At Manage My Practice, we are big proponents of using a Credit Card on File (CCOF) system in medical practices to reduce expenses and improve cash flow. Knowing how your processing vendor’s pricing plan and security features work are critical to implementing this system. You have to be able to understand and negotiate your costs, and stay current on best practices and technology that keep your patients’ data safe.
Big changes are coming to the technology end of your credit card system in October of this year (as if you won’t be busy enough with ICD-10!) and you need to make sure now that you have all the details handled for your employees and your patients. The new technology is called EMV, or “Euro Mastercard Visa” and has been used in most of the rest of the world for awhile now.
Whenever we have questions about anything credit card related, we go straight to Michael Gutlove, Director of Merchant Services at IDT. Michael has been our own vendor, as well as our top recommendation to clients for almost three years now. We asked him to help us sort out the changes.
Mary Pat: Michael, what’s your background?
Michael: I’ve been helping business owners improve their bottom lines since 1997. Reducing costs are critical – now more than ever – for all business owners, and I’ve been able to repeatedly reduce operating costs by clearing away the traditional smoke and mirrors of credit card processing.
Mary Pat: Are people in general and patients specifically using credit cards more than they used to? Do you foresee a time when people will only use credit cards, no cash or checks?
Michael: While electronic payment volume has steadily increased year after year it’s highly unlikely that cash or checks will ever be completely eliminated. Cash payments serve the “underbanked” population and checks remain a highly effective method of payment for high ticket (luxury) items.
Mary Pat: What about payment via a smartphone or watch – do you see that becoming a predominant part of the American payment experience?
Michael: Apple Pay is the first mobile wallet solution that’s made any traction into the payment space. It’s opened the door for cell phone manufacturers, wireless carriers, and any/every technology company under the moon to think about getting involved. The problem with suggesting that mobile technology will replace the way we pay (or become the primary way we pay) is that it’s not fixing an existing problem. Mobile payments are generally viewed as a convenience as opposed to a necessity and we’ve become accustomed to carrying a wallet or purse with actual credit cards.
Mary Pat: The new acronym in credit cards is EMV. What is EMV?
Michael: EMV stands for Europay MasterCard Visa. It’s an acronym for the Global standard of chip card technology facilitating electronic payment transactions. The United States is the last major country to adopt this method.
Mary Pat: Why do readers need to know about EMV?
Michael: October 2015 marks the deadline for business owners, accepting credit or debit cards, to upgrade their terminals for chip card acceptance. While it is not legally necessary to upgrade, doing so reduces the liability for fraudulent or counterfeit duplicate transactions.
Mary Pat: What does accepting chip cards have to do with liability?
Michael: EMV prevents “card present” duplicate fraud as the customer always maintains possession of their card. Instead of swiping the mag-stripe on the back, merchants will instruct customers to insert cards into the EMV ready terminal and enter a PIN or signature when prompted. Businesses that do not have the ability to accept EMV cards will be held liable for fraudulent “swiped” transactions.
Mary Pat: Does EMV eliminate fraud?
Michael: EMV is not a cure all for all types of fraud. The programs put in place will help with duplicate card fraud charge-backs, but will not impact others. Visa, MasterCard, Discover, and American Express have different liability shift requirements.
Mary Pat: What about “Card Not Present” transactions?
Michael: EMV only applies to face-to-face transactions. When it was released in Europe increased levels of fraud showed up via ecommerce and MOTO (mail order/telephone order). A similar scenario is expected once the US adopts EMV making PCI-DSS compliance even more important.
Mary Pat: What is PCI?
Michael: PCI–DSS stands for the Payment Card Industry Data Security Standard. Most processors offer comprehensive programs to ensure PCI compliance and validation.
Mary Pat: What should I do now?
Michael: Reach out to your processor and determine your risk level for EMV. Accepting EMV can only help your business but it isn’t necessary to do anything prior to October. The majority of POS (point of sale) manufacturers haven’t released EMV readers and new hardware might not be necessary depending on your existing terminal make & model.
Making sure you are getting the most you can from your credit card vendor is a critical part of protecting your data and your bottom line in today’s healthcare industry. You need to know the steps you and your vendors are taking to safeguard patient data as well as being able to relay those steps back to patients and employees. That’s why it’s important for managers to understand EMV – and their credit card setup in general. Successful implementation of a credit card on file program or any credit card processing system will always require buy-in and communication.
NOTE: Credit Card on File clients of Manage My Practice should know that Michael Gutlove will be swapping out your current swipers for EMV terminals for chip and non-chip cards at a considerable discount.
For additional information, questions, or anything else credit card related feel free to reach out to Michael Gutlove at 201.281.1621.
Can Physicians Get Paid for Chronic Care Management?
Everyone was very excited when Medicare announced its policy to start paying in 2015 for Chronic Care Management (CCM) services – non face-to-face services that physicians have been providing to their patients for free for a very long time.
CPT 99490 is the CCM code that is defined by the AMA as:
Chronic care management services, at least 20 minutes of clinical staff time directed by a physician or other qualified health care professional, per calendar month, with the following required elements: Multiple (two or more) chronic conditions expected to last at least 12 months, or until the death of the patient, Chronic conditions place the patient at significant risk of death, acute exacerbation/decompensation, or functional decline, Comprehensive care plan established, implemented, revised, or monitored.
Physicians, Certified Nurse Midwives, Clinical Nurse Specialists, Nurse Practitioners and Physician Assistants may provide CCM services, however only one provider of any kind may submit a claim and be reimbursed for the service during any given month.
The code is reimbursed by the month and the national average reimbursement by Medicare is $42.91.
But the fly in the ointment has quickly surfaced – patients are not necessarily willing to agree to the services. A provider must inform eligible patients of the availability of and obtain consent for the CCM service before furnishing or billing the service.
Why wouldn’t a patient agree to the service?
Because they are responsible for the standard 20% cost-sharing (approximately $8.40) of the service after they have met their annual deductible of $147.00. Patients may decline to pay for something they’ve been getting for free, or something they feel they are already paying for through the cost of office visits.
Here are the Q&As Medicare Released Last Week
1. CPT code 99490 requires at least 20 minutes of time per calendar month by “clinical staff” in order to bill the code. Who qualifies as “clinical staff”? If the billing physician (or other appropriate practitioner) furnishes services directly, does their time count towards the required minimum 20 minutes of time?
In most cases, we believe clinical staff will provide CCM services incident to the services of the billing physician (or other appropriate practitioner who can be a physician assistant, nurse practitioner, clinical nurse specialist or certified nurse midwife). Practitioners should consult the CPT definition of the term “clinical staff.” In addition, time spent by clinical staff may only be counted if Medicare’s “incident to” rules are met such as supervision, applicable State law, licensure and scope of practice. If the billing physician (or other appropriate billing practitioner) provides CCM services directly, that time counts towards the 20 minute minimum time. Of course, other staff may help facilitate CCM services, but only time spent by clinical staff may be counted towards the 20 minute minimum time.
2. Can CCM services be subcontracted out to a case management company? What if the clinical staff employed by the case management company are located outside of the United States?
A billing physician (or other appropriate practitioner) may arrange to have CCM services provided by clinical staff external to the practice (for example, in a case management company) if all of the “incident to” and other rules for billing CCM to the PFS are met. Because there is a regulatory prohibition against payment for non-emergency Medicare services furnished outside of the United States (42 CFR 411.9), CCM services cannot be billed if they are provided to patients or by individuals located outside of the United States.
3. Does the billing practice have to furnish every scope of service element in a given service period, even those that may not apply to an individual patient?
It is our expectation that all of the scope of service elements will be routinely provided in a given service period, unless a particular service is not medically indicated or necessary (for example, the beneficiary has no hospital admissions that month so there is no management of a transition after hospital discharge).
4. What date of service should be used on the physician claim and when should the claim be submitted?
The service period for CPT 99490 is one calendar month, and CMS expects the billing practitioner to continue furnishing services during a given month as applicable after the 20 minute time threshold to bill the service is met (see #3 above). However practitioners may bill the PFS at the conclusion of the service period or after completion of at least 20 minutes of qualifying services for the service period. When the 20 minute threshold to bill is met, the practitioner may choose that date as the date of service, and need not hold the claim until the end of the month.
5. What place of service (POS) should be reported on the physician claim?
Practitioners must report the POS for the billing location (i.e., where the billing practitioner would furnish a face-to-face office visit with the patient). Accordingly, practitioners who furnish CCM in the hospital outpatient setting, including provider-based locations, must report the appropriate place of service for the hospital outpatient setting). Payment for CCM furnished and billed by a practitioner in a facility setting will trigger PFS payment at the facility rate.
6. CPT code 99490 is payable to hospital outpatient departments (provider-based locations) under the hospital Outpatient Prospective Payment System (OPPS). Can physicians practicing in these departments or in locations that are hospital-owned (but not provider-based) also bill this code to the PFS? What if the patient is a hospital or SNF inpatient or is otherwise in a Medicare “facility” or “institution?”
If the patient resides in a community setting and the CCM service is provided by or “incident to” services of the billing physician (or other appropriate billing practitioner) working in or employed by a hospital, CPT 99490 can be billed to the PFS and payment is made at the facility rate (if all other billing requirements are met). We discuss this further under the section below addressing billing for CCM furnished in the hospital outpatient department setting.
As we discussed in the CY 2014 PFS final rule, the resources required to provide care management services to patients in facility settings significantly overlap with care management activities by facility staff that are included in the associated facility payment. Therefore, CPT 99490 cannot be billed to the PFS for patients who reside in a facility (that receives payment from Medicare for care of that beneficiary, see 78 FR 74423) regardless of the location of the billing practitioner, because the payment made to the facility under other payment systems includes care management and coordination. For example, CPT code 99490 cannot be billed to the PFS for services provided to SNF inpatients or hospital inpatients, because the facility is being paid for extensive care planning and care coordination services. However if the patient is not an inpatient the entire month, time that is spent furnishing CCM services to the patient while they are not inpatient can be counted towards the minimum 20 minutes of service time that is required to bill for that month.
Billing practitioners in hospital-owned outpatient practices that are not provider-based departments are working in a non-facility setting, and may therefore bill CPT 99490 and be paid under the PFS at the non-facility rate. However, CPT 99490 can only be billed for CCM services furnished to a patient who is not a hospital or SNF inpatient and does not reside in a facility that receives payment from Medicare for that beneficiary.
7. Is a new patient consent form required each calendar month or annually?
No, as provided in the CY 2014 PFS final rule (78 FR 74424), a new consent is only required if the patient changes billing practitioners, in which case a new consent must be obtained and documented by the new billing practitioner prior to furnishing the service.
8. Is Medicare now paying separately under the PFS for remote patient monitoring services described by CPT code 99091 or similar CPT codes?
CPT 99091 continues to be bundled with other services for payment under the PFS. As per CPT guidance, CPT codes 99090, 99091 and other codes cannot be billed during the same service period as CPT 99490. However as discussed in the CY 2015 PFS final rule (79 FR 67727), analysis of patient-generated health data and other activities described by CPT 99091 or similar codes may be within the scope of CCM services, in which case these activities would count towards the minimum 20 minutes of qualifying care per month that are required to bill CPT 99490. But in order to bill CPT 99490, such activity cannot be the only work that is done—all other requirements for billing CPT 99490 must be met in order to bill the code, and time counted towards billing CPT 99490 cannot also be counted towards billing other codes.
9. If a physician arranges to furnish CCM services to his/her patients “incident to” using a case management entity outside the billing practice, does the billing physician need to ever see the patient face-to-face?
Yes, as provided in the CY 2014 final rule (78 FR 74425), CCM must be initiated by the billing practitioner during a comprehensive Evaluation & Management (E/M) visit, annual wellness visit (AWV) or initial preventive physical exam (IPPE). This face-to-face visit is not part of the CCM service and can be separately billed to the PFS, but is required before CCM services can be provided directly or under other arrangements. The billing practitioner must discuss CCM with the patient at this visit. While informed patient consent does not have to be obtained during this visit, it is an opportunity to obtain the required consent. The face-to-face visit included in transitional care management (TCM) services (CPT 99495 and 99496) qualifies as a comprehensive visit for CCM initiation. CPT codes that do not involve a face-to-face visit by the billing practitioner or are not payable by Medicare (such as CPT 99211, anticoagulant management, online services, telephone and other E/M services) do not meet the requirement for the visit that must occur before CCM services are furnished. If the practitioner furnishes a comprehensive E/M, AWV, or IPPE and does not discuss CCM with the patient at that visit, that visit cannot count as the initiating visit for CCM.
10. Do face-to-face activities count as billable time?
CPT 99490 describes activities that are not typically or ordinarily furnished face-to-face, such as telephone communication, review of medical records and test results, and consultation and exchange of health information with other providers. If these activities are occasionally provided by clinical staff face-to-face with the patient but would ordinarily be furnished non-face-to-face, the time may be counted towards the 20 minute minimum to bill CPT 99490. However, see #11 below regarding care coordination services furnished on the same day as an E/M visit.
11. Medicare and CPT allow billing of E/M visits during the same service period as CPT 99490. If an E/M visit or other E/M service is furnished the same day as CCM services, how do I allocate the total time between CPT 99490 and the other E/M code(s)?
Under longstanding Medicare guidance, only one E/M service can be billed per day unless the conditions are met for use of modifier -25. Time cannot be counted twice, whether it is face-to-face or non-face-to-face time, and Medicare and CPT specify certain codes that cannot be billed for the same service period as CPT 99490 (see #12, 13 below). Face-to-face time that would otherwise be considered part of the E/M service that was furnished cannot be counted towards CPT 99490. Time spent by clinical staff providing non-face-to-face services within the scope of the CCM service can be counted towards CPT 99490. If both an E/M and the CCM code are billed on the same day, modifier -25 must be reported on the CCM claim.
12. Medicare and CPT specify that CCM and TCM cannot be billed during the same month. Does this mean that if the 30-day TCM service period ends during a given calendar month and 20 minutes of qualifying CCM services are subsequently provided on the remaining days of that calendar month, CPT code 99490 cannot be billed that month to the PFS?
CPT 99490 could be billed to the PFS during the same calendar month as TCM, if the TCM service period ends before the end of a given calendar month and at least 20 minutes of qualifying CCM services are subsequently provided during that month. However we expect that the majority of the time, CCM and TCM will not be billed during the same calendar month.
13. Are there any other services that cannot be billed under the PFS during the same calendar month as CPT 99490?
Yes, Medicare does not allow CPT 99490 to be billed during the same service period as home health care supervision (HCPCS G0181), hospice care supervision (HCPCS G0182) or certain ESRD services (CPT 90951-90970) because care management is an integral part of all of these services. Also see CPT coding guidance for a list of additional codes that cannot be billed during the same month as CPT 99490. There may be additional restrictions on billing for practitioners participating in a CMS model or demonstration program; if you participate in one of these separate initiatives, please consult the CMS staff responsible for these initiatives with any questions on potentially duplicative billing.
14. Can I bill CPT 99490 if the beneficiary dies during the service period?
CPT 99490 can be billed if the beneficiary dies during the service period, as long as at least 20 minutes of qualifying services were furnished during that calendar month and all other billing requirements are met.
15. Will practitioners be able to use an acceptably certified electronic health record (EHR) technology for which certification expires mid-year in order to bill for CCM? For example, can they use technology certified to the 2011 Edition to fulfill the scope of services required to bill CPT 99490 in 2015 once this technology no longer bears a “2011 Edition certified” mark?
Yes. Under the CCM scope of services, practitioners must use technology certified to the Edition(s) of certification criteria that is acceptable for the EHR Incentive Programs as of December 31st of the year preceding each CCM payment year. In certain years, this may mean that practitioners can fulfill the scope of services requirement using multiple Editions of certification criteria. For instance, for payment in 2015, practitioners may use technology certified to either the 2011 or 2014 Edition of certification criteria to meet the EHR scope of service requirements, as both Editions could be used to meet the requirements of the EHR Incentive Programs as of December 31, 2014. This remains true for a given PFS payment year even after ONC-Authorized Certification Bodies (ONC-ACBs) have removed the certifications issued to technology certified to a given acceptable edition (e.g., the 2011 Edition for CCM payment in 2015) as a result of the relevant criteria being removed from the Code of Federal Regulations. Thus, practitioners using an acceptable EHR technology that loses its certification mid-year may still use that technology to fulfill the certified EHR criteria for billing CPT 99490 during the applicable payment year.
16. Does the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA, P.L. 114-10) affect the billing rules for CCM services?
No, Section 103 of the MACRA codifies payment broadly for chronic care management services under the PFS, authorizing PFS payment after January 1, 2015, for CCM services furnished by physicians and the non-physician practitioners that Medicare generally recognizes to furnish and bill for E/M services (physician assistants, nurse practitioners, clinical nurse specialists and certified nurse midwives). It does not impact the current billing and payment rules for CPT 99490. It provides that provision of an AWV or IPPE in advance shall not be a condition of payment for CCM services, which is consistent with our current policy. It also provides that payment shall not be duplicative of other Medicare payments, consistent with the rules we have implemented to date regarding duplicative payment for CPT 99490.
17. Where can I find more guidance on CCM billing requirements?
A Fact Sheet on CCM is available on the CMS website here.The scope of service elements and other requirements for billing CCM to the PFS are also laid out in the CY 2014 and CY 2015 PFS final rules (CMS-1600-FC, CMS-1612-FC and CMS-1612-F2, available on the CMS website here. Most of the requirements were finalized in the CY 2014 PFS final rule, effective CY 2015. The CY 2015 final rule with comment period and correction notice address supervision and other “incident to” rules, electronic health record and other electronic technology requirements, valuation, and intersection with CMS’ care coordination models and demonstrations. Regarding the intersection with CMS’ care coordination models and demonstrations, please consult the CMS staff responsible for those projects. You may also direct questions to your Medicare Administrative Contractor.
18. Are hospital outpatient departments (HOPDs) eligible to bill CPT code 99490 under the OPPS?
Yes, CPT code 99490 is payable under the OPPS when certain requirements are met (see details in question #19 on billing requirements). As CPT code 99490 is defined as a physician-directed service, the OPPS provides payment to the HOPD when the hospital’s clinical staff furnishes the service at the direction of the physician (or other appropriate practitioner). Payment under the OPPS represents only payment for the facility portion of the service. Payment for the physician’s (or other appropriate practitioner’s) time directing CCM services in the HOPD setting is made under the PFS at the facility rate.
19. What are the requirements to bill CCM under the OPPS?
CPT code 99490 is a physician-directed service that is only payable under the OPPS when the hospital’s clinical staff furnishes the service at the direction of the physician (or other appropriate practitioner). The billing physician or practitioner directing the CCM services must meet the requirements to bill CCM services under the PFS, when the CCM service is furnished in the physician office or the hospital outpatient department. Specifically, a hospital outpatient department may bill and be paid for CCM services furnished to eligible hospital outpatients under the OPPS if the hospital’s clinical staff furnishes at least 20 minutes of care management services under the direction of the physician (or other appropriate practitioner) during the calendar month and the billing physician or practitioner directing the CCM services satisfies the billing requirements for CPT code 99490 under the PFS including the following requirements:
Patient Eligibility—Patient has multiple (two or more) chronic conditions expected to last at least 12 months or until the death of the patient, and that place the patient at significant risk of death, acute exacerbation/decompensation, or functional decline.
Patient Agreement— Patient consent to receive CCM services has been obtained by the practitioner and documented in the medical record.
CCM Scope of Service Elements including Structured Data Reporting, Care Plan, Access to Care, and Care Management of the patient are furnished by the hospital.
Hospital furnished the CCM services using a version of certified EHR that is acceptable under the EHR Incentive Programs as of December 31st of the calendar year preceding each Medicare PFS payment year (referred to as “CCM certified technology”). The hospital must also meet the requirements to use electronic technology in providing CCM services, such as 24/7 access to the care plan, and electronic sharing of the care plan and clinical summaries (other than by fax), specified in the CY 2014 and CY 2015 PFS final rules.
20. How does CMS define a “hospital outpatient” for whom a hospital may bill CCM services (CPT code 99490)?
Per section 20.2 of publication 100-04 of the Medicare Claims Processing Manual, a hospital outpatient is a person who has not been admitted by the hospital as an inpatient but is registered on the hospital records as an outpatient and receives services (rather than supplies alone) from the hospital. Since CPT code 99490 will ordinarily be performed non face-to-face (see # 10 above), the patient will typically not be a registered outpatient when receiving the service. In order to bill for the service, the hospital’s clinical staff must provide at least 20 minutes of CCM services under the direction of the billing physician or practitioner. Because the beneficiary has a direct relationship with the billing physician or practitioner directing the CCM service, we would expect a beneficiary to be informed that the hospital would be performing care management services under their physician or other practitioner’s direction.
21.When CCM services are furnished by a physician in a hospital outpatient department, can the physician and the hospital both bill Medicare for the CCM service?
Yes, when certain conditions are met. Specifically, when CCM services are furnished by a physician in a hospital outpatient department to an eligible patient, the physician may bill Medicare for CPT code 99490 under the PFS reporting place of service (POS) 22 (outpatient hospital), which will indicate that PFS payment should be made at the facility rate, and the hospital may bill for CPT code 99490 under the OPPS.
22. Can more than one hospital bill and be paid for furnishing CCM services if the patient has been a registered hospital outpatient at more than one hospital over a 12 month span? If only one hospital can bill and receive payment for CCM services, which hospital is allowed to bill?
CPT code 99490 is only payable under the OPPS when the hospital’s clinical staff furnishes the CCM service at the direction of a qualified physician (or other appropriate practitioner). As only one physician or practitioner is allowed to bill under the PFS for CPT 99490 during a calendar month service period, accordingly, only one hospital is allowed to bill and be paid for CPT code 99490 for a particular beneficiary during a calendar month service period. We would expect the hospital billing for CPT code 99490 under physician direction to have access to the patient’s consent to receive CCM services documented in the patient’s medical record. The patient may choose a different practitioner to furnish CCM at the conclusion of the service period, at which time the practitioner assuming the provision of CCM services will be required to have the patient consent of CCM services documented in the patient’s medical record. New patient consent is only required if the patient chooses a new practitioner to furnish CCM services, in which case a new consent must be documented in the patient’s medical record prior to furnishing the service.
23. Is CPT code 99490 payable to provider-based hospital outpatient departments under the hospital Outpatient Prospective Payment System (OPPS)? May a hospital-owned practice that is not provider-based bill the OPPS for CCM services?
A provider-based outpatient department of a hospital is part of the hospital and therefore may bill for CCM services furnished to eligible patients, provided that it meets all applicable requirements. A hospital-owned practice that is not provider-based to a hospital is not part of the hospital and, therefore, not eligible to bill for services under the OPPS; but the physician (or other qualifying practitioner) practicing in the hospital-owned practice may bill under the PFS for CCM services furnished to eligible patients, provided all PFS billing requirements are met.
24. What is the supervision level for CCM services furnished in the hospital setting?
CPT code 99490 is assigned a general supervision level under the OPPS when furnished in the hospital setting. General supervision means the procedure is furnished under the physician’s overall direction and control, but the physician’s presence is not required during the performance of the procedure. Under general supervision, the training of the non-physician personnel who actually perform the procedure and the maintenance of the necessary equipment and supplies are the continuing responsibility of the physician.
Are your patients signing up for CCM services? Tell us in the comments!
Medicare distinguishes between authorized officials and delegated officials on their enrollment forms and many people wonder what the difference is.
Authorized Official Definition
An authorized official means an appointed official (i.e. chief executive officer, chief financial officer, general partner, chairman of the board, or 5% or greater direct owner) to whom the organization has granted the legal authority to enroll it in the Medicare program, to make changes or updates to the organization’s enrollment information in the Medicare program, and to commit the organization to fully abide by the statutes, regulations, and program instructions of the Medicare program.
Authorized Official Authority
The authorized official is the only individual that has the authority to sign the initial CMS 855S application. By this signature the authorized official agrees to notify the Medicare program contractor if any of the information on the application is incorrect or untrue. Also, the authorized official agrees to notify the NSC of any changes within 30 days of the change (Supplier Standard 2).
An authorized official is the only individual that can add and remove delegated officials.
Suppliers may have as many authorized officials as desired as long as the individual meets the definition of an authorized official.
Delegated Official Definition
Delegated officials are persons who are delegated the legal authority by the authorized official to make changes to the supplier file.
A delegated official must be a W-2 employee of the supplier or an individual with 5 percent or greater direct ownership interest in, or an individual with partnership interest in the enrolling supplier. If the delegated official is the managing employee, this individual must be a W-2 employee and the NSC may request proof this individual is a W-2 employee.
Delegated Official Authority
A delegated official can make changes or updates to the supplier file, such as address changes or the addition of a part owner.
The delegated official may also sign and submit the CMS 855S to enroll additional locations, revalidate or reactivate an existing supplier.
A delegated official may not delegate its authority to another individual. Only the authorized official may appoint someone as a delegated official
A delegated official may not sign the initial CMS 855S application for the initial location.
A supplier may have as many delegated officials as desired as long as the individual meets the definition of a delegated official.
There is a lot of advice out there on making the transition to ICD-10.
Your medical practice may already have taken some of this advice and you are well on the way to readiness for I-10. But if you’ve not done anything yet for the transition, this article is for you. I’ve distilled all the blah-blah-blah down into three easy steps that any practice can follow to embrace the change.
1. Do You Need More Software Support?
There is no question that most everything hinges on your EMR and billing system’s management of ICD-10. Your vendor may say the system is I-10 ready, but what does that really mean?
Ask your vendor these questions:
Are ICD-10 codes available in the system now? If not now, when?
Can the providers and staff rehearse using I-10 inside the system by dual coding and assigning both an ICD-9 and an ICD-10 to services without having the I-10 drop to the claim?
What support, if any, does the system give for choosing the right ICD-10? Is there any type of translator or crosswalk between I-9 and I-10?
After October 1, 2015, will the software have the ability to use an I-10 or crosswalk from 10 to 9 if the payer does not accept 10? It should! Physicians and coders/billers should not have to look at the patient’s payer of record to decided which one to use, nor should they require you to change the I-10 to I-9 on the back end. It is very doable for software to crosswalk from 10 to 9 for you.
If the software supports getting to the most specific ICD-10 possible, not just picking the first one that vaguely matches, choosing the I-10 should be straightforward. If your software does nothing more than save the I-10 codes you choose to a favorites or a pick list, then you will need a standalone piece of software called an “encoder.” Hospitals and mega practices have been using encoders for years to help navigate the maze of Medicare local and national rules.
Practices without sufficient support from their EMR/Billing software will need an encoder that can not only suggest possibilities for ICD-10 codes, but can also assist in finding the right code from a series of words algorithmically ordered. (If you want to know which encoder is my particular favorite, send me an email at email@example.com.) Encoders also usually have additional benefits that your billing software or claims scrubber may not have such as CCI edits, modifier rules, global period and wRVU information.
Example of the drilling down to the correct I-10 diagnosis assisted by an encoder:
Which bone? Which part of the bone? Laterality?
Type of fracture? Open, closed, displaced, non-displaced?
Encounter? Initial, Subsequent, Sequela?
Associates diagnoses, conditions?
2. Could Documentation Be Brushed Up?
In hospitals, entire teams of people (Clinical Documentation Improvement staff, usually nurses) are dedicated to making sure that the documentation can support the specificity of the I-10 code chosen. This is especially important for the hospital side of reimbursement.
In the hospitals there are often silos between the service providers and the coding review and billing staff. In practices, we have the good fortune to be able to reflect on the documentation once the I-10 code is chosen, and clarify the documentation on the spot if needed.
Some easy ways to make sure your documentation is as complete as possible to support the I-10 code are:
Think of MEAT when you document. Every condition in your documentation should be described as Monitored, Evaluated, Assessed and/or Treated. If the patient has an existing diagnosis that you did not address during the visit, don’t put it in the documentation or on the claim.
Use “due to” or “manifested by” for each problem that you describe, if you know that information.
Change/improve your EMR templates (or paper progress note format) to accommodate the points above.
3. Are You Ready for Cash Flow Interruption?
You’ve heard this for years and it remains a legitimate concern. If there is any problem with claims processing OR if you are not using ICD-10 properly causing denials, there is a good chance your money from insurance companies will slow down or even dry up for awhile. I suspect that insurance companies may use ICD-10 as a handy excuse to delay payment regardless of the plethora of other excuses they have to choose from.
Predictions on the cost of ICD-10 fluctuate wildly, but here are the places you are most likely to feel the financial pain:
If your EMR/Billing system wants you to pay for an upgrade to your software to compensate them for the money they’ve spent upgrading their software. Since the delay, I’ve heard of fewer companies requiring a special payment for the upgrade.
Reduction of productivity based on time spent to choose an I-10 code:
Any manual form in your practice that uses ICD-9 will need an ICD-10. How will you find those codes?
Physicians who choose codes through their EHR will need software support to find those codes. Because there are so many more codes due to the specificity of each code, it will take a while to get the hang of it if you are not using an encoder.
Inability of your clearinghouse to send claims. Unless you are directly submitting claims to any payers, your clearinghouse has probably tested (end-to-end, please) with payers. Ask your clearinghouse who they’ve tested end-to-end with and what the results were. If things really bog down with CMS, they may grant advance Medicare payments to physicians that are not receiving payments due to the ICD-10 transition.
Delay in payment from any payer due to ICD-10 general chaos.
Keep in mind that a lot of the hoopla over ICD-10 has been on the hospital side. Physician practices are very lucky in that we use CPTs for reimbursement (at this point), not diagnoses. This is a huge change for the hospital/facility side, but much less of a transition for medical practices. We are hoping that physician practices will have less impact to their bottom line, but you should be ready with a line of credit or some extra funds in the bank for this possible rainy day. Starting today, practices that make distributions to owners quarterly may want to scale this back until the smoke clears.
Resources to Help You:
AHIMA (American Health Information Management Association (AHIMA) has an a nice set of tools relating to the adoption of ICD-10 here. Not all tools are available for non-members.
The AAPC has lots of high-quality offerings here, most for members or for purchase by nonmembers. Although it was written for the original 2014 transition, here’s a good article to review for the creation of an ICD-10 superbill, or just to review your top I-9s and translate them to I-10s.
Your software vendor, claims clearinghouse and specialty society should also have ICD-10 tools.
No, I’m not a glutton for punishment. What I like about complaints is that I hear directly from the patient what is bothering them, and I have an opportunity to connect with them personally. The ideal situation is having the opportunity to meet face-to-face with the patient when they are in the office.
Here’s how to apologize to a patient.
Step One: Introduce Yourself
I introduce myself and shake the patient’s hand and the hand of anyone else in the room.
Step Two: Sit Down
I sit down. There are two reasons for that. One is to send the message that they do not need to hurry – this conversation can take as long as they need it to. The second is to place myself physically below the patient. If they are in an exam room sitting on the exam table, I will sit in the chair. If they are sitting in the chair, I will sit on the step to the exam table. The message I am sending is “I do not consider myself to be above you.” It sends a strong message.
Step Three: Let Them Tell Their Story
I say “I understand we have not done a very good job with __________ (returning your calls, giving you an appointment, getting your test results back to you, etc.) Can you tell me about it?” I do not take notes as I want to maintain eye contact and focus on the patient, but I take good mental notes. The patient and/or anyone with them needs to be able to talk as long as they want. They might need to tell their story twice or many times to get to the point where they’ve gotten relief. The patient has to get the problem off their chest before the next part can happen.
Step Four: SINCERELY Apologize
I apologize, saying “I’d like to apologize on behalf of the practice and the staff that this happened. I want you to know this is not the way we intend for _______ to work in the practice.” If anything unusual has been happening, a policy has changed, or new staff have been hired, I let them know by saying “So-and-so has just happened, but that’s not your problem. We know our service has slipped, but we’re hoping we are on the way to getting it fixed.”
Don’t forget that patients can tell if you are not being sincere when you apologize.
Step Five: Answer Questions
Answer any questions the patient has. Why did the policy change? Why can’t I get an appointment when I need one? How will you fix this for me?
Step Six: Close the Meeting
If the patient complaint requires an investigation and resolution, I give the patient a date when I will be back in touch with more information. If the patient complaint does not require any resolution on the patient side, I offer my name again and give them a business card or a way for them to contact me if they have further problems.
Step Seven: Resolve the Situation
I follow-up on the information the patient has given me to find out where the system broke down or where a new system might need to be developed, and if needed, contact the patient with further information and/or resolution.
Although most people prefer not to hear complaints, paying close attention to patient complaints helps a manager to keep a pulse on the practice, know what patients are struggling with, and of course, practice humility. All good stuff.
Hospital Compare is a consumer-oriented website that provides information on how well hospitals provide care to their patients. It allows consumers to select multiple hospitals and directly compare performance measure information related to heart attack, heart failure, pneumonia, surgery and other conditions.
What Is HCAHPS?
The HCAHPS – pronounced “H-CAPS” – (Hospital Consumer Assessment of Healthcare Providers and Systems) Survey is a standardized questionnaire that measures patient perspectives of hospital care. HCAHPS results posted on Hospital Compare provide ratings, including comparisons to state and national averages, that help consumers understand how hospitals perform.
HCAHPS Star Ratings
On April 16, 2015, the Centers for Medicare & Medicaid Services (CMS) added HCAHPS Star Ratings to the Hospital Compare website as part of the initiative to add 5-star quality ratings to its Compare websites. CMS believes that star ratings spotlight excellence in health care quality and make it easier for consumers to use the information on the Compare websites. The ratings also support using quality measures as a key driver of health care system improvement.
Twelve HCAHPS Star Ratings appear on Hospital Compare: one for each of the 11 publicly reported HCAHPS measures, plus the new HCAHPS Summary Star Rating. HCAHPS Star Ratings are the first star ratings to appear on Hospital Compare and CMS plans to update the HCAHPS Star Ratings each quarter.
HCAHPS Measures Used to Determine Star Ratings
There is a star rating for each of the following HCAHPS measures:
HCAHPS Composites Measures
Communication with Nurses (Q1, Q2, Q3)
Communication with Doctors (Q5, Q6, Q7)
Responsiveness of Hospital Staff (Q4, Q11)
Pain Management (Q13, Q14)
Communication about Medicines (Q16, Q17)
Discharge Information (Q19, Q20)
Care Transition (Q23, Q24, Q25)
HCAHPS Individual Items
Cleanliness of Hospital Environment (Q8)
Quietness of Hospital Environment (Q9)
HCAHPS Global Items
Overall Hospital Rating (Q21)
Recommend the Hospital (Q22)
Other “Compares” with Stars
CMS already uses star ratings in other Compare websites:
Medicare Plan Finder uses star ratings to help beneficiaries select parts C and D plans. These star ratings also determine quality bonus payments for plans.
Why Can’t I Find My Hospital?
All hospitals that participate in the HCAHPS Survey are eligible to receive HCAHPS Star Ratings, which includes both Inpatient Prospective Payment System (IPPS) hospitals and Critical Access Hospitals (CAH). IPPS hospitals are required to report HCAHPS as part of the Hospital Inpatient Quality Reporting (IQR) Program and CAHs voluntarily participate.
In addition, hospitals must have at least 100 completed surveys in the 12-month reporting period and be eligible for public reporting in order to receive HCAHPS Star Ratings.
Exploring Hospital Compare
If you or a loved one has had a hospital experience recently, go to Hospital Compareand see if your experience correlates with other patient feedback. Please share your comparison in the comments!
This post was originally published on the LinkedIn Pulse as part of the LI Influencer program.
Staffing your medical practice can be a daily balancing act.
There’s no simple formula for staffing that one can apply to every practice because each specialty and each situation requires something different. It is very important to right-size your staffing. Understaffing can cause patient dissatisfaction, frustration, burnout and a staff exodus. Overstaffing can cause lower productivity, reduction in profit and never really getting to the root of why some problems exist.
Matching FTE Providers to FTE Employees
Most benchmarks utilize FTEs (full-time equivalents) which is an employee working a 40-hour week, or a provider working the number of hours considered full-time for providers. Although this works well for employees, it doesn’t always follow for providers. A .5 FTE provider that works two days a week may need more than a .5 clinical and .5 non-clinical person because patients still call for prescription refills and questions and test results still arrive to be reviewed on the days the provider is not there.
Back to basics
It helps to bring the equation down to the simplest formula of clinical and non-clinical staff. For now, disregard billing, lab, other ancillary services, management, and medical records and focus first on the number of staff needed to get the patient in the door (front desk), get the patient seen (clinic assistants), and get the patient out the door (front desk again.)
Let’s imagine that Dr. Goodman is a full-time primary care physician with a mature practice and a full schedule. She works 4.5 days per week and has one non-clinical person who answers the phones, checks patients in, checks patients out and handles the medical records. She also has a clinical person who rooms the patient, performs the intake, and takes the vitals. The clinical person also answers patient phone calls with medical questions and contacts patients to give them their test results. Either employee may schedule tests and referrals for patients. Dr. Goodman has 2 full-time employees and if she’s really fortunate, both employees are interchangeable so each can fill in for the other if they want to take vacation or are sick for more than a few days, maybe with the help of a temp or a prn person if needed. If the practice has electronic medical records (EMR) and everything is as automated as possible, they can probably get by for short periods of time.
Most brand new practices start with just one employee who does all front office/administrative (reception, phones, registration, scheduling, referrals, time-of-service collections) and all back office/clinical (vitals, procedure prep and assistance, phlebotomy, injections, lab testing, patient call-backs.) As the practice grows, it becomes clear when a second employee is needed.
What about a practice with ancillaries or more providers?
Front desk – as the number of providers grows, so does the need for more staff to check patients in or check patients out. Floating staff between these positions can be a temporary solution before adding full-time staff in both areas. Using a patient check-in kiosk can minimize the stress of checking-in many patients arriving simultaneously, and having patients register online or through a portal can save significant registration time.
Dedicated phone staff – when employees are consistently pulled between answering the phone and working with the patient in front of them, it’s time to consider a separate phone position away from the front desk. Don’t overlook the possibility of having a remote employee taking calls from home full-time, or part-time during peak days and times.
“Nurse” triage – if providers are seeing patients all day every day, clinical assistants may not have the capacity to answer phone calls between patients, or to manage the patient schedule. Nurse triage can keep the office flow even by deciding when patients need to come in for same day visits, answer questions, call patients with test results, and cover breaks for other clinical/non-clinical staff. Vaccines administered by the clinical staff can often be what determines when more staff is needed – if the clinical assistant is administering vaccines, s/he is not available to room the next patient. The appointment interval can be another defining factor in how many clinical staff are needed – the shorter the appointment intervals, the more help will be needed to keep the schedule moving.
Laboratory – services can be as limited as the clinical person taking specimens, or as complex as a full-blown lab staffed with a full-time lab tech to draw blood and test it. Lab services are often determined by two factors – improved care for the patient (can the provider get test results during the visit that will assist in getting the patient diagnosed and on a treatment plan?) and convenience for the patient (how far will the patient have to go to get blood drawn at a lab?)
Referrals – most primary care offices refer patients for lots of tests and if the process is not electronic and requires lots of time on the phone, you may need to dedicate a FTE person to this job if you have 3-4 providers.
Billing – billing can be completely outsourced from the entering of charges to pushing accounts to collections, or it can be handled in-house. A typical ratio is one billing person to two providers for a practice that sends statements and one billing person to four providers if using credit card on file.
Imaging– for those offices that have onsite imaging, one employee is enough if there is another imaging facility close by. Depending on the imaging volume, some practices have mobile imaging services come to office once or twice a week, or have an imaging technician who can also perform other clinical duties.
Medical records – with the predominance of EMR, the designated medical record person has just about disappeared in smaller practices. Most remaining medical record functions (scanning mailed records, tracking down records from other providers or facilities, providing records to other providers, attorneys and to patients themselves) are performed by other staff as part of a litany of shared duties.
Management – when does a practice need a manager? Well, that’s another post for another day, but typically a solo physician/provider does not need a manager, unless she has lots of ancillaries with lots of associated employees. A Fractional Administrator can offer part-time assistance that is enough to help a small but growing practice.
And in a specialist’s office:
Surgery scheduling – in some surgical practices, the clinical assistant does the scheduling while the physician is in surgery. Larger practices employ centralized surgery scheduling which usually takes 2 schedulers to make sure one scheduler is available at all times.
Specialized Testing – one technician is usually enough for each specialized testing modality, unless the practice is a referral center for other providers. The other exception is if the equipment, a nuclear camera for instance, is so expensive that the practice cannot afford to not be able to do tests if an employee is absent.
Why do some offices need more staff and some need less?
Inefficiency requires more people! If people have to get out of their seats to solve a problem or get an answer, they’re inefficient.
Systems and processes must support the work of the employees, not hinder it. Do your systems support your workflow?
Some physicians can keep two (or more) clinical assistants busy.
Some physician specialties order many more tests and need more staff to schedule them.
Poorly organized practices duplicate efforts, and in doing so, cause themselves more work. A good example of this is the patient calling the practice multiple times during the day when they do not get a callback, causing much more work than if the patient was called back within 2 hours.
What should you do if you can’t figure out if it’s taking too many people to do the work?
Do you know what every person is doing? Have everyone keep a log of all the jobs they do over the course of several weeks. Ask them to assign the percentage of time they spend doing each task. Evaluate their lists and see if staff are carrying equivalent workloads.
Cross-train employees and see if jobs take more or less time when others do the tasks. There should be some variance, but not a significant variance.
Is every task something that contributes to the practice? Does something absolutely need to be kept in two places in two formats? Are things being done because “we’ve always done them that way?”
Is one thing so far behind that it’s causing duplication of effort? Bring in a temp, ask staff to work on a Saturday, do whatever it takes to bring everyone back to ground zero again.
Hold brainstorming sessions with staff and involve them in developing plans for improving efficiency. Also ask them one-on-one for their ideas for improvements.
We expect more of everyone than we did before the economy tanked, and employees are responding by being more stressed and by being out sick more. Evaluate if everyone is out more than in the past and how that may be affecting the work.
Do a simple efficiency study by observing individual employees at work and documenting what they’re doing one minute at a time for a period of two hours. Graph the work by time to see what two hours of their day looks like. Some jobs are by nature “interruptable”, like phones, check-in and check-out, and some jobs are performed best when the employees are subjected to minimal interruption. Are these jobs defined in this way, or are the two interspersed creating inefficiencies?
Try this exercise: create the ideal staff for your office as if you could afford every person you’d like to have. Then, start to work backwards, seeing how jobs could be combined and what positions would be nice, but not necessary. Compare the final product to what you have now, and see what the differences are. Another way to approach this is to pretend your practice doesn’t have the physical confines that it does, and see if you would staff it differently if the space was more accommodating.
Last week, CMS published a new proposed rule for Meaningful (MU). This rule strives to “…align Meaningful Use (MU) Stage 1 and Stage 2 objectives and measures with the long-term proposals for Stage 3…”. In other words, make the program simpler and make it easier to achieve.
The proposed rule would simplify MU by:
Reducing the overall number of objectives;
Removingmeasures that have become redundant, duplicative or have reached wide-spread adoption;
Allowing a 90 day reporting period in 2015 to accommodate the implementation of these proposed changes in 2015, and possibly of the greatest interest to medical practice,
Remove the 5 percent threshold for Measure 2 from the EP Stage 2 Patient Electronic Access objective, requiring that at least (only) 1 patient seen by the provider during the EHR reporting period views, downloads, or transmits his or her health information to a third party.
This last one is extremely important as practices have spent much time and money trying to encourage patients to use their portals to fulfill the view/download/transmit requirement. As a patient, I understand this. I only use my PCP’s portal a couple of times a year, so I invariably forget my user ID and password (yes, I do know there are programs to store and retrieve these for me, but that’s a conversation for a totally different post) and it all ends up just being a big pain. My health is important to me, but I don’t have reason to get on the portal on a regular basis, and practices are finding out that many patients just don’t care to use the portal or don’t have a need.
More light reading on the proposed rule is available herein the Federal Register.
You may or may not have noticed that the Manage My Practice website has been, well, gone during the month of January. We are still not sure what exactly happened – it could have been hacked, but we’re not sure who might have done such a dastardly deed.
The bottom line is that we’ve been furiously working trying to reconstruct everything, and we know now that we have lost the last 100 or so posts from the blog. Many of these were posted on LinkedIn, so we can copy them back to the site, but many are probably gone forever. So…
I Am Asking You a Favor
If you’ve ever printed, copied to a Word document, or in any way kept a copy of one of my posts that was written after September 16, 2013, I would love to have a copy of your copy so I can repost it. Wouldn’t it be amazing to find every single one of those 100 posts? I don’t expect it to happen, and I’m not even sure all those posts deserve to be re-published, but I am going to take a crack at it.
Any post you find can be emailed to firstname.lastname@example.org. I’ll let you know what happens.
Thanks, and here’s to new beginnings!
p.s. Baby is my new granddaughter Lulu, born December 23, 2014 and probably the reason why I can’t get too freaked out about the whole website thing.
I am always excited when physicians design products for other physicians because they “get it.” Here’s the tale of a Midwest physician, Dr. Fred Church, who has developed a free app to communicate one-on-one with his patients via email or text.
Mary Pat: Dr. Church, tell me how you came to design e-Consult My Doctor, an app that lets physicians and patients communicate with the ease of email and text in a secure environment.
Dr. Church: I suppose the axiom of “necessity is the mother of all innovation/invention” applies here. I saw a growing need and had a growing entrepreneurial passionto solve the problem for more physician-patient interaction between scheduled visits. I believe we are at the precipice of still greater demand for mobile connectivity and services in America.
The premise of private communications to enhance doctor-patient relationships is not a novelty, but how to do it in a HIPAA-compliant manner that is also is simple and convenient is a significant challenge. We are delivering an elegant smartphone app that uniquely understands a busy doctor’s and patient’s lives and works to serve them. We have created a utility that enables any doctor to be a concierge-service doctor and every patient to be the beneficiary of that great personalized care – care that is direct from the doctors that know them and whom they trust.
Mary Pat: You describe e-Consult My Doctor as a tool to augment the physician-patient relationship, not replace the traditional office visit. Can you give some examples of this?
Dr. Church: In no way is our communication management tool intended to replace the face-to-face interaction and assessment between a physician and his established patient. We have terms of service that users will explicitly understand and agree to prior to participation. Doctors will not have to worry about this being crystal clear to patients. Most reasonable people understand that emergency situations need to be dealt with in-person and this tool is not intended to deliver emergency communications.Example Scenarios:
“Doctor, can you give me an evaluation of this mole as I think it has changed since you last saw me for my physical? You told me to watch it and document it myself on my phone… should I be seeing you now or wait until my next physical?”
“Surgeon, I am three days post-op and it’s Sunday afternoon and I’m scheduled to see you tomorrow for follow-up. Can you take a look at these two pictures of my wound to tell me if I need to go to the urgent care or ER tonight before tomorrow’s follow-up? I’m not alarmed but a little concerned at how it looks and I want to have your opinion before my scheduled follow-up.”
“Doctor, one month ago I described to you during Betsy’s well-child visit the rare sounds and behavior changes I was hearing and seeing from my 3 month-old daughter and felt like I was having difficulty adequately explaining it to you. Guess what, I was able to capture it on this video with audio. Can you listen to it and tell me your opinion if I should be concerned about it? Should I bring her back in after you view this so you can examine her again and/or do more lab workup?”
“Doctor, we talked about considering certain omega 3 supplements and I want your opinion on this particular supplement (see picture of label) from XYZ that the pharmacist recommended. Do you think it’s a good one also? I appreciate your opinion before my next follow up with you.”
Mary Pat: Foremost in everyone’s mind is the privacy and confidentiality of texting and emailing – how does e-Consult My Doctor achieve HIPAA compliance?
Dr. Church: Our smartphone app technology uses best practice standards for data at rest and in transit using AES 256-bit encryption. Doctors and patients will have a secure login to their app so that if their phone is stolen or misplaced, the data is still encrypted and cannot be viewed without a user’s password. If a user’s account is somehow compromised, administratively we can suspend his account, his e-consulting relationships, and access to the information between those relationships.
Mary Pat: Do you see this product replacing the traditional function of a nurse triage in the medical practice?
Dr. Church: Absolutely not. In fact, it is intended to offload the burden that triage is often overwhelmed with. Traditional healthcare will always need people to properly triage communications at a doctor’s office. Unfortunately, high volumes and increased costs mean that calls are not always responded to in a timely way. Doctors need communication tools that are portable and flexible and this describes e-Consult My Doctor.
Mary Pat: Your software has some interesting features, including a mini-EMR or PHR (Personal Health Record.) Can you describe the benefits of a mini-EMR available from a smartphone?
Dr. Church: Because our solution is much less complex than an EHR (Electronic Health Record), a single adult patient user may keep and manage all of his dependents’ information on one app securely. Our well-designed smartphone app stores all related health event reminders, vaccine history, and PHR information. The PHR on our smartphone app is viewable/editable without the requirement of an internet connection, which is a clear advantage over EHR portals. When patients participate in managing their information and updating their PHR data between visits, it makes it easier for intake nurses/staff during scheduled visits to make sure the EHR’s data is also reflecting recent changes that may be more current than EHR updates from various sources: other urgent cares/ERs, other specialty doctors, other health providers/doctors/sub-specialists (DDS, DC, DPM, etc.), hospitals etc. One of the main advantages of patients participating in their own PHR information is it will hopefully improve PHR accuracy, contribute to better patient compliance, and help serve both patients and doctors in traditional healthcare delivery.
Mary Pat: How does the documentation of the communication between the physician and the patient get back into the practice EMR?
Dr. Church: The app will allow for exporting content via PDF and both doctors and patients will have their own copy of e-consultation data on their apps. Doctors may elect to attach the PDF of the e-consultation interaction to their respective EHR if they believe it is important enough and pertinent to a patient’s long-term record. For example, several EHRs do not have the ability to import pictures, audio, and video content which this app will easily store for minimal convenience fees. Additionally, a doctor can simply summarize the exchange in her next scheduled office visit’s documentation if she feels the content is important enough. This will vary on an individual case-by-case basis and will be up to the doctor’s judgment.
Mary Pat: Between the secure communication and the mini-EMR, e-Consult My Doctor sounds very much like a patient portal. Can your software replace a patient portal for a medical practice?
Dr. Church: The mission of our software is to deliver a different and simpler solution for convenient communication and to augment the functionality of an EHR’s patient portal. An EHR patient portal is valuable for a singular patient to see what his doctor’s EHR documents as his current information including labs, vitals, etc. The e-Consult My Doctor app will allow direct one-to-one communication any time and anywhere the doctor and patient are willing to participate. One of the foundational premises of our product is that a doctor’s extra time and effort should be rewarded directly by the beneficiary… like having pay-as-you-go access to their mobile phone or email for enhanced, personalized care between scheduled visits.
Mary Pat: You have essentially designed a product that allows physicians to be reimbursed for care that they have been previously providing for free. Some patients will appreciate the convenience and be willing to pay for the personal attention and others will think it is akin to the airlines charging for luggage! How do you answer those who think healthcare is already too expensive without any additional fees?
Dr. Church: I’m amazed how many people are willing to pay for the $1,000 – $2000 per patient per year for 24/7/365 access that they may only utilize a few times a year. I personally know concierge doctors who are eagerly looking forward to our HIPAA-compliant solution that will help them achieve better work-family life balance with our communication management tool. We believe our smartphone app will bring a revolutionary solution that allows every doctor and every patient to participate in a concierge e-consulting relationship at a potentially lower price point. Our solution eliminates the middleman with a convenient and simple solution at a very affordable price and payment is directly and immediately received by the doctor.
Mary Pat: When will this product be available on the market and what will it cost physicians to purchase?
Dr. Church: The anticipated market delivery date is November 30, 2013. The app will be free and the basic subscription level will also be free. Users will be given a limited amount of secure storage space and may upgrade to larger amounts based on their individual needs. We will also offer a premium subscription level that will afford a larger secure space allotment and additional valuable service offerings. Our app will offer a pay-as-you-go, transactional model for the basic subscription level and a fixed-price price point for the value-minded user who wants more.
Mary Pat: How can readers get in line to try your app?
Dr. Church: They can go to http://e-ConsultMyDoctor.comand sign up for pre-launch information and be the first to try it out. We invite physicians who want to be beta-testers!