CMS Open Door Forum On Home Health Documentation On April 28

In FY 2014, the Comprehensive Error Rate Testing (CERT) program found that more than half (51.4%) of home health claims were paid improperly. Approximately 90% of the 1308 CERT-reviewed claim lines in error were found to “have insufficient documentation errors.”

CMS is now considering developing a voluntary electronic clinical template and a voluntary home health paper clinical template to assist physicians and practitioners in documenting patient eligibility for the Medicare home health benefit. Using clinical templates may reduce the burden on physicians and practitioners who order home health services, according to CMS. The templates have been in the development process for the past year. As part of this process, CMS has been hosting a series of Special Open Door Forum calls to provide an opportunity for physicians/practitioners, home health agencies, and other interested parties to provide feedback on the draft templates. The final Open Door Forum to discuss these templates will be Tuesday, April 28, 2015 at 1:30p.m. EST.

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Attention Hospices: CMS To Reissue CR 9114

Last week, NAHC received notification from staff at CMS that CMS plans to reissue Change Request (CR) 9114. The reissue is in response to concerns and questions many have raised about the requirement that hospices include the name and National Provider Identifier (NPI) number of the attending physicians on the patient’s election statement. NAHC has previously expressed concerns to CMS about the original language and sought clarification after it was released.

From NAHC:

The following is the previously issued language to be revised:

“Information identifying the attending physician recorded on the election statement should provide enough detail so that it is clear which physician or Nurse Practitioner (NP) was designated as the attending physician. This must include, but is not limited to, the attending physician’s name and NPI number.”

Here is the revised language:

“Information identifying the attending physician recorded on the election statement should provide enough detail so that it is clear which physician or Nurse Practitioner (NP) was designated as the attending physician.  This information should include, but is not limited to, the attending physician’s full name, office address, NPI number, or any other detailed information to clearly identify the attending physician.”

Click here for more information from NAHC.

Senate Passes Bill To Repeal SGR

Late yesterday, the Senate voted to pass H.R. 2, repealing the Medicare Sustainable Growth Rate (SGR), putting physicians on a two-track payment system that will continue a federal push toward risk-based payment models, including ACOs and bundled payment models. By 2019, physicians will have to have at least 25% of Medicare revenue tied to payment models to quality for higher payments and the number will triple in 2023. Senators also attempted to pass six amendments to the bill, but all failed. The bill also includes a six-month delay in enforcement of CMS’ “two midnights” payment policy for short hospital stays.

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Tiptastic Tuesday: Top 3 Data Security Issues For Physician Practices

Healthcare technology is starting to play a bigger role in patient care, greatly increasing the chances of patients’ protected health information (PHI) to be compromised. This means that it’s more important than ever for practices to keep their eyes on security trends to stay in compliance and avoid data breaches.

Here are three of the top issues practices will face this year relating to data security:

  1. More laws regulating data sharing with business associates (BAs). Trusting BAs with sensitive patient data is necessary to a practice’s operations. However, breaches can easily occur if PHI isn’t shared securely. This year, there will be increased legal scrutiny for these relationships. Make sure you have language in your contracts discussing the specifics of your associates’ security protocol.
  2. Financial woes from breaches. If practices don’t invest the money into resources needed to keep PHI safe, they will be paying for it later. With every new data breach, there will be higher fines and more lawsuits from patients and other affected parties. It will be much less costly to budget for data encryption and other security features than to face these exorbitant fees.
  3. Seamless data sharing. This year, there will be more pressure on practices to have electronic health records (EHR) systems that easily and securely share PHI with other healthcare providers. Be sure to discuss the possibility of such interoperability with your EHR vendor.

Tiptastic Tuesday: How To Stay In Compliance & Avoid Data Breaches

Healthcare technology is starting to play a bigger role in patient care, greatly increasing the chances of patients’ protected health information (PHI) to be compromised. This means that it’s more important than ever for practices to keep their eyes on security trends to stay in compliance and avoid data breaches.

Here are three of the top issues practices will face this year relating to data security:

  1. More laws regulating data sharing with business associates (BAs). Trusting BAs with sensitive patient data is necessary to a practice’s operations. However, breaches can easily occur if PHI isn’t shared securely. This year, there will be increased legal scrutiny for these relationships. Make sure you have language in your contracts discussing the specifics of your associates’ security protocol.
  2. Financial woes from breaches. If practices don’t invest the money into resources needed to keep PHI safe, they will be paying for it later. With every new data breach, there will be higher fines and more lawsuits from patients and other affected parties. It will be much less costly to budget for data encryption and other security features than to face these exorbitant fees.
  3. Seamless data sharing. This year, there will be more pressure on practices to have electronic health records (EHR) systems that easily and securely share PHI with other healthcare providers. Be sure to discuss the possibility of such interoperability with your EHR vendor.

Breaking News: NAHC’S F2F Lawsuit To Go Forward

Yesterday, the federal district court issued a victory for the National Association for Home Care & Hospice (NAHC) and the home health agencies, Medicare participating physicians, caregivers, and beneficiaries it represents. The U.S. District Court for the District of Columbia declared that it has the power to hear a challenge to the validity of a Medicare rule that requires physicians to provide a narrative explaining why the patient meets Medicare coverage standards for home health services. The court issued the order to deny Medicare’s effort to have the lawsuit dismissed by the court.

The court also granted dismissal of two additional claims in the lawsuit. NAHC challenged the ambiguity of the interpretive guidance issued by CMS along with its failure to waive the recoupment of alleged overpayments under the Medicare “without fault” provision. The court found that the factual complexities warranted a review of individual claims determinations at the administrative levels prior any judicial intervention.

NAHC and Medicare are now moving forward with the lawsuit. If the lawsuit is successful, Medicare will be required to reopen and pay any claim previously denied for an insufficient narrative and stop any further claim reviews related to the narrative requirement. NAHC has urged home health agencies to consider appealing any narrative-related claim denials while the lawsuit is progressing. This will give agencies the opportunity to have the claims reviewed by the Administrative Law Judges and will also allow for easy identification of claims that may be subject to reopening if the lawsuit is successful.

*Information provided by NAHC.

Tiptastic Tuesday: Practical Tips For Improving Patient Collections In 2015

The Affordable Care Act is now entering its second year. With continued implementation of its many provisions, both patients and providers are still getting use to the new law. 2015 will see a steady increase in the number of patients becoming insured-many for the first time. With higher out-of-pocket costs, more and more patients will become financially responsible for larger portions of their claims. Therefore, as a provider, it is integral to set financial policies in place, so that you are able to collect all monies for your services.

In an effort to assist providers with collections, we have put together a few strategies any organization can implement:

  • Establish a financial policy. Practices should establish a financial policy that is reviewed and distributed every year. This comprehensive policy should provide patients with a clear understanding of the practice’s expectations with regards to patient balances. Make sure each patient signs a copy which you should keep in his or her file. Please note, it is important to update your financial and insurance verification policies annually to reflect requirements of your individual practice.
  • Collection of patient demographic and insurance information should be obtained when the patient makes the appointment. Make sure to enter insurance information into the system prior to the visit for eligibility verification.  Advise each patient in advance to bring a copy of current insurance cards, applicable co-pays, and any deductibles owed. We also suggest that you advise your patients to verify benefits with their particular insurance company prior to the appointment. This way, the patient thoroughly understands his or her contractual obligations.
  • Eligibility verification process. For providers that use our software, Caretracker/Optum PM and Physician EMR, it performs an automatic eligibility check for the next five dates of service. Each patient’s eligibility history is automatically updated when their check is complete. Other systems may work differently and it is important to utilize this functionality to capture your patients’ current insurance information. If you do not have software that checks eligibility, we suggest that you designate a staff member to verify your patients’ insurance prior to visits.
  • Co-pay collection. Practices should collect applicable co-pays prior to visits.
  • Payment plan. With higher out-of-pocket costs and increasing premiums, there’s a good chance there will be a patient who is unable to pay for a service at the time of visit. For situations like these, it may be helpful to set up a payment plan with a promise to pay. Draft a form and make sure the patient signs it. Give the patient a copy and keep one in your accounts receivable section. This way, you will be alerted with a reminder to process a credit card, or collect cash or a check. Be sure to always follow up with a patient who has not paid on time.
  • Credit cards. Another great option for your organization is to have a credit card machine. Credit cards are a safe option to ensure payments are made on time.