Zetter HealthCare

CMS Posts EHR Incentive Payment Recipient Information

dzetter — Fri, 18 May 2012 12:37:10 +0000

In compliance with the HITECH Act’s requirement, CMS has posted the names, business phone numbers, and business addresses of Medicare eligible professionals (EPs), eligible hospitals, and critical access hospitals (CAHs) that have successfully demonstrated meaningful use and received a payment as of March 2012. Medicare EPs, eligible hospitals, and CAH’s were able to verify and edit their business phone numbers and addresses during the registration process. CMS has not posted information on group practices, as incentive payments are not provided at the group practice level.Beginning this month, CMS is posting two file formats of Medicare EHR Incentive Program payment recipients. One format is a searchable PDF, and the other is a tabular downloadable CSV file that can be opened in many common spreadsheet programs. This CSV file can also be used to sort information about recipients, for example, by medical specialty or the state in which they practice. Use the links below to access the PDF and CSV files.

CSV Files

PDF Files

Please Note:
These lists will be updated on a quarterly basis. Not all providers are eligible for the Medicare EHR Incentive Program. Only those professionals, hospitals, and CAHs that are eligible based on the regulation’s eligibility requirements, attested to meaningfully using an EHR, and have received a Medicare incentive payment will be displayed online. Finally, the Act does not require CMS to post the names of eligible professionals, eligible hospitals and CAHs that have received Medicaid EHR Incentive Program payments.

Medicare’s PECOS Rules Change Ability to Refer

dzetter — Thu, 17 May 2012 17:30:24 +0000

Provider Enrollment, Chain and Ownership System (PECOS) rules finalized by the Centers for Medicare & Medicaid Services (CMS) will make it easier for physicians to refer patients to specialists.The PECOS rules, published April 27 in the Federal Register, loosen proposed rules regarding referrals to specialists, freeing providers and Medicare patients from referrals in most cases. The rules also clarify the relationship between PECOS and the National Provider Identifier (NPI): PECOS being defined as an enrollment repository for Medicare, while the NPI database is a repository of information regarding all providers, regardless of their relationship with Medicare.

The new rule also allows physicians who are already registered with legacy Medicare systems to be able to serve and refer Medicare patients before they are registered in PECOS.

According to American Medical Association’s (AMA’s) amednews.com, CMS first outlined new enrollment rules for ordering and referring physicians in 2009, but stopped short of enforcing those requirements because as many as 200,000 doctors and other health care professionals (out of about 750,000) did not have enrollment records in PECOS.

In 2010, Congress required the use of NPIs for ordering and referring physicians on claims for medical equipment or services from laboratories, imaging providers, and suppliers. CMS later issued an interim regulation requiring all physicians who order supplies or refer services, including those from specialists, to be enrolled in PECOS by July 2010. CMS later delayed enforcement of that rule as the agency worked to validate and update enrollment records. Enforcement would have meant that claims for items or services would be rejected unless the ordering or referring physician also was in the enrollment system, not just the physician who provided the care.

Survey on Obtaining Payer Fee Schedules

dzetter — Wed, 02 May 2012 16:10:48 +0000

A colleague of mine, Frank Cohen, is conducting a survey on your ability to obtain fee schedules from your payers. We obtain quite a bit of this information from payers on our client’s behalf and usually do not have an issue obtaining it. We have participated in this survey. I have included the information about his survey below. Feel free to participate to help provide Frank with the best data possible.As a general rule, contracting law would require that a payer, under contract with a practice, make available the fee schedule being used to pay for services provided to the payer’s subscriber by physicians within that practice. Unfortunately, this is not a statutory requirement in all states, the logic of which eludes me. The only reason I can think of that would keep the payer from providing the fee schedule to the practice is to prevent the practice from using that fee schedule to ensure they are getting paid what they are supposed to under the agreement. This is inherently unethical and provides for an unfortunate business partnership for the practice.

Word on the street is that it is from very difficult to downright impossible to obtain contracted fee schedules from most private payers and I have designed a survey to test and quantify this assertion. In the survey, I have listed the top 10 or so payers and in order for the results to be significant when stratified by payer, I need a lot of responses. My goal is to use the results of this survey to press for states to enact laws requiring payers to make fee schedules available in a user-friendly format for any practice that sees a patient that is a subscriber of that payer.

As always, the results will be made available at no charge upon completion and analysis. If you are interested in participating, go to www.frankcohengroup.com and click on the Survey tab.

Frank D. Cohen, MPA, MBB
The Frank Cohen Group, LLC
www.frankcohengroup.com
frank@frankcohengroup.com
727.322.4232

CMS Increases Enrollment Submission Window

dzetter — Mon, 30 Apr 2012 17:48:18 +0000

CMS is making enrollment easier. This has nothing to do with the 60 days you have to complete a revalidation after you receive the revalidation notice in the mail. You can now submit an enrollment application up to 60 days before a provider’s start date. Previously, you were only able to submit the enrollment application (CMS 855 form or PECOS enrollment) up to 30 days prior to the start date of the provider/supplier. This is huge because this gives you twice as much time to prepare for the provider/supplier start date and to have enrollment completed even before the provider starts allowing them to bill for services rendered immediately, as long as the enrollment application has been approved. It also provides you more time to answer any development letters that may arise due to the MAC requesting or needing more information or documentation.

Physician Practices – An Opinion on Practice Survival

dzetter — Fri, 27 Apr 2012 13:56:37 +0000

There are many opinions on what a small physician practice should do to survive as a business. Obviously, in these times, it is more important than ever to “keep your eye on the ball” in order to ensure a profitable practice and your livelihood.I recently conducted a webinar for DecisionHealth on the 7 Habits of Highly Profitable Medical Practices which are tried and true examples of what high performing practices do to stay ahead of the game and viable practices.

In a recent session at the American College of Physicians’ (ACP) annual meeting, John H. O’Neill, Jr., DO, FACP, Vice Chairman of the ACP, learned that many physicians would rather stay in private practice. Physicians who prefer working in solo or small-practice arrangements appreciate the increased autonomy and control over the work environment that they have, as well as close doctor-patient relationships, compared with those in larger groups

In this session, O’Neill provided attendees his opinion of what factors were most important for a small practice to stay viable. O’Neill offered the following advice:

Analyze your top 10 charges/reimbursements by payer, including immunizations, then approach and negotiate with payers for better reimbursement. “As internists, our bread and butter is really evaluation/management codes,” he says. Physicians can use their payer program participation as leverage, he says.

Identify and micromanage your overhead using accounting software. “If you’re going to manage your overhead, you have to know what it is,” O’Neill adds. Track expenses and determine which reports to generate and read.

Pinpoint the procedures that best fit your practice, then track and optimize their use.

Implement an electronic health record/practice management system to help you improve the care you provide and to optimize your billing and reporting. He recommends using the same vendor for both systems to ensure compatibility.

Consider developing or becoming part of a Patient-Centered Medical Home (PCMH). “That’s where we’re heading,” O’Neill says. One major difference between current practices and PCMHs is that the latter includes one or more care coordinators who follow the patient inside and outside the practice.

Think about using midlevel providers in your practice; they can generate additional revenue.

I will agree with some of his points, but there are issues with others that, in my opinion, you need to be mindful of. Implementing an electronic health/practice management system is the right way to go for the future, but you really have to have a well planned implementation plan and all physicians need to really need to immerse themselves into learning it and setting up templates far in advance of going live. This is the only way it will help you improve your care and optimize your billing and reporting, otherwise it will just hinder, and possibly be the downfall of the entire practice.

I am not completely convinced that the PCMH is the way to go. This is very similar to the old “gatekeeper” system that we had back in the 90′s. If done correctly, it can definitely improve patient care, but the jury is still out on how reimbursement will turn out and how practices will survive within this structure. The other points O’Neill communicated make sense and practices of ANY size should pay attention and heed his advice. Remember, this is your business and livelihood, run the business like a business and if you need an expert to help you along the way, make the investment, but conduct and discuss the return on your investment (ROI) first to ensure that the money you spend will bring forth the results you intend. Of course, this goes for any investment you make in your practice.

NLRB Posting Rule Blocked

dzetter — Thu, 26 Apr 2012 19:47:43 +0000

Here is an update to the previous article on the new labor law poster requirement article we posted on March 31, 2012.

A rule slated to take effect April 30, 2012, that would force most U.S. employers to post a notice of employees’ rights under labor law has been blocked by a federal circuit court on the heels of a federal district court’s determination that the issuing agency lacked authority to approve the rule.

Support Page Now Available for Medicare eRx Payment Adjustment Hardship Exemption Requests

dzetter — Tue, 24 Apr 2012 14:53:22 +0000

In 2009, CMS implemented the Electronic Prescribing (eRx) Incentive Program, which is a program that uses incentive payments and payment adjustments to encourage the use of qualified electronic prescribing systems.From calendar year (CY) 2012 through 2014, a payment adjustment that increases each calendar year will be applied to an eligible professional’s Medicare Part B Physician Fee Schedule (PFS) covered professional services for not becoming a successful electronic prescriber. The payment adjustment of 1.0 percent in 2012, 1.5 percent in 2013, and 2.0 percent in 2014 will result in an eligible professional or group practice participating in the eRx Group Practice Reporting Option (eRx GPRO) receiving 99.0 percent, 98.5 percent, and 98.0 percent respectively of their Medicare Part B Physician Fee Schedule (PFS) amount for covered professional services.

Avoiding the 2013 eRx Payment Adjustment

Individual eligible professionals and CMS-selected group practices participating in eRx GPRO who were not successful electronic prescribers in 2011 can avoid the 2013 eRx payment adjustment by meeting the specified reporting requirements between January 1 and June 30, 2012.

6-month Reporting Requirements to Avoid the 2013 Payment Adjustment:

Individual Eligible Professionals – 10 eRx events via claims
Small eRx GPRO – 625 eRx events via claims
Large eRx GPRO – 2,500 eRx events via claims

For more information on individual and eRx GPRO reporting requirements, please review MLN Article SE1206 – 2012 Electronic Prescribing (eRx) Incentive Program: Future Payment Adjustments.

CMS may exempt individual eligible professionals and group practices participating in eRx GPRO from the 2013 eRx payment adjustment if it is determined that compliance with the requirements for becoming a successful electronic prescriber would result in a significant hardship.

Significant Hardships

The significant hardship categories are as follows:

The eligible professional is unable to electronically prescribe due to local, state, or federal law, or regulation
The eligible professional has or will prescribe fewer than 100 prescriptions during a 6-month reporting period ( January 1 through June 30, 2012)
The eligible professional practices in a rural area without sufficient high-speed Internet access (G8642)
The eligible professional practices in an area without sufficient available pharmacies for electronic prescribing (G8643)

Submitting a Significant Hardship Code or Request

To request a significant hardship, individual eligible professionals and group practices participating in eRx GPRO must submit their significant hardship exemption requests through the Quality Reporting Communication Support Page (Communications Support Page) on or between March 1 and June 30, 2012. Please remember that CMS will review these requests on a case-by-case basis. All decisions on significant hardship exemption requests will be final.

Significant hardships associated with a G-code may be submitted via the Communication Support Page OR on at least one claim during the 2013 eRx payment adjustment reporting period (January 1 through June 30, 2012). If submitting a significant hardship G-code via claims, it is not necessary to request the same hardship through the Communication Support Page.

For more information on how to navigate the Communication Support Page, please reference the following documents:

For additional information and resources, please visit the Electronic Prescribing Incentive Program webpage.

If you have questions regarding the eRx Incentive Program, eRx payment adjustments, or need assistance submitting a hardship exemption request, please contact the QualityNet Help Desk at 1-866-288-8912 (TTY 1-877-715-6222) or via qnetsupport@sdps.org. They are available Monday through Friday from 7am-7pm CST.

WPS: Status of 3 chronic conditions accepted with 97 guidelines only

dzetter — Mon, 23 Apr 2012 15:57:32 +0000

E/M documentation

Here is a follow-up article, to a prior blog post, that was reported by Karen Long of Part B News Practices that followed WPS carrier instructions to document extended history of present illness (HPI) with three or more chronic conditions when using the 95 E/M guidelines must retrain staff to follow the “four or more elements” requirement to avoid lost payments.

“This article is reprinted with permission from DecisionHealth (www.decisionhealth.com), the publisher of Part B News. For more information on Part B News, the leading industry publication for practice managers and physicians, visit www.partbnews.com. To subscribe, visit https://store.decisionhealth.com/Product.aspx?ProductCode=PARTBNEWS.”

by: Karen Long

Published Apr 9, 2012

If physicians choose to use the 97 guidelines, they can document the status of three chronic conditions but must record whether those conditions are improving, stable or declining, says David Zetter of Zetter Healthcare Management Consultants in Mechanicsburg, Pa.

As of April 19, WPS will no longer allow the use of the status of three chronic or inactive conditions in the HPI with the 95 guidelines, according to a March 22 email from the Medicare administrative contractor (MAC) for Iowa, Kansas, Missouri and Nebraska. WPS also is a legacy Part B carrier for Illinois, Michigan, Minnesota and Wisconsin.

Instead, physicians using the 95 guidelines will have to complete at least four of the eight elements of an HPI, Zetter says.

The change will make it more difficult to obtain the HPI elements for patients who do not have complaints, says Dianne Wilkinson, RHIT, a compliance auditor at West Tennessee Healthcare in Jackson, Tenn. Follow-up questions asking about disease maintenance wouldn’t make sense because the patient does not have a complaint.

The change will mean more documentation for physicians, who then will have less time to interact with patients, says Dr. Chris Tashjian of Ellsworth (Wis.) Medical Clinic, a family practice.

WPS no longer using CMS communication

WPS had allowed the status of three chronic conditions in the HPI using the 95 and 97 documentation guidelines based on a years-old CMS communication, the MAC states in the email. But because the comprehensive error rate testing (CERT) contractor does not “adjudicate documentation that way,” WPS made the change.

Neither WPS nor CMS responded to Part B News’ request for comment by press time.

Practices that have documentation templates – on paper or in their EHR systems – that are based on the acceptance of the status of three chronic conditions with the 95 guidelines will have to change those materials, Zetter adds.

Online resources:

WPS Evaluation and Management (E/M) Coding Guide:www.wpsmedicare.com/j5macpartb/resources/provider_types/_files/em-coding-guide.pdf

HHS Press Release: HHS Secretary Kathleen Sebelius Announces Delay of ICD-10 until October 1, 2014

dzetter — Mon, 09 Apr 2012 17:37:00 +0000

In a new press release from HHS, Secretary Kathleen Sebelius announced a proposed rule that would delay the compliance date for ICD-10 from October 1, 2013 to October 1, 2014.

The ICD-10 compliance date change is part of a proposed rule that would adopt a standard for a unique health plan identifier (HPID), adopt a data element that would serve as an “other entity” identifier (OEID), and add a National Provider Identifier (NPI) requirement. The proposed rule was developed by the Office of E-Health Standards and Services (OESS) as part of its ongoing role, delegated by HHS, to establish standards for electronic health care transactions under the Health Insurance Portability and Accountability Act of 1996 (HIPAA). OESS is part of the Centers for Medicare & Medicaid Services (CMS).

The full release can be found on the CMS Website, and more information about this proposed rule can be found on the proposed rule ICD-10 fact sheet. A segment of the HHS press release is located below.

The Department of Health and Human Services (HHS) today announced a proposed rule that would establish a unique health plan identifier (HPID). The change would save the health care industry up to $4.6 billion over ten years by enabling greater automation of electronic health care transactions, in turn helping physicians spend less time interacting with health plans — and more time with patients.

The proposed rule was developed by the Office of E-Health Standards and Services (OESS), as part of its ongoing role, delegated by HHS, to adopt standards for electronic health care transactions under the Health Insurance Portability and Accountability Act of 1996 (HIPAA). OESS is part of the Centers for Medicare & Medicaid Services (CMS). The proposed rule would implement several administrative simplification provisions of the Affordable Care Act.

The proposed rule also would delay by one year, until Oct. 1, 2014, the date by which covered entities must comply with International Classification of Diseases, 10th Edition diagnosis and procedure codes (ICD-10). Covered entities are defined in HIPAA as (1) health plans, (2) health care clearinghouses, and (3) health care providers who electronically transmit any health information in connection with a transaction for which HHS has adopted a standard .

Some provider groups have expressed serious concerns about their ability to meet the October 1, 2013 compliance date. CMS and HHS believe the change in the compliance date for ICD-10, as proposed in this rule, would give providers and other covered entities more time to prepare and fully test their systems to ensure a smooth and coordinated transition among all industry segments.

Keep Up to Date on Version 5010 and ICD-10.
Please visit the ICD-10 website for the latest news and resources to help you prepare, and to download and share the implementation widget today!

CMS has Posted the Proposed CQMs under the Stage 2 NPRM on the CMS Website

dzetter — Fri, 06 Apr 2012 15:39:54 +0000

CMS has posted the full set of proposed Clinical Quality Measures (CQMs) for 2014 as part of the Medicare and Medicaid Programs Electronic Health Record (EHR) Incentive Programs Stage 2 Notice of Proposed Rule Making (NPRM). The public can review the CQMs and submit feedback online.

Proposed CQMs
The proposed CQMs are outlined in two tables that describe each measure and provide additional information for eligible professionals (EPs), eligible hospitals, and critical access hospitals (CAHs) beyond the descriptions listed on the National Quality Forum (NQF) website.

Some of these measures are still in development; therefore, the descriptions provided in these tables may change before the final rule is published. When possible, links have been provided for measures that have corresponding information on the NQF website. If a measure does not have an NQF number, it means that measure has not yet been endorsed.

Public Comment
Public comments regarding these measures should be submitted using the same method required for all comments related to the proposed rule. You can submit public comments online through the federal regulations website.

The deadline for public comments relating to the proposed CQMs and other aspects of the Stage 2 NPRM is May 7, 2012.

Want more information about the EHR Incentive Programs?
Make sure to visit the EHR Incentive Programs website at http://www.cms.gov/EHRIncentivePrograms for the latest news and updates on the EHR Incentive Programs.