Record retention can be a significant problem for healthcare groups. Different federal and state regulations require different retention schedules for medical records and other medical-service related documents. Many managers and physicians are confused on how long they should maintain records and how best to store all this paper. Here’s an updated record retention schedule that is in sync with medical malpractice insurers (check with your malpractice carrier) and accounting firms.
There are all kinds of numbers floating around for retaining records, but unless you are focusing ONLY on record retention, you”d have to be very organized to separate what can be shredded in 1 year, 3 years, 6 years, 7 years, etc. I prefer to categorize everything into three basic categories: Save it Forever, Save it for 7 years, and Save it according to state requirements. Here is (almost) everything broken into my three categories.
I lost power in my home and office from last Saturday until this past Thursday evening due to an unexpected snow storm.
What did I learn about being resilient over these last few days, and what are the lessons that can benefit all leaders?
My family and I returned to our home last Saturday to find that we did not have heat or electricity. Our assumption was that the utility company will have the problem resolved within 24 hours. After the 24 hours came and went, we realized that we may have to deal with this problem for several days (that’s the information we were being given by our neighbors).
Each night, my wife, son, and I would wear several layers of clothes to deal with the cold environment. We listened to the radio and tried to make the best of the situation. During the day I found myself going to Starbucks so I could have e-mail access and charge my phone. This became my office. I found neighbors to be very helpful, with everyone looking to pitch in and assist each other. This routine continued until the lights came back on Thursday.
What are the lessons learned during this period?
IMPORTANT: This does not affect those providers which have already received a revalidation notice. If you have received a revalidation notice from your contractor, respond to the request by completing the application either through internet-based PECOS or completing the appropriate 855 application form.
The first set of revalidation notices went to providers who are billing, but are not currently in the Provider Enrollment, Chain and Ownership System (PECOS). To identify these providers, contractors searched their local systems and if a Provider Transaction Access Number (PTAN) for a physician was not in PECOS, a revalidation request for that physician was sent. CMS asks all providers who receive a request for revalidation to respond to that request.
For providers NOT in PECOS the revalidation letter will be sent to the special payments or primary practice address because CMS doesn’t have a correspondence address. For providers in PECOS the revalidation letter will be sent to the special payments and correspondence addresses simultaneously; if these are the same it will also be mailed to the primary practice address. If you believe you are not in PECOS and have not yet received a revalidation letter, contact your Medicare contractor. Contact information may be found here.
CMS just announced the new numbers for premiums and deductibles for 2012. Now is the ideal time to think about Medicare deductibles and what your policy is on collecting deductibles at time of service.
If you’ve been hesitant to collect deductibles, ask yourself if you can handle the loss or delay of payment of $140 per Medicare patient. Most practices can’t. If you are thinking about collecting deductibles and other front-end collection techniques, my book “The Smart Manager’s Guide to Collecting at Checkout” is your guide to making it happen for your healthcare group. Click here to read more.
MEDICARE PART B (covers a portion of the cost of physicians services, outpatient hospital services, certain home health services, durable medical equipment, and other items)
- In 2012, the Part B deductible will be $140, a decrease of $22 from 2011.
- The standard Medicare Part B monthly premium will be $99.90 in 2012, a $15.50 decrease over the 2011 premium of $115.40.
- The standard premium is set to cover one-fourth of the average cost of Part B services incurred by beneficiaries aged 65 and over, plus a contingency margin. The contingency margin is an amount to ensure that Part B has sufficient assets and income to (i) cover Part B expenditures during the year, (ii) cover incurred-but-unpaid claims costs at the end of the year, (iii) provide for possible variation between actual and projected costs, and (iv) amortize any surplus assets. Most of the remaining Part B costs are financed by Federal general revenues. (In 2012, about $2.9billion in Part B expenditures will be financed by the fees on manufacturers and importers of brand-name prescription drugs under the Affordable Care Act.)
- The largest factor affecting the contingency margin for 2012 is the current law formula for physician fees, which will result in a payment reduction of about 29percent in 2012. For each year from 2003 through 2011, Congress has acted to prevent smaller physician fee reductions from occurring. The 2012 reduction is almost certain to be overridden by legislation enacted after Part B financing has been set for 2012. In recognition of the strong possibility of increases in Part B expenditures that would result from similar legislation to override the decrease in physician fees in 2012, it is appropriate to maintain a significantly larger PartB contingency reserve than would otherwise be necessary. The asset level projected for the end of 2012 is adequate to accommodate this contingenIn 2012, Social Security monthly payments to enrollees will increase by 3.6 percent. The dollar increase in benefit checks is expected to be large enough on average to cover the increase in the Part B premium of $3.50 that most beneficiaries will experience. For those who were paying the standard premium of $115.40, their benefits checks will only increase.
Here are some highlights from the new OIG Work Plan for FY 2012. There are more items that apply to practices, as well as items for hospitals, nursing facilities, home health, and medical equipment and supplies. The link to the complete plan is at the end of the article.
Compliance With Assignment Rules
If you accept assignment with Medicare (i.e. you accept what Medicare allows as payment for a service), the OIG wants to know if you are adhering to the allowable and not collecting more than the patient’s deductible and co-insurance.
Physicians-Owned Distributors of Spinal Implants (New)
Do physician-owned distributors (PODs) of spinal implants have a conflict of interest when they sell implants to hospitals? The OIG will investigate.
Place-of-Service Errors
Because there is a payment differential between a service provided in a hospital outpatient department or ASC and the same service provided in the physician’s office, the OIG wants to know if you provided the service where you claimed you did.
Physicians: Incident-To-Services (New)
Incident-to services are reported on the honor system – the claim does not reflect that a mid-level provider performed the service under the supervision of a physician. The OIG will dig under the claims to see if practices really understand and follow the incident-to rules.
The Third Annual Health Care Social Media Summit took place on the Mayo Clinic campus in Rochester, Minnesota last week, and to my chagrin, I was unable to attend. Lots of good information and resources were shared, including this video. It was posted on YouTube on October 14th and has already been viewed more than 10,000 times.
Mayo Clinic wouldn’t mind if the video went viral, but really wants the message to go viral. For information about installing the “Know Your Numbers” app on your hospital or practice Facebook page, contact Makala Johnson at Johnson.Makala@mayo.edu.
CMS will hold a National Provider Call to discuss the revalidation of Medicare provider enrollment information on Thursday, October 27th, 2011; from 12:30 – 2PM Eastern. Most providers and suppliers who are enrolled in the Medicare program will have to revalidate their enrollment which will be reviewed under the new risk screening criteria required by the Affordable Care Act Section 6401(a). Learn what you can expect and how to prepare for this process.
Target Audience: All providers and suppliers enrolled with Medicare prior to March 25, 2011 and who expect to receive payment from Medicare for services provided!!!!!! (I had to add those exclamation points – what a statement – if you expect to be paid, you need to revalidate.)
The agenda will include:
- What is Revalidation?
- ACA Screening Requirements
- Electronic Funds Transfer
- Streamlining the Process
- Phased Revalidation
- Tips on Revalidation
- Question and Answer Session (my favorite!)
Registration Information: In order to receive the call-in information, you must register for the call. Registration will close at 12pm on Thursday, October 27, 2011 or when available space has been filled; no exceptions will be made, so please register early. For more details, including instructions on registering for the call, click here. The audio recording and written transcript will be posted after the call.
Presentation: The presentation will be posted at least one day before the call in the Downloads section of the page here.
For more information about provider enrollment revalidation, review the Medicare Learning Networks publication here.
CMS recently released an updated version of the Advance Beneficiary Notice of Noncoverage (ABN) (form CMS-R-131), which will replace the 2008 version of this form. The 2008 and 2011 ABN notices are identical except that the release date of 3/11 is printed in the lower left hand corner of the new version. The ABN is used by all providers, practitioners, and suppliers paid under Medicare Part B, as well as hospice providers and religious non-medical healthcare institutions (RNHCIs) paid exclusively under Medicare Part A.
Providers and suppliers may use either the 2008 or 2011 version of the ABN through the end of 2011; beginning Sunday, January 1, 2012, they must begin using the 2011 version. ABNs issued after Sunday, January 1, that are prepared using the 2008 version of the notice will be considered invalid by Medicare contractors. 2008 versions of the ABN that were issued prior to Sunday, January 1 as long-term notification for repetitive services delivered for up to one year will remain effective for the length of time specified on the notice.
Okay, here’s the good stuff that I get questions on all day every day – how do I use the ABN?
First, let’s understand WHEN you should use the ABN.
The ABN’s reason for being is to allow the physician practice to collect from the patient for services that the patient wants, but are not covered by Medicare. Practices are not expected to give ABNs to patients to cover services that are never covered (called statutory exclusions), however, many find that it helps the patients understand when they receive a bill for the service. (Note: you may collect in full at time of service if you so choose.) With 2011′s new wellness benefits, some of the primary reasons for using the ABN have gone away. Patients receive a Welcome to Medicare Visit (not an exam) within the first 12 months of the effective date of Medicare Part B coverage. Medicare beneficiariesare eligible for one Annual Wellness Visit (AWV) every 12 months after they have had Medicare Part B for more than 12 months. This is a “visit” and not a physical examination.
It’s taken me a long time to realize that I’m part of a seriously small group that likes, or at least tolerates change well. People universally HATE change and will do most anything to avoid it. So what is a manager to do when charged with making change happen, or when leading your own change initiative?
Know the Change
Map out the change and do your best to understand every possible implication of the change. Have a trusted colleague or mentor review the map with you and see if you’ve neglected to consider any angle. For instance, if your plan is to offer Saturday clinic hours, make sure you’ve considered:
- A budget for the change – are all the stakeholders in agreement on the money that will be spent to make the change? Is this a pilot for a specific time period or will the Saturday hours be continued regardless of the patient volume?
- How will it be decided which staff will work Saturdays? Will working Saturdays be optional or mandatory? Will staff be allowed to earn overtime, or will they have to adjust their weekday schedule? Will there be a pay differential for Saturday hours? Will there be lots of staff wanting to work Saturdays or will there be no staff wanting to work Saturdays? Because they are so personal, staffing and payroll will always be the stickiest parts of making change happen, so assign them top priority!
- How will it be decided which physicians or mid-level providers will work on Saturdays? Have issues with pay, call, and time off been resolved?
- A marketing plan for the new Saturday hours. Letting people know that you will be open Saturdays is critical to the success of the plan.
- Will all services be offered on Saturdays, or will it be modeled after on an urgent care? If it is an urgent care model, will it be billed as an urgent care visit and will co-pays be collected for urgent care services? How will an urgent care model be communicated to patients so they are not surprised when there are different terms of service than they usually encounter?
- What, if any, changes will need to be made to forms, the computer system, HVAC, security, janitorial, lights, payroll system, etc. What workflows might need to be changed because the practice is not used to operating on Saturdays? Role play a patient coming for a Saturday appointment and map out all the possibilities.
Frame the Change Message
Let everyone know why the change is being considered/happening. Craft the change message into something repeatable. Everyone must understand the reason and must be able to attach the reason to a change message. It could be “We’re growing!” or “More service for our patients” or “We will thrive.” Whatever one or two messages you choose, repeat them in your Rule of Seven (see below) and throughout your change process. Explain that the change is coming because:
Peter Polack, MD of Medical Practice Trends interviewed me recently for a series of podcasts for his site. Here we talk about “How To Tell If Your Practice Is Well-Managed.” Click here to listen.
- Warning signs that your practice has management issues
- Why hiring your spouse as your manager may cost you in the long run
- Standard benchmarks that typical practices should be aware of
- The importance of being a calm practice
