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What Practices Should Do About ICD-10 – Forget About It!

When Should Practices Start to Panic Again About ICD-10?

 

 

 

 

 

 

 

 

 

 

 

 

 

Everywhere I look, I see articles about staying the course with ICD-10 between now and October 1, 2015. Staying the course means learning ICD-10 and ultimately coding all services in ICD-9 and ICD-10 simultaneously, called dual coding.

Dual coding (double work) for the next 17 months?

I don’t think so.

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Posted in: Collections, Billing & Coding, Compliance, Day-to-Day Operations, Headlines, ICD-10

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Start Your Own Private Practice in Five Easy* Steps

Five Steps to Starting a New Private Practice

Medicine is a complex and critical art, and the business behind patient care is very complex in its own right. Rising costs, stagnant reimbursements, Meaningful Use, Obamacare and ICD-10 are just some of the NEW challenges facing private practices, and because of it, many physicians are opting to sell to a larger group, or close and seek employment in a system or hospital.

With all of this going on, it’d be easy to say someone would have to be crazy to face the massive undertaking of starting a new practice in this environment.

I respectfully and completely disagree.

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Posted in: Day-to-Day Operations, Headlines, Innovation, Leadership

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Medicare Physician Payments: Data Release Is Good and Bad!

Expensive Drugs Cause Physician Payments for Some Specialties to Look Disproportionate

The big headline on Wednesday was the Centers for Medicare and Medicaid Services’ (CMS) identification of 2012 physician payments. Included in the data is the providers’ names, addresses, specialties, billing rates, the amount paid by Medicare, number of Medicare beneficiaries and number of services provided for every Medicare provider. Note that only procedures performed on more than 10 patients were included and data on durable medical equipment (think canes and walkers) was not included. USA Today published a nice interactive map of payments by state here.

This is a good thing and a bad thing.

Why is it a good thing?

  • It promotes pricing transparency, although anyone can go to the Medicare Physician Fee Schedule lookup site and find out what a physician gets paid for services. For that matter, Medicare patients get individual statements showing what their physicians are paid, as well as quarterly statements showing all Medicare payments on their behalf for the past three months. So what Medicare pays has been available to the public for a long time, although not cumulatively.
  • Might the publication of data bring to light the fraudulent providers? it’s certainly possible. But shouldn’t Medicare have already found the physicians whose billings seems out of proportion to the average physician of that specialty?

Why is it a bad thing?

  • Sensationalism: As with all things healthcare these days, it makes for sensational headlines. CNNMoney says “Doctors make Millions Off of Medicare.” What does that smack of, if not that all physicians are getting rich off the taxpayer dollar? CNN states “…nearly 4,000 are Medicare millionaires.” If Medicare is the motherload, why are physicians closing their doors to Medicare patients, or limiting their panels? Why don’t all doctors see ONLY Medicare patients, if it is such a sweet ride?
  • They make how much? Medicare payments to physicians do not equate with physician’s take home pay. Revenue is used to pay for staff, medical equipment, technology, rent, utilities, and drugs, to name a few. Expenses in medical practices take between 50 and 75 cents of every dollar that a practice receives.
  • Who really got paid? Payments are categorized by National Provider Identifier or NPI, and it is often the case that clinicians working for or under the physician (for instance Nurse Practitioners or Physician Assistants) bill and are paid under the physician’s NPI.
  • Drugs tip the scale: Some of the most costly Medicare payments are for drugs, so while it may seem that the physician is receiving a hefty payment for administering a drug (during chemotherapy, for instance), the majority of that payment is to reimburse the practice for the drug, as Medicare only allows physicians to charge 6% above the average wholesale price, which has to cover the practice’s expense for ordering, receiving, storage, mixing, payment, documentation, and disposal.
  • Clean data? Physicians were not given an opportunity to review the data before it was released and bring any errors to the attention of CMS.
  • Only part of the overall picture: The data only covers original Medicare services, not those provided to Medicare Advantage (replacement) plans or to Medicaid, nor does it report on any commercial payers or self-pay patients.
  • Meaningful data? There is nothing to qualify the acuity of the patients, the age of the patients, or the quality of the care. When proponents state that consumers can use this data to make better care choices, I have no idea what they’re talking about.

Although my list of “bads” is longer than my list of “goods”, I ultimately believe the release of this data is a good thing because it draws back the veil of secrecy.

What do you think – is the publication of Medicare data a good thing or a bad thing?

This article was originally posted on LinkedIn via the Influencer Program.
Photo Credit: Phil and Pam via Compfight cc

Posted in: Headlines, Medicare & Reimbursement, Medicare This Week

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CMS to Hold Claims for 10 Days as of April 1, 2014

Breaking Healthcare Management News from CMS on the SGR.


MGMA (Medical Group Management Association) just reported the following announcement from the Centers for Medicare and Medicaid Services (CMS):
“The 2014 Medicare Physician Fee Schedule (MPFS) final rule stipulated a negative update to the MPFS that was to be effective January 1, 2014. That reduction was averted for three months with the passage of the Pathway for SGR Reform Act of 2013, which provided for a 0.5 percent update for services paid under the MPFS through March 31, 2014.

CMS is hopeful that there will be congressional action to prevent the negative update from taking effect on April 1, 2014. CMS has instructed the Medicare Administrative Contractors to hold claims containing services paid under the MPFS for the first 10 business days of April (i.e., through April 14, 2014). This hold would only affect MPFS claims with dates of service of April 1, 2014, and later. The hold should have minimal impact on provider cash flow, because under current law, clean electronic claims are not paid any sooner than 14 calendar days (29 days for paper claims) after the date of receipt. All claims for services delivered on or before March 31, 2014, will be processed and paid under normal procedures, regardless of any Congressional actions.”
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Posted in: Collections, Billing & Coding, Day-to-Day Operations, Finance, General, Headlines, Medicare & Reimbursement

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5 Ways Your Medical Practice Can Avoid Being “Targeted”

This article first appeared on LinkedIn.

5 Ways Your Medical Practice Can Avoid Being "Targeted"

Everyone in the retail, security, and banking business has probably been fielding a lot of questions about the “Target Breach” recently.

For those who have not heard, in December 2013 and January 2014 Target announced that hackers had gained access to the internal servers of the chain of stores, and had used that access to install a virus on Target’s point of sale credit card swipers. The virus collected credit card and PIN (Personal Identification Number) information, and stored it secretly on the servers where the hackers could later go back in and retrieve it. Once the hackers had that in place, they were also able to gain access to other Target databases with email, address and phone records. In all, 40 million credit card numbers and 70 million personal records were compromised.

The fallout has been ugly. Last week, Target’s CIO Beth M. Jacob resigned over the failures. In February the chain announced quarterly earnings were down 46% in the 4th quarter, and on a personal note, a new debit card just arrived in my mailbox.

Medical practices are used to having to secure information under HIPAA laws, and should already have policies in place for any credit card information they come into contact with. It is easy to see why a retail chain would garner a lot of attention from cyber criminals, but as loopholes are tightened and more people are aware of the dangers of hacking and the need for security, smaller businesses will begin to show up on hackers’ radar.

So how do you avoid being the next, ahem, Target? Here are five ways your practice can protect itself.

1. Start a Credit Card on File System

We probably get more questions about credit card security than most consultants because we are such big proponents of medical practices using a credit card on file program. However, we think keeping the patient’s card on file, offsite, in an encrypted payment gateway reduces the liability for the practice because there are less human touches in the process that can invite fraud. Consider: If you let patients swipe their cards at every checkout for time of service payments, then their card data is exposed at every visit. If the card is handed to an employee to swipe, not only is the card exposed magnetically, it’s exposed to another human being. With a credit card on file system, after the initial swipe, any employee can never see more than the last four digits, and the patient doesn’t even have to bring the credit card to the visit, or enter the PIN during the visit.

On top of that, when you no longer send out statements, you provide extra protection to patient financial and health data by not sending it through the mail.

2. Review your financial and security policies.

Audits reviewing breaches of Protected Health Information (PHI) and protected Payment Card Industry (PCI) data focus less on the actual events that led to the breach, and more on the culture, policies and environment the breach occurred in, and how that contributed to the incident. If a breach was disclosed tomorrow, how could your organization prove to an external reviewer that you had “fostered a culture of compliance”?

The best place to start is with policies. Annual HIPAA, OSHA and billing compliance training, data security, physical and administrative safeguards, how information is stored and retained – all of these are critical ways that your organization sets the tone for compliance, and defines in clear, black and white terms what is expected of the employees.

3. Create a culture of compliance, privacy and respect.

This is a no-brainer for medical practices and entities that have to comply with HIPAA, but this has to be extended to financial data as well. More than individual policies, rules and regulations, an office’s culture is the accumulation of norms, practices and relationships that guide how things are done in any given situation. If you have great policies in place, but the culture of the office dictates that they aren’t followed, or are only followed under ideal conditions, you are still at a great risk for a breach.

Consider this question: How often would you say “policy” is completely followed by employees, down to the letter? 75%? 80%? 90%? Culture is the difference between intention and execution, and as Peter Drucker famously said – “Culture eats strategy for lunch”.

4. Talk to your vendors.

Credit card processing for medical practices, whether traditional or in an “on file” system, is a very competitive business. Average sales are high, volume is steady, and there is less fraud than usual. So not only should you make sure you are negotiating for the best possible rate, you should also be making sure your credit card gateway and processor are giving you all the tools you need to keep your patient financial data safe.

Ask your vendors what else you can be doing to stay secure and compliant. Do they have training materials or other resources you can use to keep your staff sharp? These vendors are thrilled to have your business – use them!

5. Talk to your customers.

Be proactive! Most patients think privacy notices and HIPAA documents are “just paperwork” that gets shuffled to them on visits when all they really want to do is see the doctor! With the breaches at Target and elsewhere, this is the perfect time to start a conversation with your patients about how you can do more to communicate with them, and involve them in their security.

After reviewing your policies, let your patients know what you are doing to keep their information safe. Talk about new developments or changes in the framework of their protection, but most of all, have the conversation before a breach – not in response to one.

The battle between network security and hackers will probably never end. As attacks and defenses become more sophisticated, the playing field may change, but good habits ingrained by culture will always set the table for success. Use these five tips as a jumping off point, and start taking security seriously today.

Posted in: Collections, Billing & Coding, Compliance, Day-to-Day Operations, Finance, Headlines, HIPAA

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The Reports of the Death of the Independent Practice Have Been Largely Exaggerated

The Reports of the Death of the Private Practice have been largely ExaggeratedMonday’s New York Times feature New Law’s Demands on Doctors Have Many Seeking a Network” interviews two practices in Louisville, Kentucky — one owned by the hospital and one owned and operated independently by a physician. The article illuminates many of the hurdles that all physicians are working to overcome: insufficient reimbursement, rising regulatory and compliance costs, and a seismic change from volume to value due to the Affordable Care Act (aka Obamacare). The piece wasn’t meant to be a report on the independent physician as a whole — just a profile of two practices responding the changing dynamic of the industry.

Why Hospitals Can Do What Independent Practices Can Not

One of the things that stood out starkly for me in the article was the Medicaid discussion. Most physicians would like to care for at least some Medicaid patients if their practice can afford it. The article emphasized that the hospital-employed physician, Dr. Jonsson, could see Medicaid patients because the hospital will recoup some of those fees by serving Medicaid patients in other areas of the hospital, particularly ancillary services such as lab and imaging, and potentially outpatient or inpatient procedures or surgeries. In addition, the hospital has a community mission to fulfill. The independent physician Dr. Ragland, on the other hand, has to be very careful about taking Medicaid patients as she has no other potential fees from Medicaid patients to offset office visits as a “loss leader” and she is not a non-profit entity. She is a small business trying to make a go of it.

Hospitals are required by law to see any patients who come to the Emergency Room, whether or not the ER is the right level of care for the patient’s medical problem. It is in the hospital’s best interest to redirect patients away from the ER and into primary care practices such as Dr. Jonsson’s. Hospital-owned practices currently have the ability to charge more for the same office visit than independent practices do, and most payers will pay the larger charge! Just this week, Highmark (Blue Cross of PA) said that as of April 1, 2014, it will no longer pay more for the same care rendered in a hospital-owned practice than it will in an independent practice. Many physicians employed by hospitals don’t realize that their patients are receiving two bills for care — one for the physician’s care and one for the use of the facility, and that the patient has to shoulder an additional financial burden because of it. It will be interesting to see if hospitals begin to winnow their employed physician numbers if all payers follow Highmark’s lead.

Who Is Hospital Employment Right For?

There is no doubt in my mind that hospital employment is the right choice for many physicians. For a physician right out of residency with big loans to pay, a guaranteed paycheck can be the right thing. For physicians who are tied to their current practice by partnership agreements and a heavy debt burden, selling to the hospital can be the way to untangle from big buildings, costly medical equipment and an expensive electronic medical record system (EMRs) and eventually, emerge back into private practice with a clean financial slate and a desire to restart small.

How Physicians Can Afford to Be in Independent Practice in 2014

Starting small and possibly staying small is the advice I give to most of the physicians who approach me about starting a new practice. Today, physicians can have their own practice with any of a number of new models that allow them to start lean and stay lean. Some of these models are:

  • Micropractice – a physician and a computer
  • Direct Primary Care (DPC) – the patient pays a monthly fee for all primary care and has insurance for specialists, tests and hospitalization
  • Cash Practice (may be called Concierge) – no insurance accepted, an annual fee for all care from a primary care physician or specialist
  • Traditional Insurance Practice With Limited Medicare or Medicaid
  • Traditional Insurance Practice Without Medicare or Medicaid – accepting commercial insurance only which eliminates the requirement for EMR, Meaningful Use (MU) and other compliance mandates
  • House Call Practice – a physician and a computer
  • Telemedicine – a physician and a computer
  • Nursing Home Practice – a physician and a computer
  • Visiting Surgeons – a physician and a computer seeing patients in the Primary Care Physician’s practice

These models all address the Big Three traditional financial barriers to independent practice. They are:

The Office

The physical space of the physician’s office has changed drastically in recent years. With electronic record storage, a single doctor with a laptop or tablet in a patient room can be the entire practice. Physicians can rent space from other practices or systems with available space, or find office space intheir own home, a time share medical space or a non-medical office building. Telehealth can even completely eliminate the need for office space under certain circumstances.

The Technology

Practice Management (PM) and Electronic Medical Records (EMR) software has always been a big investment for practices, independent, affiliated or otherwise. Between hardware, software, training, and maintenance, the costs for implementing the PM/EMR programs could be a significant barrier to starting a practice – or even changing vendors. Today, the declining cost of computing and the availability of cloud-based storage and software has meant a significant reduction in costs, and a shift from large capital outlays at the beginning of the contract to monthly service operating costs that can be better controlled and planned for. Some packages are even available for free or on a freemium model.

The Management

The administrative burden, and pace of change in the industry can give physicians the sense that they can’t handle it all on their own. The marketplace for experienced management talent is competitive and expensive, and small practices are managing these costs in addition to all of the others. However, new networks of physicians like ACOs and new variations on the Independent Practice Association, as well as the widespread availability of cheap internet voice and video communications means that practices can bring in more resources — the negotiating power of an ACO, or IPA, or fractional administrator services via video — without losing their independence.

To be clear — it is tough out there, especially for the independents, and especially in primary care, which encompasses pediatrics, family medicine, OB/GYN, internal medicine and geriatrics. But physicians have options — a lot of them — and they have a lot of tools at their disposal that make it possible to practice on their own terms. For those willing to adapt to the new paradigm, it is a great time to be in independent practice.

This article was originally published on LinkedIn.

Posted in: A Career in Practice Management, Day-to-Day Operations, Electronic Medical Records, Headlines, Innovation, Medicare & Reimbursement, Practice Marketing, Quality

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Healthcare Social Media Review #48: The Listening Edition

Healthcare Social Media Blog Carnival Listening to Patients

Engagement is an extremely hot topic in the healthcare industry right now, and for this edition of the Healthcare Social Media Review we’re focusing on the often-forgotten “other half” of engagement: when you listen to what the patient population has to say. How is social media enabling you to understand what’s on your patients’ minds writ large? How is social media amplifying individual voices?

With that in mind, these are some of the posts we have been listening to intently.

In a prime example of how healthcare social media can “take the collective temperature” of  a population, Science Daily reviewed research from the Geisel School of Medicine at Dartmouth that declares:

Social networking sites, such as Facebook, have become immensely popular in recent years and present a unique opportunity for researchers to eavesdrop on the collective conversation of current societal issues.

Software maker Kareo’s “Getting Paid” blog explores “3 Ways to Listen to Your Community and Better Engage Patients.”

Your patients are impacted by many things, and really engaging them means taking those things into consideration. This is where social listening comes in.

Social Media Examiner declared “Social Listening” one of 5 Social Media Trends for 2014.”

If you really want to see results, you need to listen and respond strategically.

At consultant Rebecca Morehead’s Practice Manager’s Solutions Blog, the bigger picture is painted in the post Improve Patient Satisfaction through Social Media Engagement.”

The important thing is to monitor, adjust and control the brand of your practice and the perception of you to your patients. That starts with knowing how important your patients are to you.

Are you suffering from delusions? The eHealth Equity Blog lists The 5 Health IT Myths of Patient Engagement.”

The most fundamental myth when discussing patient engagement is assuming that patients and consumers are interchangeable, when asking what a segment of the population wants from HIT.

At Mind the Gap, Steve Wilkins has a patient-centric approach that talks about teaching your panel to speak more clearly with How To Speak So Your Doctor Will Listen.”

Doctors interrupt patients 18 seconds into an office visit, on average. Given this fact, patients who seek to maximize their healthcare must learn how to speak so that doctors will listen.

The HealthBlawg was happy to host the Health Wonk Review in February and rounded up some of the latest policy developments in the industry for “Health Wonk Review: In Like a Lion.”

 As they say, reasonable minds may differ — and you’ll see a range of opinions on some of the issues of the day.

Over at Wing of Zock, they’re posting about a University of New Mexico mobile app that gives residents information and calculations about obtaining coverage under the ACA with University of New Mexico Residents Design #GetCovered App.”

As information [about Medicaid expansion in New Mexico] began appearing in the news and with ads on billboards encouraging people to enroll in the exchanges, I started brainstorming how to get the word out to many people simultaneously.

Next month’s Healthcare Social Media Review will be curated by Kathi Browne of BrowneKnows.

Thanks for reading!

Posted in: Headlines, Innovation, Social Media

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CMS Delays Two Midnight Rule: What Your Physicians and Patients Need to Know

The Centers for Medicare and Medicaid Services' Two Midnight RuleThe Centers for Medicare and Medicaid Services (CMS) announced several weeks ago that they were extending the “Probe and Educate” review of hospital payments under Medicare as part of the implementation of CMS-1599-F, better known as the “Two Midnight Rule.” This means that the regional Medicare Administrative Contractors (or MACs) will continue to audit claims made by hospitals for payment, but RACs (Recovery Audit Contractors) will “generally” not yet begin post-payment reviews, or audits that seek to draw money back from hospitals for payment of improper admissions or documentation. This “Probe and Educate” period, originally slated to end March 31st is intended to educate hospitals about necessary billing practices and ease the transition to the new rule before retrospective audits begin.

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Posted in: Compliance, Day-to-Day Operations, Finance, Headlines, Medicare & Reimbursement

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Goodbye Telehealth, Hello Connected Care

Telehealth rebranded as Connected CareAs physician advocates, telehealth – connecting patients and providers remotely through video, audio, and monitoring technologies – is one of the most exciting frontiers in care delivery. The industry is facing a constant torrent of change and reform, but is also newly armed with tools that allow medicine to be practiced on the patients’ and providers’ own terms.

The opportunity to provide a more convenient and accessible healthcare system, as well a one that is more coordinated and efficient is at the core of all this telehealth excitement. A newly formed lobbying organization is putting some serious political muscle behind the idea, and their first step is to re-brand telehealth all together. Say hello to “connected care!”

Some of the benefits of connected care are: (more…)

Posted in: Headlines, Innovation, Medicare & Reimbursement

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Will Windows XP Compromise Your HIPAA Security?

Microsoft XP Logo

 

 

 

 

 

 

If your practice is using desktop or laptop computers with Windows XP installed on them, you could be in for a rude awakening this spring. Microsoft has announced that after April 8, 2014 they will no longer support or release security patches for Windows XP.

What does “no longer support” actually mean?

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Posted in: Compliance, Day-to-Day Operations, General, Headlines, Medicare & Reimbursement

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