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76 Ways to Use the Cloud in Your Medical Practice (or Any Business)

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

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

SECURITY & RISK MANAGEMENT

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

INFORMATION SHARING

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

BUSINESS MANAGEMENT

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

COLLABORATION

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

INCREASE EFFICIENCY

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

IMPROVE MOBILITY

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

DAY-TO-DAY MANAGEMENT

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

SAVE MONEY

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



Medicare is Auditing You! What To Do Next?

CMS logo found on the header of all audit lettersThere are a number of different audits that are carried out by Medicare-contracted auditors.  It’s important to know the differences and have a plan for responding.

CERT stands for Comprehensive Error Rate Testing and CERT audits were initiated in 2000. The program is responsible for measuring improperly paid claims. The CERT Program uses the following OIG-approved methodology:

  1. A sample of approximately 120,000 submitted claims is randomly selected;
  2. medical records from providers who submitted the claims are requested; and
  3. the claims and medical records are reviewed for compliance with Medicare coverage, coding and billing rules.

RAC stands for Recovery Audit Contractor and began in early 2009. The RACs detect and correct past improper payments so that CMS and Carriers, FIs, and MACs can implement actions to stop future improper payments.  RAC is currently focusing on inpatient services and physical therapy services.  As of the date this post was published RAC was not focusing on physician services.

ZPIC (Zone Program Integrity Contractors) replaces the Medicare Program Safeguard Contractors (PSCs) and Medicare Drug Integrity Contractors (MEDICs) that are currently in use by CMS.  ZPICs are be responsible for detection and deterrence of fraud, waste and abuse across all claim types. ZPICs have access to CMS National Claims History data, which can be used to look at the entire history of a patient’s treatment no matter where claims were processed.  Being able to look at the overall picture will enable them to more readily spot over billing and fraudulent claims. Among other things, ZPICs will look for billing trends or patterns that make a particular provider stand out from the other providers in that community. Once a ZPIC identifies a case of suspected fraud and abuse, the issue is referred to the Office of Inspector General (OIG) for consideration and possible initiation of criminal or civil prosecution.  ZPIC is widely considered to be the greatest threat to physician practices.

Seven ZPIC zones have been identified.  The zones include the following states and/or territories and most have been assigned contractors:

  • Zone 1 – CA, NV, American Samoa, Guam, HI and the Mariana Islands http://www.safeguard-servicesllc.com/zpic.asp
  • Zone 2  – AK, WA, OR, MT, ID, WY, UT, AZ, ND, SD, NE, KS, IA, MO AdvanceMed was just purchased by NCI – site not current
  • Zone 3 – MN, WI, IL, IN, MI, OH and KY – not awarded
  • Zone 4  – CO, NM, OK, TX. HealthIntegrity
  • Zone 5  – AL, AR, GA, LA, MS, NC, SC, TN, VA and WV AdvanceMed was just purchased by NCI – site not current
  • Zone 6 – PA, NY, MD, DC, DE and ME, MA, NJ, CT, RI, NH and VT – not awarded
  • Zone 7  – FL, PR and VI http://www.safeguard-servicesllc.com/zpic.asp

How should you respond to a Medicare audit?

  1. Log all requests for records from all payers.  Time and date all communications received and all communications sent.
  2. Scan all records sent and include a cover letter itemizing contents of response.
  3. Send records via certified mail.
  4. If you get a request for a large amount of records at one time, consider getting advice from a consultant or attorney who specializes in Medicare audits as a large scale record request may cripple the practice operations.

How can you be proactive before you get an audit letter?

  1. Check the audit sites monthly to see if your specialty or any services you provide are being targeted for an audit.
  2. Conduct an internal assessment to identify if you are in compliance with Medicare rules or hire a third-party to conduct an audit for you.
  3. Identify corrective actions to promote compliance.
  4. Appeal when necessary

Excellent resource site http://www.willyancey.com/sampling-claims.html




The RAC Outreach Session: Get Your Medical Practice Ready Now!

Today I was fortunate enough to attend an outreach session designed to educate hospitals, physicians and other providers about Recovery Audit Contractors (RAC), specifically Connolly Consulting, the RAC for North Carolina.  Although I cannot vouch that the information I am sharing for Region C will be consistent for the other three RACs, the fact that there is a standard handout being used for all RAC outreach sessions makes me think there’s a very good chance that CMS is encouraging a high level of consistency.

If you read the recent Manage My Practice article here by Carla Hannibal, you already know that the RACs were established after CMS demonstration projects proved “to be successful in returning dollars to the Medicare Trust Funds and identifying monies that need to be returned to providers. It has provided CMS with a new mechanism for detecting improper payments made in the past, and has also given CMS a valuable new tool for preventing future payments.” (CMS website)

Each RAC bid for and won the jurisdiction as follows:

  • Region A: CT, DE, DC, MD, ME, MA, NH, NJ, NY, PA, RI, VT Diversified Collection Services (DCS) -1-866-201-0580, website here
  • Region B: MN, WI, IL, IN, OH, MI, KY CGI Technologies and Solutions -1-877-316-7222, website here
  • Region C: AL, AR, CO, FL, GA, LA, MS, NC, NM, OK, SC, TN, TX, VA, WV and the territories of Puerto Rico and U.S. Virgin Islands. Connolly Consulting, Inc. -1-866-360-2507, website here
  • Region D: WA, OR, ID, CA, NV, MT, WY, UT, AZ, ND, SD, NE, KS, IA, MO, AK, HI HealthDataInsights, Inc.-Part A: 866-590-5598, Part B: 866-376-2319, e-mail: website here

Each RAC is required to provide outreach education sessions in their region prior to sending out any letters.   Any hospital or physician who bills fee-for-service programs (Part A and/or Part B) for Medicare beneficiaries is eligible for a RAC audit.

These are the important points that I took away from attending this outreach program:

  1. RACs may review claims as far back as October 1, 2007.
  2. RACs review claims after they have been paid using the same Medicare policies used to pay the claim initially.
  3. There are two types of reviews: Automated Reviews which do not request the medical record and Complex Reviews which will request the medical record.
  4. Automated Reviews are “done deals” and the claim will be adjudicated and a letter sent detailing the dollars requested.
  5. Providers may return the payment by writing a check, allowing a recoupment from future payments or may apply for an extended payment plan.
  6. Complex Reviews entail a request for medical records.  Records can be mailed, faxed, or sent on a CD/DVD.  Mailed records must be sent in a tamper-proof package, and should be sent via trackable carriers (FedEx, UPS, Registered USPS.)  Multiple records may be sent in one package if each record set is in a separate envelope inside the package.
  7. Note: if faxing, fax the records to yourself to check for readability before you fax to the RAC.
  8. Email records are currently not acceptable due to HIPAA.
  9. Providers have 45 days plus 10 mailing days for a total of 55 days to send the records, but extensions are available if this is not abused.  If you do not communicate with your RAC about any problems you are having sending the records (e.g. you can’t find the record!), you risk having the claim(s) automatically recouped.  The Connolly representative even mentioned something to the effect that she wasn’t above calling the practice/entity CEO to let them know that their contact person wasn’t playing by the rules.
  10. Once a claim has been reviewed and a Complex Review is in play, the provider will receive a Demand Letter from the RAC and the provider will have a “discussion period” to contact the RAC and ask questions and/or provide additional information.  The RAC representative emphasized to communicate, communicate, communicate and to call the RAC and  speak to the reviewer of the claim.  Once you have spoken to the reviewer, if you still disagree with the decision, you should ask to speak to the supervisor, and if there still is no agreement, you need to file an appeal.
  11. Appeals must be filed within 120 days of the receipt of the demand letter from the RAC.

Here is a suggested action plan for physician practices to prepare for the RAC process:

  1. Visit the CMS website here and click on Demonstration Projects to see what improper payments were found by the RAC demonstration projects.
  2. Visit the CMS and OIG websites to see what improper payments were found by reading the OIG (Office of Inspector General) reports here and CERT (Comprehensive Error Rate Testing) reports here.
  3. Conduct an internal assessment to see if you are in compliance with Medicare rules, and if not, identify corrective actions needed to bring your group into compliance.  Corrective actions may include provider education and a periodic internal audit to rate the improvement.
  4. Provide your RAC (they will tell you how to do this) with a contact person who will receive RAC letters and who will be the point person for providing the RAC with additional documentation.  The RAC will also ask for information about providers and their NPIs, including any providers who were with the group between October 1, 2007 and now, even if the provider is no longer with you.  Connolly suggests copying the list of providers you supply to the RAC and placing it in the personnel file of the contact person to be reminded of this important responsibility if this person leaves the organization.
  5. Develop a basic tracking system for receipt of letters, and activity for each request.
  6. VISIT YOUR RAC WEBSITE AT LEAST WEEKLY.

I have received lots of questions about what a RAC letter will look like, and the speaker today provided a sliver of information saying that the Region C letters will have the CMS logo at the top of the letter and Connolly’s logo at the bottom of the letter.  Because your practice/entity will be providing the RAC with a contact person’s name, unless things are in total chaos at your place of business, the letters will go to the person you’ve entrusted with this important responsibility.

Here are some other questions and answers from the program today:

Q: Does the RAC pay for the copying/mailing for records?

A: They will pay hospitals, but will not pay physicians for record expense.

Q: If  a claim is refunded to Medicare, must the patient be refunded their portion?

A: Yes.

Q:What determines which region the practice/entity belongs to for RAC?

A: The state that the practice/entity is located in.

Q: Are patients contacted if their claim is audited?

A: They receive a notice if the claim is adjusted in any way.

Q: I heard that there are consultants selling RAC insurance – is that a good idea?

A: There is no such thing as audit insurance, but there is such a thing as appeal insurance.

Q: Will a claim be audited if a practice/entity self-audits, finds an error and corrects it?

A: As long as an amended claim is filed by the provider, RAC will not audit the claim.

Q:Who sets the guidelines for medical necessity?

A: The medical director of the RAC.

Q: Are the number of claims that can be audited in each period counted by transaction lines (5 per CMS form) or by claim/single CMS form?

A: By transaction lines.

Q: Will the RACs extrapolate their findings?

A: The RACs are entitled to extrapolate their findings if they so choose.

Q: Are the RACs paid on a percentage of their findings?

A: Yes, RACs are paid a percentage of both overpayments and underpayments.  The percentage ranges from 9% to 12.50% based on each RAC’s bid.

If this information is new to you, I suggest you click on some of the links provided in this article, start developing your RAC plan, and start educating your providers and staff.  This topic is also a good one for sharing of best practices between local and regional groups.  To get email updates on RAC from CMS, sign-up here. Remember to bookmark your RAC’s website and visit often!

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