Manage My Practice

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?

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One of the most exciting trends in modern healthcare can be found at the intersection of two larger societal changes: the shifting demographics of an aging Baby-Boomer population, and the fast adoption of smart mobile devices and mobile application platforms. As robust, secure and intuitive mHealth applications are adopted, patients are more empowered to monitor and share their health data outside of a traditional medical office or hospital setting. As healthcare delivery system already short on providers becomes even more taxed, mHealth applications will allow the system as a whole (patients, caregivers, loved ones, and payers) to navigate health decisions in a more efficient and informed way.

This quote from the Deloitte Center for Health Solutions 2010 Survey of Health Care Consumers says it all:

Boomers view tech-enabled health products as a way to foster control and ongoing independence for themselves, especially in light of the rise in incidence in chronic disease with aging, and their desire to reduce costs. Nearly 56% of boomers show a high willingness to use in-home health monitoring devices in tandem with care of their primary physician.

What are the advantages of pushing home health medical data from the source to the care provider?

• Minimum lag time between data collection and the clinicians ability to review it.
• Reduction in errors associated with human intervention in data entry.
• Intuitive and simple interfaces promote active patient involvement and caregiver communication in healthcare management.
• Secure sharing of PHI (Protected Health Information) with patient, family members, and approved internal and external stakeholders in health.

Here are just a few of the companies and products available now (or in the near future) that might change your mind about where and how health data is captured and shared. Each of these products automates the capture of health data and the transfer of the data in a usable format to an Electronic Health Record.

Near Field Communications

NFC (Near Field Communications) is a wireless technology that allows for quick transfer of data between two sensors that are fairly close (an inch or two) together. The secure transfer allows for seamless data tracking inside caregivers workflow. For example: medical supplies, drugs, injectables and fluids can be fitted with low cost sensors that are swiped past a patients sensor to indicate they will be administered to the patient, and then again past the providers sensor to indicate a finished procedure, capturing time of administration, dosage, and patient information without slowing down the care to enter this critical data by writing them down, typing them in, or just resolving to remember them for later entry.

Gentag makes the data sensors and applications that manufacturers can use to send data via cell phone to the hospital or physician for seamless inclusion in the electronic medical record (EMR). Monitoring of blood pressure, fever, weight management and urinalysis are just a few of the ways Gentag has improved data capture in healthcare.

iMPak Health makes a cholesterol monitor the size of a credit card that accepts a small blood sample to process for triglyceride levels. The data is uploaded wirelessly to a cell phone that transmits it to a health provider.

Smart Fabrics and Wearable Monitors

Researchers at the Universidad Carlos III de Madrid in Spain developed a fascinating concept for an Intelligent T-Shirt that uses sensors woven into a washable fabric to create a hospital garment that does more than preserve the patients modesty. The sensors in the fabric can detect and record temperature, bioelectric impulses (for ECG monitoring), as well as the patients location, current resting position, and level of physical activity.

Copenhagen Institute of Interaction Design graduate Pedro Nakazato Andrade has designed a dynamic cast called Bones that collects muscle activity data around a fracture area by using electromyographic (EMG) sensors to report the patients progress to physicians automatically. This could reduce the need for follow-up visits and imaging, or change the specifics of rehabilitation.

The Basis Band is a wristwatch-type accessory that monitors heart rate by directing light into the skin to image blood flow. It also uses a heat sensor for skin temperature changes, an accelerometer for recording movement and activity, and sensors for galvanic skin response. The band also gives customers access to a free, web-based health dashboard to oversee the data the device collects and transmits.

There are still some considerable hurdles to full adoption of mobile home health monitoring. Very few patients use only one medical device, so not only do monitoring devices need to work with networked EHR technologies, they have to be integrated with each other to present a comprehensive picture of health to providers and Health Information Exchanges (HIEs). Also, as patients navigate the system of generalists, specialists, and emergency care providers, the possibility of encountering multiple software and hardware platforms will require flexible, integrated solutions that can run on any device. As with any networked application of sensitive data, security and availability are major factors in a success deployment. Unless patients can count on the privacy of their data, and providers can count on the uptime of their software, healthcare systems wont be able to realize the full benefit of mHealth installations. On top of that, more monitoring of patient health means that there will be even more data to be collected on each patient, and on the population as a whole. While more data means more opportunity for large scale research and analysis for the public benefit, it also means more data has to be secured and protected as a part of the health record, requiring even more security and storage resources. And finally, the Food and Drug Administration will have a large say in the future of mHealth application development through industry regulation. Device makers and application developers will certainly have to work within a governmental framework which will have a large say in the time-to-market of many possible products.

With all that being said, the opportunity to meet the demographic challenges of an already stressed healthcare system with mobile home health monitoring and Electronic Health Records will be one of the major themes of the future of both the heath and technology industries.

CMS Announces 90-Day Period of Enforcement Discretion for Compliance with New HIPAA Transaction Standards

Today the Centers for Medicare & Medicaid Services Office of E-Health Standards and Services (OESS) announced that it would not initiate enforcement action until March 31, 2012, with respect to any HIPAA covered entity that is not in compliance with the ASC X12 Version 5010 (Version 5010), NCPDP Telecom D.0 (NCPDP D.0) and NCPDP Medicaid Subrogation 3.0 (NCPDP 3.0) standards. Notwithstanding OESS discretionary application of its enforcement authority, the compliance date for use of these new standards remains January 1, 2012 (small health plans have until January 1, 2013 to comply with NCPDP 3.0).

CMS has posted the transcript from the National Provider Call on Thursday, October 27, 2011

Dont miss this opportunity to hear from CMS experts on this important topic. Click on National Provider Call on Revalidation of Medicare Provider Enrollment to view the transcript. This transcript contains a number of post call clarifications such as where to find the listing of providers which have received a notice to revalidate. The audio file will be posted in the near future.

Now Available Online: List of Providers sent a Revalidation Request

In response to provider requests, CMS has posted a listing of providers who have been sent a request to revalidate their Medicare enrollment information. The listing containsthe name and national provider identifier (NPI) of each provider sent a letter, as well as the date the letter was sent. To see the listing, click on Revalidation Phase 1 Listing in the Downloads section of the Medicare Provider Supplier Enrollment Revalidation Page. NOTE: You must widen each column in the spreadsheet to view the contents. CMS will be updating this list monthly.

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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 ready for another busy, productive, and meaningful month. Presenting, The Best of Manage My Practice, October 2011!

• Are you ready for the holidays? How about the New Year? Even though it’s still a few months off, make sure you don’t see an interruption in your practice’s cashflow by getting ready for the January 1st 5010 deadline!
• CMS has released the Premiums and Deductibles for Medicare patients for 2012, so you can start informing staff and patients now. More importantly, will 2012 be the year that you get serious about collecting deductibles at the time of service?
• Mary Pat’s “Collection Basics”series about the fundamentals of Revenue Cycle Management in Physician offices is now at part three! Check out Patient Collections Basics: Developing a Financial Assistance Program.
• One of Healthcare’s most misunderstood and underutilized documents- the Medicare Advance Beneficiary Notice- is changing for 2012. Make sure you’re ready.
• And finally, the Office of the Inspector General (OIG) of he department of Health and Human services has released its 2012 Work Plan for areas it will concentrate on investigating. Better safe than sorry! Mary Pat goes over the highlights here.

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 October? Let us know in the comments!

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.

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Today, PhysiciansPractice sponsored a webinar with CMS’s Robert Anthony on the topic of “Meaningful Use Stage 1.” Robert Anthony is a Health Insurance Specialist in the Office of E-Health Standards and Services (OESS) at the Centers for Medicare & Medicaid Services (CMS), where he focuses on the EHR Incentive Programs. Robert had a very pleasant voice to listen to, and he gets my vote for the best CMS Employee Speaker that I’ve heard!

I was not familiar with the OESS before, so I looked it up and found out what they do: Provide the overall leadership for and coordinate the implementation of Title IV of the HITECHAct. (Title IV = Medicare and Medicaid Health Information Technology)

Robert briefly reviewed what has happened to date with the EHR Incentive Program and the terms of the Medicare and Medicaid programs. The three main differences in the two programs are:

1. The types of providers that are eligible for each program – information here.
2. The volume of each type of patient needed to participate: no volume needed to participate in the Medicare program and 30% Medicaid patients for all eligible practitioners except pediatricians who only need 20% Medicaid patients.
3. The tasks in year one in which the certified EHR is adopted. For Medicaid the practice only needs to attest that they have adopted, implemented or upgraded an EHR. In year one for Medicare the practice needs to attest to meaningful use for 90 days, which means data is collected and input into the attestation system.

The majority of the webinar was devoted to FAQs (my favorite part of any CMS-related education session!)

FAQs

Q: Can entities participate in the Medicare EHR Demonstration Project, and the Medicare or Medicaid EHR Incentive programs too?

A: Yes. The demonstration projects are about to be sunsetted (completed.)

Q: What information must be provided to patients to meet the requirement for a clinical summary at the end of each visit?

A: If system is certified, it will automatically provide the appropriate information for the clinical summary, which includes the patient’s problem list, medication list, medication allergy list, and diagnostic test results.

Robert suggested looking at the answer online at the CMS FAQ which I posted below:

In our final rule, we defined “clinical summary” as: an after-visit summary that provides a patient with relevant and actionable information and instructions containing, but not limited to, the patient name, provider’s office contact information, date and location of visit, an updated medication list, updated vitals, reason(s) for visit, procedures and other instructions based on clinical discussions that took place during the office visit, any updates to a problem list, immunizations or medications administered during visit, summary of topics covered/considered during visit, time and location of next appointment/testing if scheduled, or a recommended appointment time if not scheduled, list of other appointments and tests that the patient needs to schedule with contact information, recommended patient decision aids, laboratory and other diagnostic test orders, test/laboratory results (if received before 24 hours after visit), and symptoms.

The EP must include all of the above that can be populated into the clinical summary by certified EHR technology. If the EP’s certified EHR technology cannot populate all of the above fields, then at a minimum the EP must provide in a clinical summary the data elements for which all EHR technology is certified for the purposes of this program (according to 170.304(h)):

• Problem List
• Diagnostic Test Results
• Medication List
• Medication Allergy List

Q: How and when are incentive payments made?

A: After the online attestation is made (attestation thresholds must be attained), provider information is verified, then in 6 to 8 weeks a payment is generated. Payments are made in whatever way the entity typically gets CMS payments.

Q: What if patients do not routinely receive prescriptions during an office visit? How can the threshold be met? (Referring to computerized provider order entry (CPOE) for medication orders.)

A: For attestation, practices need to do this for 30% or more of all unique patients with at least one medication in their medication list. Note that patients with no medications in their medication list are excluded, so CMS believes this core initiative is realistic.

Q: For the Medicaid program, do you count the patient visit or the number of services (e.g. patient visit plus two tests equals three patient ticks) during the visit?

A: This question needs follow-up and if you send an email to editor@physicianspractice.com, they will be sent to CMS for the answer. Here is additional information from the CMS FAQ:

When calculating Medicaid patient volume or needy patient volume for the Medicaid EHR Incentive Program, are eligible professionals (EPs) required to use visits, or unique patients?

There are multiple definitions of encounter in terms of how it applies to the various requirements for patient volume.Generally stated, a patient encounter is any one day where Medicaid paid for all or part of the service or Medicaid paid the co-pays, cost-sharing, or premiums for the service.The requirements differ for EPs and hospitals.In general, the same concept applies to needy individuals.Please contact your State Medicaid agency for more information on which types of encounters qualify as Medicaid/needy individual patient volume.

Q: We are a new practice and plan on getting an EMR in the next 3 months. Can you walk me through the time lines?

A: If you haven’t chosen an EMR yet, your first year in either program will probably be 2012. In the first year of Medicare participation, you will need to use the EMR meaningfully for 90 days during calendar year 2012, and you have up to 60 days after the close of the calendar year to attest to your use. In the first year of Medicaid participation, you will need to adopt (acquire, install), implement (commence utilization of EHR such as train, data entry), or upgrade (expand) a certified EHR and attest to your activity at any time during the calendar year.

Q: What validation or oversight will CMS provide for the attestation process?

A: Before any payment is made, checks of provider eligibility and information will be done. Keep in mind that attestation is a legal process. Random audits will be put in place in the near future.

Q: Should a practice register if we don’t know which program we are going to use?

A: You can register at any time, and you can change from one program to the other prior to attesting, so you can register for one program and change before you begin the attestation.

Q: If your first year of attestation is in 2012, can you get the full 44K over the course of the program?

A: Yes.

Q: Can you verify if Physician Assistants are eligible for one of the programs?

A: Physician Assistants (PAs) are only eligible under the Medicaid program and must be the lead provider for a Federally Qualified Health Center (FQHC) or Rural Health Clinic (RHC) to qualify.

Q: Does a radiology practice have to provide a clinical summary for patients?

A: No practice type is excluded from clinical summary mandate. CMS has not heard of any practice type having a problem with this so far. Remember, to achieve meaningful use, you must provide clinical summaries to patients for more than 50 percent of office visits within three business days. Exclusion: Any EP who has no office visits during the period of EHR reporting.

Q: Is the problem list supposed to be related to the chief compliant of the office visit?

A: Not necessarily. Practices are required to maintain an up-to-date problem list of current and active diagnoses based on ICD-9-CM or SNOMED CT (Systematized Nomenclature of Medicine – Clinical Terms) codes. To comply, at least 80 percent of all unique patients seen by eligible providers must have at least one entry (or an indication of none) recorded as structured data.

Q: What if questions were not able to be answered during the webinar?

A: Please e-mail Physicians Practice and well get your answers from CMS. This could take several days, so please be patient. We will post your answers and all post-webinar questions at http://www.physicianspractice.com and notify you via e-mail as well.

Resources

A great list of additional resources were provided by Robert Anthony and Physicians Practice:

Resources from CMS

• EHR Incentive Programs website
• ONC website
• FAQs
• Listserv
• Meaningful Use Specification Sheets
• EHR Information Center
• Registration & Attestation User Guides
• EHR Hotline: 888-734-6433 / -6563 (TTY)

Resources from PhysiciansPractice.com

• Topic Resource Centers
  • EHR
  • Meaningful Use
• Tools
  • Are You Ready? Quiz
  • Pricing Worksheet
  • Preparation Checklist
  • Meaningful Use Stage 1 Crib Sheet
• You can also listen to an archived video of today’s webinar here.

Other Posts I have written on this topic:

Step by Step Directions for Getting the EHR Incentive Money: My Notes From Last Weeks CMS Call

CMS Holds National Provider Calls for the Medicare EHR Incentive Program and EHR Attestation Q & A

Digging Into the Details of Certified EMR & Tips For Buying an EMR

How Do You Get That Stimulus Money for Using an Electronic Medical Record? (You Register!)

How My Practice Knew We Were Ready for EMR

10 Ways to Get More Out of Your PM, EMR or Any Medical Software

Hospital Wage Index Reform Call

Special Open Door Forum: Presentation and Listening Session on Hospital Wage Index Reform

Tuesday, April 12, 2011, 1:30 PM 3:00 PM ET.

Section 3137(b) of the Affordable Care Act requires CMS to submit to Congress, by December 31, 2011, a report that includes a plan to reform the wage index under the Medicare hospital inpatient prospective payment system (IPPS). CMS acquired the services of Acumen, LLC to assist in its study of the wage index. During the first part of this special open door forum, Acumen will present its concept of an alternative methodology for the wage index. The second part will be a listening session, during which CMS would like to hear from you regarding your opinions about Acumen’s concept, as well as any suggestions on alternative methods for computing the wage index. If you wish to participate via conference call, dial 1-800-837-1935 Conference ID 50101623. Please see the full participation announcement in the Downloads section here.

Electronic Health Record Incentive Program Attestation Begins This Week

Attestation for the Medicare Electronic Health Record (EHR) Incentive Program begins on Monday, April 18, 2011. In order to receive your Medicare EHR incentive payment, you must attest through CMS’s web-based Medicare and Medicaid EHR Incentive Programs Registration and Attestation System.

You can preview selected screenshots of the Attestation System to help you understand what the attestation process will involve. Please note that these screenshots are only examples the final appearance and language may incorporate additional changes. CMS will release additional information about the Medicare attestation process soon, including User Guides that provide step-by-step instructions for completing attestation and educational webinars that describe the attestation process in depth.

You need to understand the required meaningful use criteria to successfully attest. Meaningful use requirements for eligible professionals (EPs), eligible hospitals, and critical access hospitals (CAHs) participating in the Medicare EHR Incentive Program are different:

• EP Meaningful Use Criteria Must report on 15 core measures, 5 of 10 menu measures, and 6 clinical quality measures, consisting of 3 required core measures and 3 additional measures.

• • Visit the Stage 1 EHR Meaningful Use Specification Sheets for EPs for information on core and menu measures for EPs.
  • Visit the Clinical Quality Measures page for information on the required clinical quality measures for EPs.

• Eligible Hospital and CAH Meaningful Use Criteria Must report on 14 core measures, 5 of 10 menu measures, and 15 clinical quality measures.

• • Visit the Stage 1 EHR Meaningful Use Specification Sheets for Eligible Hospitals and CAHs for information on core and menu measures for eligible hospitals and CAHs.
  • Visit the Clinical Quality Measures page for information on the required clinical quality measures for eligible hospitals and CAHs.

You should also make sure that you begin your 90-day reporting period in time to attest and receive a Medicare payment in 2011. The last days to begin 90-day reporting periods for 2011 incentive payments are:

• Sunday, July 3, 2011, for eligible hospitals and CAHs; and
• Saturday, October 1, 2011, for EPs.

Under the Medicaid EHR Incentive Programs, the date when participants can begin attestation for adopting, implementing, upgrading, or demonstrating meaningful use of certified EHR technology varies by state. Visit the Medicaid State EHR Incentive Program web-tool for more information about your state’s participation in the Medicaid EHR Incentive Program.

Want more information about the EHR Incentive Programs? Make sure to visit the CMS EHR Incentive Programs website for the latest news and updates on the EHR Incentive Programs; also read the new EHR Incentive Program FAQs from CMS.

Preventive Services, Preventive Physical Examinations and Annual Wellness Visits Quick Reference Charts

The ABCs of Providing the Initial Preventive Physical Examination Quick Reference Chart provides Medicare Fee-For-Service providers a list of the elements of the IPPE, as well as coverage and coding information. View the chart here.

The ABCs of Providing the Annual Wellness Visit Quick Reference Chart provides Medicare Fee-For-Service providers a list of the elements of the AWV, as well as coverage and coding information. View the chart here.

The Medicare Preventive Services Quick Reference Chart provides Medicare Fee-For-Service providers coverage, coding, and payment information on the variety of preventive services covered by Medicare. View the chart here.

A hardcopy booklet containing all three charts, as well as the Quick Reference Information: Medicare Immunization Billing chart, will be available at a later date.

Latest HCPCS Code Set Changes

The Centers for Medicare & Medicaid Services is pleased to announce the scheduled release of modifications to the Healthcare Common Procedure Coding System (HCPCS) code set. These changes have been posted to the HCPCS web page here. Changes are effective on the date indicated on the update.

Revisions to ASP Pricing Files

The Centers for Medicare and Medicaid Services (CMS) has posted revised October 2010 and January 2011 ASP (average sales price) files, which are available for download here (see left menu for year-specific links).

Physician or NPP Signatures on Lab Requisitions

In the Monday, November 29, 2010, Medicare Physician Fee Schedule final rule, the Centers for Medicare & Medicaid Services (CMS) finalized its proposed policy to require a physicians or qualified non-physician practitioners (NPP) signature on requisitions for clinical diagnostic laboratory tests paid under the clinical laboratory fee schedule effective Saturday, January 1, 2011. (A requisition is the actual paperwork, such as a form, which is provided to a clinical diagnostic laboratory that identifies the test or tests to be performed for a patient.)

On Monday, December 20, 2010, CMS informed its contractors of concerns that some physicians, NPPs, and clinical diagnostic laboratories are not aware of or do not understand this policy. As such, CMS indicated that it will focus in the first quarter of 2011 on developing educational and outreach materials to educate those affected by this policy. CMS indicated that once the first quarter educational campaign is fully underway, it will expect requisitions to be signed.

After further input from community, CMS has decided to focus for the remainder of 2011 on changing the regulation that requires signatures on laboratory requisitions because of concerns that physicians, NPPs, and clinical diagnostic laboratories are having difficulty complying with this policy.

Face-to-Face Encounter Requirements for Home Health and Hospice

Effective April 1, 2011, the Centers for Medicare & Medicaid Services (CMS) expects home health agencies and hospices have fully established internal processes to comply with the face-to-face encounter requirements mandated by the Affordable Care Act (ACA) for purposes of certification of a patients eligibility for Medicare home health services and of recertification for Medicare hospice services.

Section 6407 of the ACA established a face-to-face encounter requirement for certification of eligibility for Medicare home health services, by requiring the certifying physician to document that he or she, or a non-physician practitioner working with the physician, has seen the patient. The encounter must occur within the 90 days prior to the start of care, or within the 30 days after the start of care. Documentation of such an encounter must be present on certifications for patients with starts of care on or after January 1, 2011.

Similarly, section 3131(b) of the ACA requires a hospice physician or nurse practitioner to have a face-to-face encounter with a hospice patient prior to the patients 180th-day recertification, and each subsequent recertification. The encounter must occur no more than 30 calendar days prior to the start of the hospice patients third benefit period. The provision applies to recertifications on and after January 1, 2011.

On December 23, 2010, due to concerns that some providers needed additional time to establish operational protocols necessary to comply with face-to-face encounter requirements mandated by the Affordable Care Act (ACA) for purposes of certification of a patients eligibility for Medicare home health services and of recertification for Medicare hospice services, CMS announced that it will expect full compliance with the requirements, beginning with the second quarter of CY2011.

Throughout the first quarter of 2011, CMS has continued outreach efforts to educate providers, physicians, and other stakeholders affected by these new requirements. CMS has posted guidance materials including a MLN Matters article, questions and answers documents, training slides, and manual instructions which are available via CMS Home Health Agency Center and Hospice webpages. CMS Office of External Affairs and Regional Offices contacted state and local associations for physicians and home health agencies and advocacy groups to ensure awareness about the face-to-face encounter laws, and to distribute the educational materials.

CMS will continue to address industry questions concerning the new requirements, and will update information on the Web site here for home health and here for hospice.

Federally Qualified Health Center Fact Sheet Revised

The revised publication titled Federally Qualified Health Center (revised March 2011) is now available in downloadable format from the Medicare Learning Network here. This fact sheet is designed to provide education about Federally Qualified Health Centers (FQHC), including background; FQHC designation; covered FQHC services; FQHC preventive primary services that are not covered; FQHC Prospective Payment System; FQHC payments; andMedicare Prescription Drug, Improvement, and Modernization Act of 2003 provisions that impact FQHCs.

Avoiding the Adjustment 2012 Medicare Payment Adjustment for Not ePrescribing in 2011

In November 2010, the Centers for Medicare & Medicaid Services announced that, beginning in calendar year 2012, eligible professionals who are not successful electronic prescribers based on claims submitted between Sat Jan 1 and Thu June 30, 2011, may be subject to a payment adjustment on their Medicare Part-B Physician Fee Schedule-covered professional services. Section 132 of the Medicare Improvements for Patients and Providers Act of 2008 (MIPPA) authorizes CMS to apply this payment adjustment whether or not the eligible professional is planning to participate in the eRx Incentive Program.

From 2012 through 2014, the payment adjustment will increase each calendar year. In 2012, the payment adjustment for not being a successful electronic prescriber will result in an eligible professional or group practice receiving 99% of their Medicare Part-B PFS amount that would otherwise apply to such services. In 2013, an eligible professional or group practice will receive 98.5% of their Medicare Part-B PFS-covered professional services for not being a successful electronic prescriber in 2011 or as defined in a future regulation. In 2014, the payment adjustmentfor not being a successful electronic prescriber is 2%, resulting in an eligible professional or group practice receiving 98% of their Medicare Part-B PFS-covered professional services. (The payment adjustment does not apply if less than 10% of an eligible professionals or group practices allowed charges for the Sat Jan 1, 2011 through Thu June 30, 2011, reporting period are comprised of codes in the denominator of the 2011 eRx measure.) Also note that earning an eRx incentive for 2011 will NOT necessarily exempt an eligible professional or group practice from the payment adjustment in 2012.

How to Avoid the 2012 eRx Payment Adjustment:

• Eligible professionals An eligible professional can avoid the 2012 eRx Payment adjustment if (s)he:
  • Is not a physician (MD, DO, or podiatrist), nurse practitioner, or physician assistant as of Thu June 30, 2011, based on primary taxonomy code in NPPES;
  • Does not have prescribing privileges. Note that (s)he must report G8644 at least one time on an eligible claim prior to Thu June 30, 2011;
  • Does not have at least 100 cases containing an encounter code in the measure denominator;
  • Becomes a successful e-prescriber; and reports the eRx measure for at least 10 unique eRx events for patients in the denominator of the measure.

NOTE: Group Practices For group practices that are participating in eRx GPRO-I or GPRO-II during 2011, the group practice MUST become a successful e-prescriber. Depending on the groups size, the group practice must report the eRx measure for 75-2500 unique eRx events for patients in the denominator of the measure. For additional information, please visit the Getting Started webpage here or download the Medicares Practical Guide to the Electronic Prescribing (eRx) Incentive Program under Educational Resources on the same website.

Implementation of Errata for Version 5010 of HIPAA Transactions

BTW, errata is a list or lists of errors and their corrections. Errata is plural and the singular is erratum.

CMS does not have a version 4010A1 direct data entry and a separate version 5010 direct data entry. The Priority (Type) of Admission or Visit code is now required on all version 4010A1 institutional claims submitted or corrected via direct data entry, as well as on version 5010 institutional claims, regardless of how they are submitted. Providers that are unsure which code to use are to use code 9 (Information not Available). Additional Priority (Type) of Admission or Visit code values and descriptions are available from the National Uniform Billing Committee or from your servicing MAC. The Priority (Type) of Admission or Visit code is not required on 4010A1 institutional claims submitted or corrected via an 837. More information on Version 5010 here.

IMPORTANT 5010/D.0 IMPLEMENTATION ITEMS

REMINDER 5010/D.0 Errata requirements and testing schedule can be found here

REMINDER Contact your MAC for their testing schedule

READINESS ASSESSMENT Have you done the following to be ready for 5010/D.0?

READINESS ASSESSMENT What do you need to have in place to test with your MAC?

READINESS ASSESSMENT Do you know the implications of not being ready?

New Mental Health Services Booklet

A new publication titled Mental Health Services is now available in downloadable format from the Medicare Learning Network here. This booklet is designed to provide education on mental health services, including covered mental health services, mental health services that are not covered, mental health professionals, outpatient psychiatric hospital services, and inpatient psychiatric hospital services.

Ambulance Fee Schedule Fact Sheet Revised

The revised publication titled Ambulance Fee Schedule (revised March 2011) is now available in downloadable format from the Medicare Learning Network here. This fact sheet is designed to provide education about the Ambulance Fee Schedule including background, ambulance providers and suppliers, ambulance services payments, and how payment rates are set.

Health Professional Shortage Area Fact Sheet Revised

The revisedpublicationtitled Health Professional Shortage Area (revised March 2011) is now available in downloadable format from the Medicare Learning Network here. This fact sheet is designed to provide education on the Health Professional Shortage Area (HPSA) payment system and includes an overview of the program and general requirements.

Medicare Disproportionate Share Hospital Fact Sheet Revised

The revised publication titled Medicare Disproportionate Share Hospital (revised March 2011) is now available in downloadable format here. This fact sheet is designed to provide education on Medicare Disproportionate Share Hospitals (DSH) including background; methods to qualify for the Medicare DSH adjustment; Medicare Prescription Drug, Improvement, and Modernization Act of 2003 and Deficit Reduction Act of 2005 provisions that impact Medicare DSHs; number of beds in hospital determination; and Medicare DSH hospital payment adjustment formulas.

G0431QW is Deleted and G0434QW is Added to CLIA Waived Test Schedule

The Centers for Medicare & Medicaid Services (CMS) is updating the status of two codes on the Clinical Laboratory Fee Schedule (CLFS).

• Effective April 1, 2011, code G0431QW is deleted from the CLFS. Code G0431 describes a high complexity test, and should not be reported with a QW modifier; the QW modifier indicates a CLIA waived test.
• Effective April 1, 2011, code G0434QW is added to the CLFS. Code G0434 can describe a CLIA waived test. The use of the QW modifier to indicate a CLIA waived test is necessary for accurate claims processing.

Codes G0431 and G0434 will remain on the CLFS.

CMS Launches a Dedicated Web Page for the Medicare Shared Savings Program/Requirements for ACOs

On March 31, 2011, The Centers for Medicare & Medicaid Services (CMS) published in the Federal Register proposed rule CMS-1345-P, Medicare Program; Medicare Shared Savings Program: Accountable Care Organizations that implements the Medicare Shared Savings Program (Shared Savings Program) and establishes the requirements for Accountable Care Organizations. CMS has launched a dedicated web page here for Medicare FFS providers and other providers of services and suppliers. Bookmark the web page and check back often, as CMS continues to add information on the program.

Program for Evaluating Payment Patterns Electronic Report (PEPPER) for CAHs

Beginning in April 2011, the Centers for Medicare & Medicaid Services (CMS) will make available free hospital-specific comparative data reports for critical access hospitals (CAHs) nationwide. The Program for Evaluating Payment Patterns Electronic Report (PEPPER) provides hospital-specific data statistics for Medicare discharges at risk for improper payments. Hospitals can use the data to support internal auditing and monitoring activities. PEPPER is the only free report comparing a CAHs Medicare billing practices with other CAHs by state, Medicare Administrative Contractor (MAC) or Fiscal Intermediary (FI) jurisdiction and the nation. CMS has contracted with TMF Health Quality Institute to develop and distribute the reports.

PEPPER will be distributed electronically to CAH QualityNet Administrators and those who have basic user accounts with the PEPPER Recipient role on or about Monday, April 25, via a My QualityNet secure file exchange. In preparation for receiving and downloading PEPPER from My QualityNet, these individuals should verify that their computer systems are equipped with the software and configuration required to use My QualityNet by following the steps at www.qualitynet.org (see Getting Started With QualityNet and Test Your System.) Additional information about downloading PEPPER from My QualityNet can be found here (includes System Setup and Test Guide, Troubleshooting Tips and a guide for Configuration Changes for Compatibility with QualityNet).

CAHs may work with their Quality Improvement Organization (QIO) to obtain a QualityNet administrator account by visiting www.qualitynet.org and clicking on the Hospitals – Inpatient link. Obtaining a My QualityNet account may take several weeks; CAHs should plan accordingly.

TMF will conduct a web-based training session for CAH staff providing information on PEPPER and how to use it on Thursday, April 28, at 1 p.m. central time. To register for the training, CAH staff should visit https://tmfevents.webex.com. The training will be recorded and posted on http://www.pepperresources.org.

For more information, including the PEPPER distribution schedule, a sample PEPPER for CAHs and information about QualityNet accounts, visit the PEPPER website. CAH staff are encouraged to join the e-mail list on this website to receive important notifications about upcoming PEPPER distribution and training opportunities.

Image by The Library of Congress via Flickr

I’ve had a lot of questions since last week when I offered to help readers “get on the cloud.” Most people want to know – what exactly does getting on the cloud mean?

The term cloud comes from both the look of technical drawings which depict the relationship between cloud services and consumers, and is also a metaphor for the fact that cloud service providers exist out of sight in some distant location. My favorite definition of the cloud is “Using the Internet to store, manipulate and deliver data. Here are 76 ways to do just that!

SECURITY & RISK MANAGEMENT

1. Decide user by user which files and folders each employee or stakeholder may have access to. Decide if the user may view information, upload information, download information, invite other collaborators or edit documents. Change the user’s permission instantly, or eliminate their access to everything on the spot.
2. Store critical documents: letter of incorporation, Tax ID assignment, Medicare letters, shareholder agreements, by-laws, etc.
3. Scan in any and all documentation of lawsuits and or legal correspondence about patients.
4. Collate logon information for important sites: CAQH, NPPES, PECOS, state board, specialty board, etc.
5. Collect all information needed for credentialing and privileges for all providers in one easy place: CV, photo, license, board credentials, DEA, state registration, malpractice, references, etc. Keep copies of all credentialing applications in the same file.
6. Keep a licensing and privileges spreadsheet for all professionals so deadlines don’t take you by surprise. Include CPR, ALSC, DEA, state licenses, and board certification and recertification.
7. Never worry if you’ve locked your office, your file cabinet or your desk again. Your information is safe in the cloud.
8. Store important logons and passwords on the cloud along with instructions and know that if something happens to you, the business will recover quickly.
9. Have employees watch for health fairs and special events that your practice can participate in. Develop a calendar for community events that you can prepare for annually.

INFORMATION SHARING

1. Share files up to 2GB (images, video, audio, text)
2. Turn a folder into a public web page.
3. Start a secure referrers area and give access to those practices that refer to you. Stock it with FAQs, referral forms, maps and directions to your practice, and phone numbers and emails for communication. Keep a referrer satisfaction survey on their pod at all times.
4. Push the patient schedule into the cloud so any provider can check their schedule at any time from anywhere.
5. Store building or suite blueprints.
6. Develop a practice glossary to document all abbreviations and specialty-specific terminology – very helpful for new employees and transcriptionists.
7. Make a secure education area for your patients which they can access from your website or in your waiting area on iPads. Include websites, blogs, patient satisfaction and other surveys, health tracking programs, etc.
8. For those providers on productivity bonuses, push a productivity report to the cloud for them to review privately.
9. Put staff education programs on the cloud for new employee orientation and annual training on compliance, OSHA, HIPAA, fire safety and disaster communication plans.
10. Post photos of the office picnic or Christmas party, or the new baby, or the bride and groom.
11. Use the cloud as a digital scrapbook of events, new employees, new services, accolades, advertising or publicity.
12. Pass around a digital birthday greeting card to all staff except the one having the birthday!
13. Post a job on craigslist. Once you have a group of candidates you want to consider, give them a link to a folder with the position job description, benefits schedule and in-depth information about the hiring time line.
14. Post lunch menus for restaurants and take-outs within several miles of the practice so employees can get lunch efficiently and quickly.
15. Post the office schedule for the year showing which dates the office will be closed for holidays.
16. Post the call schedule and let your answering service and the hospitals view it.
17. Publish your weekly practice newsletter on the cloud – it becomes an instant record of when and how things were communicated.

BUSINESS MANAGEMENT

1. Scan invoices to the cloud for storage once youve paid them.
2. Scan invoices to the cloud for an external bookkeeper to access and pay them.
3. Scan invoices to the cloud for a physician to approve them for payment.
4. Scan the daily accounts receivable work (EOBs, checks, deposit slips, denials, reconciliations) to the cloud and shred the originals at the interval of your choice.
5. Scan documents to the cloud when you are notified that employees are having monies withheld from their paychecks for child support or garnishment, or when they change their deposit information or retirement plan contribution.
6. Track the history of files and folders – when did we change this policy? When did we go to this compensation system? What was the original wording of this contract?
7. Generate reports on employee productivity, looking for patterns of collaboration and innovation.
8. Scan RAC, CERT, ZPIC and other audit letters when they come and keep a spreadsheet of dates records and appeals are due.

COLLABORATION

1. Have online meetings centered around documents in the cloud.
2. Post job protocols and empower employees to change protocols regularly as information and routines change.
3. Start a CME log for each provider that the providers can easily add to.
4. Have your employees collect stories, links and other items in the cloud to push to your Facebook page or website blog.
5. Keep minutes from physician meetings and request all physicians review, ask for changes and sign off.
6. Keep attendance and minutes from staff meetings and ask all staff to electronically sign the minutes.
7. Have each employee keep a continuing education log for face-to-face and online education.
8. Assign tasks. Place something on the cloud and assign staff to respond to it, change it, develop it or implement it.

INCREASE EFFICIENCY

1. Develop a How Do I? document for quick information new employees need to know and established employees may not remember. Some examples: How do I reach the inclement weather information line? What do I do if there is a blood spill in the practice?
2. For the manager – develop a staff roster with dates of hire, dates of birth, social security numbers, phone numbers, hourly wage and termination dates. One document will answer 25% of questions you have or others ask you every day.
3. Standardize protocols and information when you have multiple sites or divisions.
4. Show each employee how to keep their most-used files on their digital desktop to access without a logon and password.
5. Sync desktop folders to cloud folders automatically – documents are updated to the latest version without thinking about it.
6. Restructure your files and folders as many times as you want or need to. Rename files, move and copy files, and delete files if they are not serving the purpose you thought they would.
7. Expand the number of users instantly for special projects.
8. Put every form on the cloud, have employees complete them on the cloud, sign them electronically, then share them with you for your electronic signature.
9. Put new templates or forms on the cloud for everyone to draw from – eliminate old letterheads, logos, addresses, etc. instantly.

IMPROVE MOBILITY

1. Fax documents from the cloud to a fax machine.
2. Email files from anywhere.
3. Search for anything in your cloud by words or phrases. Never lose anything again!
4. Access the cloud from anywhere and from any device – smartphone, PC, iPad…
5. Put the patient schedule information into the cloud so if inclement weather hits, staff can access the schedule at home and contact patients about their appointments.
6. Access your business 24/7/365.

DAY-TO-DAY MANAGEMENT

1. Assign a folder for your CPA to be notified when financials are available for download, or for you and the physicians to be notified when s/he finishes the financials or taxes.
2. Assign a folder for your benefits broker to be notified when new employee applications for medical and dental benefits are available for download.
3. Assign a folder for your banker to be notified when quarterly financials are available for download.
4. Assign a folder for your physicians/owners to be notified when monthly or quarterly financials are available for their review.
5. Post practice calendars for paid time off requested and approved.
6. Develop a physician referral resource tool if your PMS does not organize that information well. Create your own spreadsheet with all the fields of information that are important to your practice and have all employees add to it and correct it routinely. Have someone in the practice or a temp or prn person call every practice/group on the list twice a year and confirm all the pertinent information.
7. Post a Who Covers Whom list that spells out who covers primary responsibilities in the practice when someone is out of the office. Building your team 3 deep (for every primary task, there are at least 3 people that can perform that task) is crucial for reducing vulnerability.
8. Video new employees answering a few questions about themselves and post it on the cloud for all staff to view.
9. Put video of all staff introducing themselves and telling what they do on the cloud for new employees to view.
10. Video benefit providers discussing benefits so employees can watch at any time - medical insurance, dental insurance, vision insurance, short and long-term disability, life insurance and retirement benefits. Employees will get more out of and become more aware of what their benefits are.
11. Make an easy-reference spreadsheet with the payer contracts listed and images of the plan cards for staff to be able to identify the contracts and plans in force at any given time.
12. Keep personnel files on the cloud. You may choose to have a file of documents the employee may see and get a copy of, and a file of documents they may not see or get copies of. Both can be a part of the same folder.
13. Store scripts for your messages on hold, your after-hours message and your scripting for employees.

SAVE MONEY

1. Increase storage space without buying any hardware or software.
2. Scan charts into the cloud as a preliminary repository before implementing EMR, or scan charts of inactive patients in so you don’t have to pay to store them offsite.
3. Never back-up your documents on your computer again.
4. Put your triage algorithm or flow sheet on the cloud. Hire nurses to triage from home.
5. If a manual doesn’t come electronically, scan it onto your cloud. Check the manual before you call the repairman.
6. Preserve your valuable employee knowledge – have each department develop a folder with the important resources for their staff. The billing department may have websites they refer to for coding questions, a primer on evaluation and management coding, a cheat sheet on standard practice fees, and a calendar for the times of the year that different updates and revisions to CPTs, ICDs and NCCI edits.

Publications For Your Medicare Beneficiaries
New! The Medicare Learning Network (MLN) has released a new product titled Publications For Your Medicare Beneficiaries. This factsheet lists a variety of beneficiary-related publications available to assist providers in responding to patients questions related to Medicare, all of which can be printed and provided to patients. This product is available in downloadable format here. Check it out – links to more than 70 different publications!

The 2007 Physician Quality Reporting Initiative
New! Anew Medicare Learning Network publication titled The 2007 Physician Quality Reporting Initiative (PQRI) (November 2010) is now available in downloadable format here. This booklet is a compilation of CMSs various educational resources relevant to the 2007 Physician Quality Reporting Initiative.

Guidelines for Teaching Physicians, Interns, and Residents
The Guidelines for Teaching Physicians, Interns, and Residents (revised December 2010) is now available in downloadable format here. This factsheet provides information about payment for physician services in teaching settings, general documentation guidelines, and evaluation and management documentation guidelines.

HIPAA EDI Standards Web-Based Training
The Medicare Learning Network is now offering therevised HIPAA EDI Standards web-based training (revised January 2011) for CE credit. The goal of this activity is to provide information to physicians, suppliers, and healthcare professionals regarding electronic billing and other healthcare electronic transactions such as the Administrative Simplification provisions of HIPAA, electronic transaction standards and code sets required by HIPAA, and an overview of the steps involved in the Medicare electronic data interchange process. To take this training, go here and click on Web-Based Training Modules under Related Links Inside CMS. There are 15 other web-based training classes available on the same site.

Understanding the Remittance Advice: A Guide for Medicare Providers, Physicians, Suppliers and Billers
The publication titled Understanding the Remittance Advice: A Guide forMedicare Providers, Physicians, Suppliers and Billers (revised October 2010) is designed to educate institutional and professional providers who bill Medicare with general remittance advice (RA) information. It includes instructions to help you interpret the RA received from Medicare and reconcile it against submitted claims and provides guidance on how to read Electronic Remittance Advices (ERAs) and Standard Paper Remittance Advices (SPRs), as well as information on balancing an RA. This publication may be downloaded here. If you are training an employee to be a biller or post payments, or if you want to understand more about your billing yourself, this is an excellent resource.

Evaluation and Management Services Guide
The publicationtitled Evaluation and Management Services Guide(revisedDecember 2010) is now available in downloadable format from the Medicare Learning Network here. This guideis designed to provide education on medical record documentation and evaluation and management billing and coding considerations. The 1995 Documentation Guidelines for Evaluation and Management Services and the 1997 Documentation Guidelines for Evaluation and Management Services are included in this publication. This is another great resource that you can use to train staff, physicians, and other providers, or to get up to speed yourself if E & M codes are not part of your education or experience.

Image Credits:

Dancing Seniors: Image by StevenM_61 via Flickr

Money Rainbow: Image by TW Collins via Flickr

Note: I get great pleasure in finding resources for my readers, and today I have a showstopper! Carol Flagg is co-owner of HITECH Answers and is visiting Manage My Practice to announce a free resource for eligible providers and hospitals.

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For the past two years HITECH Answers has been a vendor neutral resource for education on details of the HITECH Act. In that time, weve amassed a significant library of recorded webinars for viewing, along with a body of exclusive white papers and research.

But the time for analyzing the HITECH Act has ended. Similar to the purpose served by the 62 Regional Extension Centers (RECs) , our goal is to support as much as we can the process of adoption of a certified EHR system that meets meaningful use criteria. Given the sheer number of health care providers needing significant help and guidance through this process, we have transitioned our existing web-based subscription model to function as a Virtual Extension Center.

This Virtual Extension Center, or VEC, supports health care providers and hospitals looking for education and analysis throughout the HITECH life cycle in a 100% virtual environment. In a nutshell, our VEC widens the education circle and opportunity for all Eligible Professionals and Eligible Hospitals. Weve also made membership to our VEC completely free for EPs and EHs for the entire life cycle of the HITECH Act.

So what, exactly, is the VEC? And how does it function?

First and foremost, this newly created VEC houses all of the existing recorded training material and research accumulated over the past two years. This information is readily accessible upon members logging on to HITECH Answers. Heres what has been added to round out VEC membership:

• Meaningful Use for EPs and EHs Live webinar events hosted twice a month that focus specifically on the details for achieving Stage 1 meaningful use for EPs and EHs.
• Upcoming live web casts on tax implications for incentives for EPs and EHs, workflow, ICD-10 migration, HIPAA security assessment, the pros and cons of SaaS, EHR contract negotiation and more.
• Live web cast for our VEC members who are vendors and HIT consultants that address pressing topics and needs in conducting business in this industry.
• Attendance to live webcast interviews and presentations from leading national experts.
• Access to exclusive white papers and research found only in our VEC.
• Direct access to independent experts to help answers your specific questions.

An obvious large part of the VEC will be our live events. We debut our event offerings with these two important topics Meaningful Use for Specialists andEHR Contract Negotiations.

Meaningful Use for Specialists Qualifying for CMS EHR Incentives

January 18, 2011, 7 pm EST

Event summary: A first glance at the Stage 1 Core and Menu Set objectives makes sense for primary care, but what about specialists? How can Psychiatrists, Oncologists, Radiologists, Urologists, and other specialists meet the requirements and objectives outlined in CMS EHR Incentive Program? EPs that are specialists can still achieve the CMS incentives based on the flexibility that is incorporated into two primary areas: Menu Exclusions and Quality Measures.

EHR Contract Negotiations: Q & A with William OToole, OToole Law Group

January 25, 2011, 7 pm EST

Event summary: The HITECH Act of the American Recovery and Reinvestment Act of 2009 is driving new technology acquisitions unlike anything seen in the healthcare information technology (HIT) sector since Y2K. Specific terms and warranties in Electronic Health Record (EHR) agreements are absolutely essential for the protection of provider customers. Competent and experienced legal advice is extremely important. Get your questions answered in this special Q & A session.

You can visit our Events Page to learn more about these sessions.

And you can learn more about qualifying for a free membership at Become A Member or you can contact me at: carol@hitechanswers.com.

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Disclosure from Mary Pat: HITECH Answers sells my book on their site, and I am a Consulting Expert to HITECH Answers.