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 $2.9 billion 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 29 percent 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 Part B 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.
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 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 Network’s® publication here.
NOTE: We have just added an educational webinar on using the ABN form. This is an expanded webinar with 75 minutes of content and 15 minutes of Q & A with the attendees. Click here to go to our webinar page for more information.
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 beneficiaries are 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
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.
I have known of Transworld Systems for almost as long as I’ve been in healthcare – a long time. But it wasn’t until I got to know Karen Cooper from Transworld Systems that it came home to me what a difference a company representative can make in the ultimate success of the service.
Karen has been with Transworld for 10 years (the company has been in business for 41 years), moving to a sales job with the company after getting her MBA and getting her kids started in elementary school. She looked for the right job for a year and a half and even though she had never been in sales before, she knew she could leverage her professional experience and education to great advantage in full-service collections.
Although not exclusively working with healthcare clients, Karen loves the medical market and enjoys the “lingo” that is so specific to medical practices and hospitals. She has seen many changes in healthcare over the past 10 years, particularly physicians’ interest in and acceptance of a business approach to collections. With patients having responsibility for more of the healthcare bill, physicians and managers are turning to specialists to do the staff-intensive chore of collections.