Mary Pat: Where does the name of your company, Lutrum, come from?
Ed Garay: When I was developing a name for this company, I didn’t want to be like every other healthcare IT services company with health, md, medical, etc. as part of their name. I wanted it to represent something deeper about what we do and who we are as an IT organization. Although we are IT specialists, I realized that one of the things that I am always working with my team on is to listen and understand our clients needs. Which lead me to creating the name, Lutrum. Lutrum is a slight variant of the Latin word Lutra. Lutra means otter in English. And the otter symbolizes empathy.
Mary Pat: What led up to you starting your own business?
Ed Garay: In late 2000, I worked as an IT Director for an organization that continued to downsize. I came to a career crossroad. With starting to support under 100 systems, and the network running in tip-top shape, there was really no need for me to be there full-time in the long run. So, do I look for another job that cant possibly be as fulfilling as where I was, or do I take a leap of faith and start up my own business and share my knowledge with the masses? Through the feedback of mentors and other resources that knew me personally and professionally, I was highly motivated to take the leap of faith and have never looked back. My business career has evolved over the years and has naturally lead me to Lutrum.
Mary Pat: What are Managed IT Services?
Many physicians have some type of lab testing capability in their practices, with most practice labs classified as Waived Labs, which means having a Certificate of Waiver. This Certificate enables a practice to perform simple tests including tests such as urine dipsticks, rapid Strep A for sore throats, Mono Tests, pregnancy slide tests on urine, and Rapid Flu tests.
There is little effort required to become or maintain a Waived Lab
There are no personnel qualification requirements, and the only regulation is to follow the manufacturer’s instructions on the test packages. In order to obtain a Certificate of Waiver, an application form (the CMS116 form) must be completed and submitted to CLIA at the state CLIA office. The CLIA office will issue a CLIA identification number and the practice will receive a bill for the Certificate of Waiver for $150. Life is wonderfully simple at a Certificate of Waiver level.
In health care, we are “blessed” with an abundance of rules, policies, standards and laws. In Health Care Regulation in America: Complexity, Confrontation, and Compromise, Robert I. Field, professor of health management and policy at Drexel University School of Public Health, observes the following:
”Regulation shapes all aspects of America’s fragmented health care industry, from the flow of dollars to the communication between physicians and patients. It is the engine that translates public policy into action. While the health and lives of patients, as well as almost one-sixth of the national economy depend on its effectiveness, health care regulation in America is bewilderingly complex.”
Here are some of the most important regulations in health care that you should not only know about, but should be actively managing with a robust compliance plan.
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.
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.
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.
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.
If you’ve read parts 1 (Know Your Payers) and 2 (Implementing Your Financial Policy) of this series, you are ready to consider a financial assistance policy for those patients without insurance.
Patients without insurance fall into one of three categories:
- Patients without insurance who have the ability to pay their medical bills but refuse to pay them.
- Patients without insurance who have the ability to pay their medical bills and are willing to do so.
- Patients without insurance who do not have the financial resources to pay their medical bills.
Patients in category #1 are easy to identify. We’ve all encountered them and we know that they do not value what the physician or care provider offers, or they believe that for some reason they should not be required to pay. They will waste your valuable time and should be discharged from your service if possible.
Just in case you haven’t had a chance (what have you been doing?) to focus on the January 1, 2012 deadline for the transition to 5010, take 5 minutes to read this post and make sure your healthcare group is on track. It is critical to have NO interruption in cash flow in January – a time when cash flow is already lower due to the new deductibles in play for many plans including Medicare.
The American Medical Association (AMA), in its “5010 Implementation Steps: Getting the Work Done in Time for the Deadline” recommends the following to protect your cash in January:
- Submit as many transactions as possible before Jan. 1, 2012.
- Decrease expenses before Jan. 1, 2012, to increase cash reserves.
- Consider establishing a line of credit with a financial institution.
- Research payers’ advance payment policies.
- Consider using manual or paper processes to complete transactions until the electronic transactions are fixed.
Note that HIPAA standards, including the ASC X12 Version 5010 and Version D.0 standards are national standards and apply to your transactions with all payers, not just with FFS Medicare. Therefore, you must be prepared to implement these transactions for your non-FFS Medicare business.
Beginning January 1, 2012 all electronic claims, eligibility and claim status inquiries must use Version 5010 or D.O.
As we finish off another month here at MMP, we wanted to go back over some of our most popular posts from the month and get us ready for another busy, productive, and meaningful month. Presenting, The Best of Manage My Practice, September 2011!
- With the weather getting chillier, and coats and sweater getting pulled out of the closets again, it’s time once again to get ready for your patients’ flu shots! The CMS has released coding and pricing information for Flu shots given after September 1st, 2011, so bookmark the page or print it out for easy reference.
- Did your providers get their e-Prescribing done to avoid your Medicare rate reduction? If not, you’ll probably want to apply for a CMS Hardship Exemption for 2012. Find out how here!
- Mary Pat continued her series “Collection Basics” about Revenue Cycle Management in Physician offices with “Part II: Implementing Your Financial Policy“
- Do you dread patient complaints? Don’t! Patients with complaints are a GOLDEN opportunity to learn about your practice, gain new perspectives on your operation and connect and learn about your customers. Learn how to get everything you can from a complaint in “Why I Can’t Wait to Hear Patient Complaints“!
- And finally, everything you always wanted to know but we’re afraid to ask about a common, but sometimes vague office routine: “The Right Way to Do Write-offs.”
We’ve started this monthly wrap-up to make sure you don’t miss any of the great stuff we post throughout the month on Manage My Practice, but we also want to hear from you! What were your favorite posts and discussions this month? Did we skip over your favorite from September? Let us know in the comments!
