CMS announced today that four additional significant hardship exemptions will allow physicians to be exempt from the 2012 Medicare payment reduction of 1%.
Exemptions will be granted to:
- Eligible professionals who register to participate in the Medicare or Medicaid EHR Incentive Program and adopt certified EHR technology.
- Eligible professionals who are unable to electronically prescribe due to local, state, or federal law or regulation.
- Eligible professionals who have limited prescribing activity.
- Eligible professionals who have insufficient opportunities to report the e-prescribing measure due to limitations of the measures denominator.
As we have previously reported, the Department of Labor is taking important steps in the fight against excessive fees in the retirement plan space. Some service providers in the retirement plan industry are opposed to these regulations, claiming they are unnecessarily burdensome. The opposition of the 408(b)(2) regulation that was scheduled to become effective on July 16, 2011 has now been pushed back to an effective date of January 1, 2012. What does this new regulation mean to you as an employer offering retirement plan benefits to your employees?
What is 408(b)(2)?
408(b)(2) requires retirement plan service providers to disclose comprehensive information about their fees and potential conflicts of interest to you, the plan sponsor. This sounds like a good idea, right? And it seems relatively simple. Service providers must disclose to their clients how much is being received in fees and tell them if they have any conflicts of interest.
As you can imagine, service providers cried wolf saying the Department of Labor did not give them enough time to meet the regulation. Enough time? How much time does it take to take to let plan sponsors know what fees they are paying? The department of labor responded by issuing a statement that said in effect that they recognize service providers may need additional time for compliance.
“We want employers and workers to benefit from the increased transparency provided by these rules as soon as possible,” said Phyllis C. Borzi, assistant labor secretary for employee benefits security. “But we also appreciate that service providers may need more time for compliance efforts, because they have not yet seen a final Employee Retirement Income Security Act Section 408(b)(2) regulation. This action will provide that plan fiduciaries have all required information from service providers before they must disclose information to their workers, ensuring that workers receive accurate information about their retirement plan and investment costs.”
What are the questions to ask about retirement plan fees?
Last week the U.S. Department of Health and Human Services (HHS) announced a new initiative to help improve care for patients while they are in the hospital and after they are discharged. Doctors, hospitals, and other health care providers can now apply to participate in a new program known as the Bundled Payments for Care Improvement initiative (Bundled Payments initiative). Made possible by the Affordable Care Act, it will align payments for services delivered across an episode of care, such as heart bypass or hip replacement, rather than paying for services separately. Bundled payments will give doctors and hospitals new incentives to coordinate care, improve the quality of care and save money for Medicare.
“Patients don’t get care from just one person – it takes a team, and this initiative will help ensure the team is working together,” said HHS Secretary Kathleen Sebelius. “The Bundled Payments initiative will encourage doctors, nurses and specialists to coordinate care. It is a key part of our efforts to give patients better health, better care, and lower costs.
Payment bundling is the future
In Medicare currently, hospitals, physicians and other clinicians who provide care for beneficiaries bill and are paid separately for their services. This Centers for Medicare & Medicaid Services (CMS) initiative will bundle care for a package of services patients receive to treat a specific medical condition during a single hospital stay and/or recovery from that stay this is known as an episode of care. By bundling payment across providers for multiple services, providers will have a greater incentive to coordinate and ensure continuity of care across settings, resulting in better care for patients. Better coordinated care can reduce unnecessary duplication of services, reduce preventable medical errors, help patients heal without harm, and lower costs.
The Bundled Payments initiative is being launched by the new Center for Medicare and Medicaid Innovation (Innovation Center), which was created by the Affordable Care Act to carry out the critical task of finding new and better ways to provide and pay for health care to a growing population of Medicare and Medicaid beneficiaries.
Four bundled payment models
Released today, the Innovation Centers Request for Applications (RFA) outlines four broad approaches to bundled payments. Providers will have flexibility to determine which episodes of care and which services will be bundled together. By giving providers the flexibility to determine which model of bundled payments works best for them, it will be easier for providers of different sizes and readiness to participate in this initiative.
In a traditional healthcare setting, the revenue cycle begins with the insurance companies who pay the majority of the bill. There are multitudes of payers and each payer can have many plans. How can a healthcare organization catalog this information, keep this information updated and make this information easily accessible to staff so they can discuss payments with patients in an informed and confident way?
Start by breaking your payers into five main categories as a logical way to organize the data.
- Payers with whom you have a contract
- Payers with whom you do not have a contract
- State and Federal government payers (Medicare, Medicaid, TriCare)
- Medicare Advantage payers
- Patients
Payers with whom you have a contract
Your organization has signed a contract with a payer and you have agreed to accept a discounted fee called an allowable, and to abide by their rules. What is the information you need to collect?
- A copy of the contract
- A detailed fee schedule, or a basis for the fees, such as 150% of the 2008 Medicare fee schedule.
- Any information about the fees being increased periodically based on economic indicators, or rules (notification, timeline, appeals) on how the payer can change the fee schedule.
- The process and a contact name for appealing incorrect payments.
- Information on what can be collected at time of service. Hopefully your contract does not have any language that prohibits collections at time of service, but you must know what the contract states.
- Process for checking on patients eligibility and benefits: representative by phone, interactive voice response (IVR), website or third-party access.
The US Office of Management and Budget recently approved changes to the Medicare Provider-Supplier Enrollment Applications (CMS-855) in order to update them from the 2008 versions, as well as the new CMS-855O application form used for the sole purpose of enrolling to order and refer items and/or services to Medicare beneficiaries. The revised and new forms are now available on the CMS Provider-Supplier website here.
Providers and suppliers enrolling for the sole purpose to order and refer are required to begin using the new CMS-855O form immediately. Providers and suppliers using the other CMS-855 forms to enroll in Medicare are encouraged to begin using the revised forms, though may continue to use the old forms through October 2011.
All of us have a lot of information to process in our daily lives. Information is readily available – almost too readily available – and healthcare is exploding with information that must be read, processed, prioritized, and sometimes filed for future reference.
During the course of the day, I typically skim, read and sometimes participate in:
- Google News (and sometimes Fast Flip)
- Google+
- Listserv email
- Business and personal email
Yikes! It is so easy to spend a hours consuming new information every day and still feel that youve missed something. So how does a manager stay current without spending the entire day reading and organize information so you can find it when you want it?
In recent announcements and materials, CMS incorrectly included chiropractors in the list of physician and practitioner types that may order and refer items or services to Medicare beneficiaries. In accordance with section 1877(a)(1) and (5)(A), and section 1861(r)(5) of the Social Security Act, and 42 CFR 410.21(b)(1) and (2), doctors of chiropractic medicine are not eligible to order and refer. Medicare coverage extends only to treatment by means of manual manipulation of the spine to correct a subluxation; all other services furnished or ordered by chiropractors are not covered.
CMS is in the process of revising documents (including change requests) to reflect this correction.
Note: This article was first published as PM, EMR and Portals: A Primer on Healthcare-specific Software for Ambulatory Care on Technorati.
Few industries are currently changing as much as the US healthcare system. While many perspectives and ideas are shaping the debate on how to change the system to meet current and future demands, most believe that technology can and will have a huge positive impact on the ability of the industry to deliver quality care in a cost-effective way. Network technologies that can support the ubiquitous exchange of health information in a secure, efficient and collaborative environment hold the potential to streamline and modernize the current system to maximize resources and positive patient outcomes.
The opportunities for improvement have generated a lot of buzz in both the private and public sectors, and incentivizing adoption of Healthcare Information Technology (HIT) through the American Recovery and Reinvestment Act of 2009 (the ARRA or Stimulus bill) has led to considerable interest in an industry often known for lagging behind in the adoption of new technologies.
For many, the healthcare-specific technical jargon and operational knowledge of how healthcare works can be as complex as the products themselves. Here then are descriptions of the three types of medical software used by ambulatory care providers.
Practice Management (or PM) Software
Practice Management (or PM) software has been in wide use in the healthcare industry for almost three decades. Its primary use is the collection of patient demographics, patient insurance detail and the healthcare services and related diagnoses provided. This information is formatted to conform to payer requirements and is submitted electronically to request reimbursement for services. PM software also manages the responses from the payers in electronic format and invoices any balance to the patient in the form of printed and mailed statements. PM systems can be all-encompassing in functionality or can be a la carte in modules.
While there are multiple levels of laboratory complexity, it is possible to have a lab in your practice with very little fuss and administrative burden. The level of complexity of any lab is determined by the testing being performed, and the complexity level of each test or test system is assigned by the FDA.
What is Waived Testing?
The Waived category allows physicians to do simple testing in their offices to facilitate diagnosis and enhance patient care with on-the-spot results. A test or test kit gets classified as Waived if it:
- is extremely easy to perform
- has built-in safeguards, and
- requires little education or training to do and interpret correctly.
Urine dipsticks, rapid Strep A kits, urine pregnancy test kits, and rapid Mono Test kits are examples of waived tests. In addition, there are also some Point of Care (POC or POCT) tests/instruments that have been granted waived status, including glucose monitors and hemoglobin instruments. There is a wide variety of testing available to the practitioner without having to bear the administrative burdens of the moderate or high complexity laboratory.
Of the various types of laboratories defined, the Waived lab has the least regulatory oversight. CLIA does not have personnel requirements for Waived labs other than requiring there be a lab director, which any physician in the practice can fulfill. It is common for the lab director to receive a monthly stipend of $300 – $500 per month for fulfilling this simple role.
The only regulations that apply to waived testing are:
- requirement to have a CLIA ID # and pay the Certificate Fee every two years, and
- to follow the manufacturers instructions for any test performed.
Announcement from CMS:
All providers and suppliers who enrolled in the Medicare program prior to Friday, March 25, 2011, will be required to revalidate their enrollment under new risk screening criteria required by the Affordable Care Act (section 6401a). Providers/suppliers who enrolled on or after Friday, March 25, 2011 have already been subject to this screening, and need not revalidate at this time.
New Screening Criteria
In the continued effort to reduce fraud, waste, and abuse, CMS implemented new screening criteria to the Medicare provider/supplier enrollment process beginning in March 2011. Newly-enrolling and revalidating providers and suppliers are placed in one of three screening categories limited, moderate, or high each representing the level of risk to the Medicare program for the particular category of provider/supplier, and determining the degree of screening to be performed by the Medicare Administrative Contractor (MAC) processing the enrollment application. More information on the screening categories is here.
Notices Will Be Sent to Providers/Suppliers
Between now and March 2013, MACs will be sending notices to individual providers/suppliers; please begin the revalidation process as soon as you hear from your MAC. Upon receipt of the revalidation request, providers and suppliers have 60 days from the date of the letter to submit complete enrollment forms. Failure to submit the enrollment forms as requested may result in the deactivation of your Medicare billing privileges. The easiest and quickest way to revalidate your enrollment information is by using Internet-based PECOS (Provider Enrollment, Chain, and Ownership System), at https://pecos.CMS.hhs.gov.
Fees Levied
Section 6401a of the Affordable Care Act requires institutional providers and suppliers to pay an application fee when enrolling or revalidating (institutional provider includes any provider or supplier that submits a paper Medicare enrollment application using the CMS-855A; CMS-855B, not including physician and non-physician practitioner organizations; CMS-855S; or associated Internet-based PECOS enrollment applications); these fees may be paid via www.Pay.gov.
In order to reduce the burden on the provider, CMS is working to develop innovative technologies and streamlined enrollment processes including Internet-based PECOS. Updates will continue to be shared with the provider community as these efforts progress.
For more information about provider revalidation, review the Medicare Learning Networks Special Edition Article #SE1126, titled Further Details on the Revalidation of Provider Enrollment Information.
