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Risk Assessment of Medical Practice Billing Companies

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Office of Inspector General

trites

[By Pati Trites MPA, CHBC with Staff Reporters]

The Office of Inspector General [OIG] believes a medical billing company’s written policies and procedures, its educational program and its audit and investigation plans should take into consideration the particular statutes, rules and program instructions that apply to each function or department of the billing company.

Co-ordination Needed

Consequently, coordination between these functions is needed, with an emphasis on areas of special concern that have been identified by the OIG through its investigative and audit functions.

Furthermore, the OIG recommends that billing companies conduct a comprehensive self-administered risk analysis or contract for an independent risk analysis by experienced health care consulting professionals. This risk analysis should identify and rank the various compliance and business risks the company may experience in its daily operations.

Risk Analysis

Once completed, the risk analysis should serve as the basis for the written policies the billing company should develop. The OIG provides the following specific list of particular risk areas that should be addressed by billing companies. It should be noted that this list is not all-encompassing and the risk analysis completed as a result of the company’s audit may provide a more individualized roadmap. Nonetheless, this list is a compilation of several years of OIG audits, investigations and evaluations and should provide a solid starting point for a company’s initial effort.

Problem List

Among the risk areas the OIG has identified as particularly problematic are:

  • Billing for items or services not actually documented;
  • Unbundling;
  • Upcoding, such as, for example, “DRG creep;
  • Inappropriate balance billing;
  • Inadequate resolution of overpayments;
  • Lack of integrity in computer systems;
  • Computer software programs that encourage billing personnel to enter data in fields indicating services were rendered though not actually performed or documented;
  • Failure to maintain the confidentiality of information/records;
  • Knowing misuse of provider identification numbers, which results in improper billing;
  • Outpatient services rendered in connection with inpatient stays;
  • Duplicate billing in an attempt to gain duplicate payment;
  • Billing for discharge in lieu of transfer;
  • Failure to properly use modifiers;
  • Billing company incentives that violate the anti-kickback statute or other similar Federal or State statute or regulation;
  • Joint ventures;
  • Routine waiver of copayments and billing third-party insurance only; and
  • Discounts and professional courtesy.

Additional Risk Areas

The physician-executive should understand that a billing company’s prior history of noncompliance with applicable statutes, regulations and Federal health care program requirements may indicate additional types of risk areas where the billing company may be vulnerable and may require necessary policy measures to prevent avoidable recurrence.

Additional risk areas should be assessed by billing companies as well as incorporated into the written policies and procedures and training elements developed as part of their compliance programs.

Assessment 

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Billing companies that do not code bills should implement policies that require notification to the provider who is coding to implement and follow compliance safeguards with respect to documentation of services rendered.

Moreover, the OIG recommends that billing companies who do not code for their provider clients incorporate in their contractual agreements the provider’s acknowledgment and agreement to address the above coding compliance safeguards.

Conclusion

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Political Primer on Healthcare Reconciliation

What it is – How it Works

By Staff Reporters

Several ME-P readers have contacted us for a definition of the term “reconciliation” and what it means in the current political debates and the recent Healthcare Summit in Washington, DC.

Definition,

According to Wikipedia, Reconciliation is a legislative process intended to allow consideration of a contentious budget bill without the threat of filibuster. Introduced in 1974, reconciliation limits debate and amendment, and therefore favors the majority party. Reconciliation also exists in the House of Representatives, but because the House regularly passes rules that constrain debate and amendment, the process has had a less significant impact on that body.

Healthcare Significance  

“In 2009 the House and Senate each passed separate healthcare reform bills. The Senate bill passed only after all 60 members of the Democratic caucus voted for cloture to stop an attempted Republican filibuster. Negotiations to produce a compromise bill acceptable to majorities in both houses were thrown off track by Republican Scott Brown’s victory in the Massachusetts.

After Brown’s victory, the Democratic caucus no longer had enough votes to stop a Senate filibuster of the compromise bill. An alternative plan was for the House to pass the Senate bill verbatim, and for each house to pass another bill that would embody the compromises agreed to in the negotiations. This separate piece of legislation, which might possibly include a public option, would require use of the reconciliation procedure in the Senate.”

Of Minutia

No matter whether the House votes on reconciliation or the Senate bill first, the Speaker can ensure that the health care bill is signed into law before reconciliation. (The dirty little secret of Congress is that even if the House votes to pass the Senate health care bill tomorrow, the Speaker has unilateral power to hold that bill at her desk until January 3rd of next year before sending it to the President and starting the 10-day Constitutional veto clock).

Assessment

The Republican leader in the Senate, Mitch McConnell, said: “Using reconciliation would be an acknowledgment that there is bipartisan opposition to their bill, another in a series of backroom deals, and the clearest signal yet that they’ve decided to completely ignore the American people.” according to the New York Times, February 19, 2010.

Other opponents of Democratic legislative initiatives in the 111th Congress began to refer to reconciliation as the “nuclear option, although that term had previously been used to refer only to a majoritarian procedure to effect a formal change in Senate rules.

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Note: Cloture  is the only procedure by which the Senate can vote to place a time limit on consideration of a bill or other matter, and thereby overcome a filibuster. Under the cloture rule (Rule XXII), the Senate may limit consideration of a pending matter to 30 additional hours, but only by vote of three-fifths of the full Senate, normally 60 votes.

Conclusion

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The ME-P at Your Service

Collegial Greetings – All Readers and Subscribers        

By Ann Miller; RN, MHA

[Executive-Director]

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The Medical Executive-Post is a thriving online and onground community that connects  medical professionals with financial advisors and management consultants. We participate in a variety of educational seminars, teaching conferences and national  workshops.  We produce journals, textbooks, handbooks and award-winning dictionaries. 

Our didactic heritage includes innovative Research & Development initiatives, litigation support activities, engaged private clients and media sourcing in the sectors we passionately serve.

Through the unbiased collaboration of this sharing forum, we have become a leading network in the healthcare administration, economics and financial planning space for doctors and hospital executives.

Assessment 

Even if not seeking our services, we hope this site is useful to you. In the modern Health 2.0 era, our goal is to “bridge the gap between medical mission and profit margin.”       

Thank you in advance for allowing us to be of service! 

Wall Street and athenahealth

More than just a Hiccup?

By Staff Reporters

According to TheStreet, health care information company AthenaHealth(ATHN Quote) just announced what seemed like a minor account hiccup.

Last night however, another accounting hiccup for AthenaHealth surfaced, and the health care information company announced that it will be postponing its fourth-quarter earnings.

Link: http://www.thestreet.com/story/10690575/1/athena-health-dives-on-accounting-issues.html

Assessment

Investors now fear that the seemingly isolated accounting events, one right on top of the other, could snowball.

According to one physician-investor,“this looks less like a hiccup, and more like a spasm of the diaphragm, which is innervated by the phrenic nerve.”

Conclusion

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Are You Prepared for a HIPAA Dental Audit?

Why – or Why Not?

By D. Kellus Pruitt; DDS

If you are a dentist and pay ADA dues year after year to be kept better informed about protecting your patients as well as your practice, your ignorance of HIPAA is not entirely your fault. The ADA clearly dropped the ball. Nevertheless, you could still suffer fines as high as $1.5 million for what our leaders failed to emphasize.

It’s time members accept the shameful truth about the ADA Department of Dental Informatics, headed by Ms. Jean Narcisi. Narcisi, working under the direction of ADA Sr. Vice President Dr. John Luther, has been abysmally negligent in preparing members for HITECH HIPAA, and now the compliance deadline is only days away. It’s been months since any information about HIPAA has been published in any ADA publications. Why?

HIPAA Avoidance 

Why do ADA leaders avoid discussing HIPAA? They are ashamed, not unlike embarrassed scam victims. About six years ago, Newt Gingrich visited ADA Headquarters and “lied” to ADA Delegates about the future of eHRs in the US. Then he bribed the ambitious career bureaucrats in the crowd with millions of dollars in federal grants to play along with the scam. I can only imagine that the Delegates must have been star-struck by the former Speaker of the House, because nobody dared asked the tough questions.

Newt’s Slick

So here I am, Ms. Jean Narcisi. I’m again doing your job because your mistakes I pointed out years ago now have you frozen in shame. If you disagree, and consider self-respect as something worth defending, let’s discuss your innocence in front of everyone – including the ADA members who pay your salary. Or, you can continue to hide from your responsibilities. This crap will catch up with you soon enough, Ms. Narcisi, and Dr. Luther no longer has the courage to stick his neck out to protect you. He’s also scared of me. You are alone.

Newsletters 

Dom Nicastro, senior managing editor at HCPro, edits the Briefings on HIPAA and Health Information Compliance Insider newsletters. He posted an informative article on HealthLeadersMedia.com today titled “HIPAA Compliance Questions to Ask as HITECH Date Nears.”

http://www.healthleadersmedia.com/page-1/TEC-246514/HIPAA-Compliance-Questions-to-Ask-as-HITECH-Date-Nears

The article features Chris Apgar, CISSP, president, Apgar & Associates, LLC, in Portland, Oregon. Mr. Apgar notes that “many covered entities and business associates have consistently failed to comply with the HIPAA Security Rule.” Apgar adds, “I find this over and over when conducting compliance audits.”

The lack of compliance described by Apgar is consistent with the results from my study in 2008, “HIPAA Rules and Dentistry.”

https://healthcarefinancials.files.wordpress.com/2008/08/hipaa-survey-dentists4.pdf

Study Abstract

A survey of 18 dentists was performed using the Internet as a platform. The volunteer dentists’ anonymity was guaranteed. The dentists were presented with ten HIPAA compliancy requirements followed by a series of questions concerning their compliancy as well as the importance of the requirements in dental practices.

The range of compliancy was found to be from 0% for the requirement of a written workstation policy to 88% for that of password security. The average was 49%, meaning that less than half of the requirements are being respected by the dentists in this sample.

Frustrated at Mandates

Frustration with the tenets of the mandate, as well as open defiance is evident by the written responses. In addition, it appears that a dentist’s likelihood of satisfying a requirement is related to the dentist’s perceived importance of the requirement. Even though this is a limited pilot study, there is convincing evidence that more thorough investigation concerning the cost and benefits of the requirements need to be performed before enforcement of the HIPAA mandate is considered for the nation’s dental practices. 

HIPAA

Questions to Consider

Apgar says that the security rule requires covered entities to consider these questions:

  • Has a risk analysis been conducted lately? Was it properly documented? Were damages mitigated and were the risks acceptable?
  • Is privacy/security training current? Have new workforce members who will have access to personal health information (PHI) been adequately trained? Has refresher training for all staff been accomplished? Have security reminders been provided?
  • Are the office policies and procedures complete, current and enforceable? Are workforce members trained on the policies and procedures they are required to respect?
  • Has a comprehensive audit program been implemented? (The security rule requires three periodic audits and an “evaluation” or compliance audit). Are evaluations current? Have audit findings been addressed and documented?
  • Have up to date disaster recovery and emergency mode operations plans been communicated and recently tested?
  • Are CMS’ remote access guidelines being followed? (These are not part of the rule, but CMS earlier indicated remote access management would be included as audit criteria).
  • Are data in transit and data at rest encrypted? Are non-electronic PHI being protected?

Office of Civil Rights

Mr. Apgar adds that even though the Office of Civil Rights isn’t saying when audits will start, if a complaint is filed with OCR alleging ”willful neglect,” OCR is mandated by statute to investigate. The fines for “willful neglect” are much more devastating than fines for simple carelessness. And “willful neglect” is a subjective judgment call made by inspectors … who work on commission.

Assessment

Unfortunately for the nation’s dentists, the statute invites disgruntled patients and employees to celebrate revenge via federal inspectors. And, the more dentists are fined, the more the inspectors make. That can’t end well. Where are you hiding, Jean Narcisi? You’ve been silent far too long. Let’s talk. Don’t make me come get you.

Editor’s Note: The applicability of this post to all medical specialties is obvious.

Conclusion

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Reality TV or Healthcare Summit?

Preparing for the Debate and a TV Audience 

By Staff Reporters

In convening today’s bipartisan health session, President Obama is angling to recreate the kind of spontaneous, unscripted debate that gave him a decided advantage when he took questions on live television at a House Republican retreat in Baltimore Maryland, last month.

Link: http://www.nytimes.com/2010/02/25/health/policy/25summit.html?ref=health 

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Assessment

Or, will the meeting be like the summer’s flu summit; much ado about nothing?

Conclusion

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