested in excuses or blaming; they simply want to know you are embracing the EHR and it’s to their advantage.  They will understand a learning curve; after all they had one too.  For older patients, ask them about their use of computer, you will be amazed at how many have embraced the technology.

Healthcare delivery is complex, and there are many many components to that delivery.  But if you will focus on these really simple principles, you will find that you have the time and energy to focus on the really hard stuff.