Reed Tinsley, CPA

EHR Incentive Program: 2014 Attestation Deadline for Eligible Professionals February 28

If you are an eligible professional participating in the Medicare Electronic Health Record (EHR) Incentive Program, you have until 11:59 pm ET on February 28, 2015 to attest to demonstrating meaningful use of the data collected during your EHR reporting period for CY 2014. The CMS Attestation System is open and fully operational, and includes the 2014 Certified EHR Technology (CEHRT) Flexibility Rule options. Reminder: You must attest to demonstrating meaningful use every year to receive an incentive and avoid a Medicare payment adjustment. If you are participating in the Medicaid EHR Incentive Program, please refer to your state’s deadlines for attestation information.

Payment Adjustments Payment adjustments were applied beginning January 1, 2015 for Medicare eligible professionals that did not successfully demonstrate meaningful use in 2013 (or 2014 for first-time participants) and did not receive a 2015 hardship exception. Medicare eligible professionals that did not successfully demonstrate meaningful use in 2014 and do not receive a 2016 hardship exception will have payment adjustments applied beginning January 1, 2016. The application period will open in early January 2015. For more information, please review the payment adjustment tipsheet.

Is it "patient" or "customer"

Just read a pretty interesting article about patient vs. customer as the language being used in healthcare but not in any other industry.  The point was made that the word “patient” is now an antiquated term for healthcare consumer and in very real ways, patients are now customers shopping for care.  The origin of the word patient from the Latin means” one who suffers”….or more literally, “I am suffering”.

I can’t resist chiming in with my two cents on this discussion.  Having been a CPA and consultant in the healthcare industry for over 25 years; my first thought is that of the hundreds of physicians I have personally known not much has changed during my years.  Of course technology has revolutionized how physicians document and communicate about and with patients.  It has even changed how some specialties treat patients; but technology has not changed the vast majority of physician motivation.  

What motivates most physicians is two-fold and complex.  It drives their behavior both in and out of the office, hospital, OR, home.  They are driven to find ways to treat disease and eliminate suffering  in humans.  And they would like to make money while doing that.  It’s not that simple nor as easy to define, but for the sake of argument will use it.

I remember a pathologist client I worked for early in my career who while talking on the phone to a surgeon about a frozen section of a tumor, had on hold his stockbroker who was concerned about the diamond mines in South Africa the physician had holdings in.  The pathologist was totally committed to the surgeon who had a patient on the table and would give him nothing less than his very best trained and experienced diagnosis while at the same time talking to his broker.  

To deny that money doesn’t at all motivate physicians would be a mistake. To say money is the only motivator would be a bigger one.  None of us are simply motivated individuals.  Most of us carry dual roles and we call that normal. We are parents, spouses, friends, consumers while at the same time full time in the workforce.  What is different about doctors (at least the ones I have known) is that they are 100% committed to patients while at the same time wearing multiple hats as we all do.  We have never misunderstood why doctors make money in the past. Why do we now?  

Even with the current environment of patients being consumers and of course in many ways customers of healthcare. They are still patients to most of the providers of healthcare and are living better and longer to prove it.

Everyone reading this can immediately think of physicians they have known that they doubt the humanitarian side, so can I, but the vast majority are dedicated to their patients well-being and spend most of their lives ensuring that well-being and keeping suffering at bay.  

As long as there is suffering, I think the term "patient" still applies.

What does value based care really mean?

A new term is making an impression on healthcare…..”Value Based Care”.  What does value based care really mean?

“Healthcare is evolving from a proficiency-based art to a data-driven science, from freelance physicians to hospital-employed physicians, from one-size-fits-all community hospitals to vast hospital networks organized around centers of excellence. As more independent physicians begin to be hired by hospitals, the opportunity for large group practices and hospital consolidation grows. As consolidation expands, data and transparency become increasingly important, as a way to ensure that caregivers across the system are providing comparable care. All of this, of course, leads back to quality, which requires an effort to achieve standardization, reduce variation, and eliminate unpleasant surprises. Its analyzing processes, measuring outcomes, and changing practices until you get it right.”  At least that’s the way the Harvard Business Review has reported.  

The key factors that every practice can take away from the Harvard discussion are”

• More employed physicians
• More data mining for information to re-think medical decision-making
• Practice consolidation with other practices should be realistically considered
• Cost control does not have to mean compromise of patient care
• Providers will be paid less to deliver better care

And therein lays the rub!  How do you convince providers that it is in their interest to provide more cost effective and measurable care for less revenue?

The answer is probably in the age group of the providers.  For new providers, time off can bring value to them and should be considered in employment agreements as part of compensation.  For older providers, early retirement or part-time work is being considered by many of them.  20 years from now, most of the baby boomer providers will be retired and a new population of providers understanding new technology gains, and employment models will be equipped to embrace the Harvard scenario.  Until then, the business of healthcare will struggle with what will give patients better outcomes, reduce cost and continue to define value differently.  The gains will not be achieved through sweeping one time changes in protocols; but in consistent measuring and tweaking processes and changing habits that will bring meaningful change.

Data mining for better outcomes primarily means standardization.  The disparity between treatments among same specialties for very similar patients can be far-reaching.  The same diagnosis, the same patient geography and similar history can mean between $18,000 and $20,000 difference in treatment options.  Finding ways to standardize care through data mining and discovering ways to enhance outcomes based on large volumes of data to analysis will bring the largest gains in cost cutting. Large hospitals are doing this now as they utilize community health exchanges to accumulate data and analyze.

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.

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.

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.

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.

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:  [email protected]
Mail: NPI Enumerator
P.O. Box 6059  
Fargo, ND  58108-6059

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!!

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?