Manage My Practice

Per the excellent live coverage at SCOTUSBlog of the Supreme Court’s decision in the constitutional challenge to the Affordable Care Act,

The bottom line: the entire ACA is upheld, with the exception that the federal government’s power to terminate states’ Medicaid funds is narrowly read.

The reporters had quick access to physical copies of the opinion, and found the explanation of the Mandate Status in the majority opinion.

“Our precedent demonstrates that Congress had the power to impose the exaction in Section 5000A under the taxing power, and that Section 5000A need not be read to do more than impose a tax. This is sufficient to sustain it. “

Updates, with links to the full opinions, to follow.

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There is plenty of confusion surrounding the rules for using a locum tenens. This video will set the record straight.

Medicare has so many programs that have the potential to increase or decrease your payments that practices need a list to keep them straight.

Here’s your list with information on which programs are mutually exclusive and which can be combined.

1. Electronic Health Records (EHR) Incentive Program

• You must be an eligible provider to participate.
• You must be the owner of the EHR, although you do not need to have paid for the EHR.
• The EHR must be certified.
• You can choose to participate in Medicare (federally administered) or Medicaid (state administered) program.
• You must register for the programs.
• You must attest or document that you have adopted, implemented, upgraded or demonstrate meaningful use.
• Eligible professionals choosing to participate the Medicare program can each earn up to $44K over 5 years, and eligible professionals choosing to participate in the Medicaid program can each earn up to $63,750 over 6 years.

2. ePrescribing Incentive Program

• Eligible professionals do not need to register for the program.
• You can participate in one of three ways: via submitting codes on claim forms, via an EHR or via a registry
• Each professional needs to report 10 eRx events for Medicare patients for dates of service before June 30, 2012 OR apply for one of five exclusions or four exemptions.
• EPs who are successful e-prescribers can qualify to earn an incentive payment based on a percentage of their total estimated Medicare PFS allowed charges processed not later than 2 months after the end of the reporting period. For reporting year 2012, EPs who are successful e-prescribers can qualify to earn an incentive payment equal to 1.0 percent of allowed charges. For reporting year 2013, EPs can qualify to earn an incentive payment of 0.5 percent of allowed charges. Beginning in 2012, EPs who are not successful e-prescribers in 2011 and do not qualify for a hardship exception will be subject to a payment adjustment equal to 1.0 percent of their Medicare PFS allowed charges. The payment adjustment increases to 1.5 percent in 2013 and 2.0 percent in 2014.

3. PQRS (Physician Quality Reporting System)

• Originally called PQRI (Physician Quality Reporting Initiative) is the basis for pay-for-performance models.
• Physicians may report individually or practices may choose a set of three measures that relate to the type of patients they see. Measures are performed and modifiers are attached to claims.
• Bonuses are available until 2014; starting in 2015 practices not participating in PQRS will receive a negative payment adjustment.
• For reporting years 2012 through 2014, EPs who satisfactorily report Physician Quality Reporting System measures will earn an incentive payment equal to 0.5 percent of allowed charges. Additionally, for reporting years 2011 through 2014, EPs who satisfactorily report Physician Quality Reporting System measures can qualify to earn an additional 0.5 percent incentive payment by, more frequently than is required to qualify for or maintain board certification status, participating in a maintenance of certification program and successfully completing a qualified maintenance of certification program practice assessment. Beginning in 2015, EPs who do not satisfactorily report under the Physician Quality Reporting System will be subject to a payment adjustment equal to 1.5 percent of their Medicare PFS allowed charges. The payment adjustment increases to 2.0 percent in 2016 and beyond.

4. Medicare Wellness Visits

• Many practices are losing money due to the confusion over what Medicare pays for and what Medicare doesn’t pay for. Medicare introduced three new visits in 2010 and many providers continue to have trouble understanding and providing them correctly.
• The “Welcome to Medicare” visit is technically called the “Initial Patient Physical Examination” (IPPE), but to everyone’s dismay, it is not a physical examination at all, with the exception of basic visits such as height, weight, BMI, blood pressure and pulse, and the potential for an EKG and an Abdominal Aortic Aneurysm screening. The Annual Wellness Visit (AWV) and the Subsequent Annual Wellness Visit are not physical examinations either, yet almost ALL patients believe that Medicare now gives free annual physicals.
• Practices must train all staff and physicians to use the correct terminology first. I suggest everyone stop using the phrases “annual physical” or “complete physical” with Medicare patients. Patients can request and receive:
  • A Welcome to Medicare Visit with no exam (no deductible, no co-insurance)
  • A first annual Wellness Visit with no exam (no deductible, no co-insurance)
  • A Subsequent Annual Wellness Visit with no exam every year thereafter (no deductible, no co-insurance)
• What patients think they want is either a preventive visit, which Medicare will NOT pay for, or a standard Evaluation & Management (E/M) visit, which their deductible and co-insurance will apply to.
• The only way the practice can win is by driving home to patients what Medicare does pay for and doesn’t pay for and making sure your documentation matches the code you submit to Medicare.

5. The ABN (Advance Beneficiary Notice)

• Many practices miss revenue when they provide services to Medicare patients that are statutorily excluded from Medicare benefits.
• These may be services that do not meet the Medicare definition of medical necessity or are provided at more frequent intervals than Medicare approves.
• Identifying these non-covered services is the hard thing, however, unless your EMR can alert you to a service that will not be paid by Medicare, and if the patient requests the service and signs an ABN prior to the provision of the service In this case, the practice may collect the full fee from the patient.

6. Primary Care Incentive Payment Program (PCIP)

• Eligible Providers (Clinical Nurse Specialists, Nurse Practitioners, Physician Assistants, and Physicians who have their primary specialty designation in family medicine, internal medicine, geriatric medicine or pediatric medicine) can receive a 10% incentive payment for services under Part B.
• The PCIP program, which was created by the Patient Protection and Affordable Care Act, requires Medicare to pay primary care providers, whose primary care billings comprise at least 60 percent of their total Medicare allowed charges, a quarterly 10-percent bonus from Jan. 1, 2011, until the end of December 2015.
• Eligible primary care physicians furnishing a primary care service in a Health Professional Shortage Area (HPSA) area may receive both a HPSA and a PCIP payment.

7. HPSA (Health Professional Shortage Area)

• Medicare makes bonus payments annually of 10% to physicians who provide medical care services in geographic areas that lack sufficient health care providers to meet the needs of the population.
• Payments are automatic; there is no need to register or report anything on the claim for
• If services are provided in ZIP code areas that do not fall entirely within a full county HPSA or partial county HPSA, the AQ modifier must be entered on the claim to receive the bonus.

8. HPSA (Health Professional Shortage Area ) Surgical Incentive Payment (HSIP)

• The Affordable Care Act of 2010, Section 5501 (b)(4) expands bonus payments for general surgeons in HPSAs. Effective January 1, 2011 through December 31, 2015, physicians serving in designated HPSAs will receive an additional 10% bonus for major surgical procedures with a 10 or 90 day global period.
• Payments are automatic; there is no need to register or report anything on the claim form.
• If services are provided in ZIP code areas that do not fall entirely within a full county HPSA or partial county HPSA, the AQ modifier must be entered on the claim to receive the bonus.

9. NEW! Comprehensive Primary Care Initiative (CPCi)

• Payment model per beneficiary per month (PBPM) for care management of Medicaid and Medicare patients
• Markets in Arkansas, Colorado, New jersey, New York, Ohio/Kentucky, Oklahoma and Oregon for Medicaid patients
• Arkansas, Colorado, Ohio and Oregon are the four states for Medicaid pilots.
• Multiple payers, including CMS, will be paying a monthly care management fee to support the 5 primary care functions of:
  • Risk-stratified care management
  • Access and continuity
  • Planned care for chronic care & preventive care
  • Patient & caregiver engagement
  • Coordination of care across the medical neighborhood
• Primary care practices in the states and markets can apply from June 15 to July 20, 2012 (application here.)

What Medicare Bonus or Incentive Programs Can Be Claimed Together?

• PQRS can claimed with eRx.
• PQRS can be claimed with EHR.
• HPSA and PCIP are automatic and are not affected by any other programs
• EHR and eRx can both be claimed but you cannot earn both an eRx incentive and an EHR incentive in the same year if you elect to receive the EHR incentive payment through Medicare. NOTE: Just because you cannot claim the eRx bonus in conjunction with EHR incentive, you must still continue to ePrescribe to avoid the eRx penalty!

• Only 8 Days Left to Apply for a 2013 ePrescribing Exemption: Will You Face a 1.5% Adjustment? (jump to story)

• Register Now: CMS National Provider Call on Certified EHR Technology (jump to story)

• Two New CME Modules on Medscape: Fraud and Abuse (jump to story)

If You Are Not Currently ePrescribing, and Have Not Applied for a Hardship Exemption, You Have Until July 1st, 2012 to Do So

Reminder from CMS. All Emphasis Mine.

The 2013 eRx payment adjustment only applies to certain individual eligible professionals. CMS will automatically exclude those individual eligible professionals who meet the following criteria:

• The eligible professional is a successful electronic prescriber during the 2011 eRx 12- month reporting period (January 1, 2011 through December 31, 2011).
• The eligible professional is not an MD, DO, podiatrist, Nurse Practitioner, or Physician Assistant by June 30, 2012, based on primary taxonomy code in the National Plan and Provider Enumeration System (NPPES).
• The eligible professional does not have at least 100 Medicare Physician Fee Schedule (MPFS) cases containing an encounter code in the measures denominator for dates of service from January 1, 2012 through June 30, 2012.
• The eligible professional does not have 10% or more of their MPFS allowable charges (per TIN) for encounter codes in the measures denominator for dates of service from January 1, 2012 through June 30, 2012.
• The eligible professional does not have prescribing privileges and reported G8644 on a billable Medicare Part B service at least once on a claim between January 1, 2012 and June 30, 2012.

Avoiding the 2013 eRx Payment Adjustment

Individual eligible professionals and CMS-selected group practices participating in eRx GPRO who were not successful electronic prescribers in 2011 can avoid the 2013 eRx payment adjustment by meeting the specified reporting requirements between January 1 and June 30, 2012.

6-month Reporting Requirements to Avoid the 2013 Payment Adjustment:

• Individual Eligible Professionals 10 eRx events via claims
• Small eRx GPRO 625 eRx events via claims
• Large eRx GPRO 2,500 eRx events via claims

For more information on individual and eRx GPRO reporting requirements, please see the MLN Article SE1206 – 2012 Electronic Prescribing (eRx) Incentive Program: Future Payment Adjustments.

CMS may exempt individual eligible professionals and group practices participating in eRx GPRO from the 2013 eRx payment adjustment if it is determined that compliance with the requirements for becoming a successful electronic prescriber would result in a significant hardship.

Significant Hardships

The significant hardship categories are as follows:

• The eligible professional is unable to electronically prescribe due to local, state, or federal law, or regulation
• The eligible professional has or will prescribe fewer than 100 prescriptions during a 6-month reporting period (January 1 through June 30, 2012)
• The eligible professional practices in a rural area without sufficient high-speed Internet access (G8642)
• The eligible professional practices in an area without sufficient available pharmacies for electronic prescribing (G8643)

Submitting a Significant Hardship Code or Request

To request a significant hardship, individual eligible professionals and group practices participating in eRx GPRO must submit their significant hardship exemption requests through theQuality Reporting Communication Support Page (Communication Support Page) on or between March 1 and June 30, 2012.Please remember that CMS will review these requests on a case-by-case basis.All decisions on significant hardship exemption requests will be final.

Significant hardships associated with a G-code may be submitted via the Communication Support Page or on at least one claim during the 2013 eRx payment adjustment reporting period (January 1 through June 30, 2012). If submitting a significant hardship G-code via claims, it is not necessary to request the same hardship through the Communication Support Page.

For more information on how to navigate the Communication Support Page, please reference the following documents:

• Quality Reporting Communication Support Page User Guide
• Tips for Using the Quality Reporting Communication Support Page

For additional information and resources, please visit the E-Prescribing Incentive Program web page.

If you have questions regarding the eRx Incentive Program, eRx payment adjustments, or need assistance submitting a hardship exemption request, please contact the QualityNet Help Desk at 866-288-8912 (TTY 877-715-6222) or via qnetsupport@sdps.org. They are available Monday through Friday from 7am to 7pm CST.

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Registration Open for National Provider Call on Certified EHR Technology

If you are feeling “a little lost” about switching from a paper record, Meaningful Use, and choosing an EHR to get you started, this is the national provider call for you!

Wednesday, June 27; 2-3:30pm ET

Join CMS and the Office of the National Coordinator for Health Information Technology (ONC) for a National Provider Call providing an overview of the use of certified EHR technology to meet meaningful use. Learn about the different types of certification and what certification actually tests. As of April 30, over $5 billion has been paid in EHR incentives under both programs. This is the last year Medicare eligible professionals can begin to participate to earn the full Medicare Electronic Health Record (EHR) incentive payments.

Target Audience: Eligible Professionals and Eligible Hospitals as defined by the Medicare and Medicaid EHR Incentive Programs.

Agenda:

• Overview of Meaningful Use
• How and Why of Certification
• Which EHR Products are Certified
• Resources
• Q&A with CMS and ONC experts

Registration Information: In order to receive call-in information, you must register for the call on the CMS Upcoming National Provider Calls web page.Registration will close at 12pm on the day of the call or when available space has been filled; no exceptions will be made, so please register early.

Presentation: The presentation for this call will be posted prior to the call on the FFS National Provider Calls web page. In addition, a link to the slide presentation will be emailed to all registrants on the day of the call.

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Two New CME Modules Now Available on Medscape on Fraud and Abuse

In early June, Medscape postedtwo new CME modules entitled, “Reducing Medicare and Medicaid Fraud and Abuse: Protecting Practices and Patients” and “How CMS Is Fighting Fraud: Major Program Integrity Initiatives.” These modules highlight efforts by CMS to fight fraud and abuse and how health care professionals can be part of those efforts.

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As the “12 Ways to Supercharge Your Practice for 2012″ series comes to a close, Manage My Practice introduces a new series, the The Manager’s Minute in video format. These short videos provide bite-sized information on a wide array of topics and take about one minute to watch!

If you have a topic you’d like us to cover during an episode of The Manager’s Minute, leave us a suggestion in the comments!

What’s your website doing for your practice?

If your website is providing information to future and current patients, that’s a good thing.

More importantly, though, your website should be

1. Driving new patients to the practice.
2. Driving established patients to return to the practice.
3. Keeping patients attached to you as their provider.

Your website should be providing B2C (business to consumer) marketing for you. How does a website accomplish these things? In a web search, being the first or one of the first unpaid results that appears in the search is the way to ensure searchers find your practice. The way to get to page one, even number one on page one, is through SEO.

SEO stands for Search Engine Optimization.

Search Engine Optimization is the way you market your practice on the internet so that you show up in internet searches as high on page one of a search as possible. Wikipedia defines SEO as

the process of improving the visibility of a website or a web page in a search engine’s “natural,” or un-paid (“organic” or “algorithmic”), search results.

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We are very excited today to announce two new products available for purchase in the Manage My Practice store!

We have had a lot of requests for the recorded version of our Webcourse – Creating a Credit Card on File Program in Your Practice, and we are excited to say that it is now available! For $29.95 you will receive the 60 minute video recording of the course, as well as the course slide deck, and the action pack of handouts to get you started on the program including:

1. Worksheet for Credit Card on File Program Return on Investment
2. Staff Script & Role Playing Suggestions for Staff Training
3. Sample Security Policy to Comply With PCI Guidelines
4. Credit Card on File Program Timeline Worksheet
5. Credit Card Program Comparison Worksheet
6. Patient Handout #1: Information About Our Credit Card on File Program & Discontinuation of Statements
7. Patient Handout #2: What is a Deductible and How Does It Affect Me?

Check out the Webcourse!

We are also very excited to be adding a second book to our store: Heart and Soul in the Boardroom by Bob Cooper. We have been thrilled to reprint some of Bob’s great posts about leadership, and are now honored to sell his book. Heart and Soul in the Boardroom is a book that champions honesty, authenticity, and a management style based on a real assessment of success – both in the workplace, and in the workplace’s relationship to your life.

Get Bob’s Book for $14.50 plus 2.95 shipping and handling. And if you are buying for a group (or department, or your staff!) Bob will ship them free with the purchase of three or more!

Check out Bob Cooper’s Book!

Any time I ask a practice about their pain points, they invariably name “the phones” as one of their toughest problems to solve. Phone calls are escalating as many patients are trying to avoid going to the doctor. That means instead of making an appointment, patients are calling hoping to be given advice or a prescription over the phone.

Staffing up to answer the phones is rarely an option for most practices. In many cases, there is no compensation for healthcare via the phone, therefore adding more staff for no additional compensation is not tenable. This is just one example where the physician is feeling the bite of having to pay more for a practice that produces less income.

There is no best practice for number of phone receptionists to number of physicians and non-physician providers. Every practice is different based on the specialty, the practice culture and staffing structure.

When the problem is the phones, the issue is complex. Doing a poor job of answering the phones not only causes patient dissatisfaction, it snowballs as patients call back again looking for answers, causing confusion and inefficiency. Poor phone management also has the potential to compromise care if a patient’s question goes unanswered.

Where do you start to tackle the problem with the phones?

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• Starting July 1, 2012, Medicare Fee For Service Will Reject 4010 Transactions: Are You Ready? plus How to Avoid Common 5010 Rejections (jump to story)

• Are You Facing a 1.5% Medicare ePrescribing Payment Adjustment in 2013? Find Out If You Qualify For a Hardship Exemption (jump to story)

• Major Improvements to Medicare PECOS Online Enrollment System (jump to story)

• Register Early for Best Results from the EHR Incentive Program; 2012 Is Your Last Chance to Get Started for Full Benefits (jump to story)

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Last week Mary Pat and I had a chance to meet and sit down for a while with a smart guy whose new venture is doing some really exciting things in the healthcare space. One of our favorite things to do! In an effort to keep on readers on the edge of what’s new, and to give more of the people we meet a chance to say hello and connect to our audience, we present the first in the MMP Interview series.

We first got in touch with David when he commented on one of our 2.0 Tuesday posts on Medigram- a new, private beta secure communications service. David let us know that Medigram wasn’t the only player in the space, and we agreed to meet for coffee and a chat. We got a chance to sit down with David soon after for a coffee and a demo of his company’s flagship product qliqConnect- also currently in Beta.

David is a sharp, passionate guy, and we loved having the chance to talk to him. Check out the interview below!

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