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Mental Health Coding and Billing

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Dr. David E. Marcinko MBA

By Dr. David Marcinko MBA

http://www.CertifiedMedicalPlanner.org

Coding Classification

The classification and coding systems used by mental health insurers, both diagnosis-related groups (DRGs) through revenue codes for facility and program services and current procedural terminology (CPT) for in and out patient professional services and consultations, are still being defined through historical methodologies and are vague compared to the medical classification coding structure.

Example:

As an example, mental health insurers classify Tourette Syndrome (TS) as a “mental disorder.” In fact, TS is an inherited, neurobiological disorder, and both neurologists and psychiatrists treat TS with the same medications. If TS were reclassified under the medical coding structure, TS would not only receive potentially a better reimbursement but public perception of TS as a “mental disorder” would be changed.

DSM-IV-TR

The Diagnostic and Statistical Manual of Mental Disorders (4th edition, text revision), also known as the DSM-IV-TR, is a manual published by the American Psychiatric Association (APA) that includes all currently recognized mental health disorders. The coding system utilized by the DSM-IV is designed to correspond with codes from the International Classification of Diseases, commonly referred to as the ICD. Since early versions of the DSM did not correspond with ICD codes and updates of the publications for the ICD and the DSM are not simultaneous, some distinctions in the coding systems may still be present.

For this reason, it is recommended that users of these manuals consult the appropriate reference when accessing diagnostic codes. In addition, DSM5 was last updated in May 2013.  For more information, contact the APA at (800) 368-5777.

Assessment

Besides the above coding manual, the International Statistical Classification of Diseases and Related Health Problems” produced by the World Health Organization (WHO) is another commonly used manual which includes criteria for mental health disorders.

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NPI: More Than Just a Number

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Billing and Reimbursement are dependent on the taxonomy code designation and detail

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By Susan Theuns, PA-C, CPC, CHC

“Taxonomy codes and other elements of NPI registration directly affect a provider’s ability to submit claims, order services, and receive reimbursement.”

Back when the National Provider Identifier (NPI) was implemented in 2005 as part of the Health Insurance Portability and Accountability Act (HIPAA), a new identifier accompanied it: the taxonomy code. With that, the Centers for Medicare & Medicaid Services (CMS) developed the National Plan and Provider Enumeration System (NPPES) to officially assign these unique identifiers of the provider. These codes were created to improve the efficiencies and effectiveness of electronic medical claims submission and electronic health information.

What’s in a Name?

When registering for an NPI, one of the elements that also needs to be completed is the selection of a taxonomy code. Taxonomy codes are nationally standardized 10-character codes that are alphanumeric. The definitions range from prosthesis case managers to transplant surgeons. When healthcare providers initially applied for an NPI number, little importance was associated with selection of the taxonomy codes. However, now payers, including Medicare and Medicaid, are rejecting claims based on inconsistency of services provided and taxonomy codes. Now it matters.

The Healthcare Provider Taxonomy Code Set is available from the Washington Publishing Company (WPC) at wpc-edi.com. Taxonomy codes are maintained by the National Uniform Claim Committee, nucc.org, and update twice yearly with effective dates for changes April first and October first. Information included with the hierarchical classifications include descriptions and definitions as well as the codes themselves. The codes can be a primary (level I classification) or subclassifications (level II and III). The more detailed a classification, the more specialized the description. These are the codes that determine a provider’s area of concentration within their discipline, so being generic is not as effectual as drilling down to the most specific code. Think of this as an unspecified versus a specified code.

Depending on the underlying area of expertise, there may be more than one taxonomy code to choose from. For example, a “hand surgeon” may be subclassified under orthopaedics or plastic surgery – depending on the physician’s training. Sports Medicine is another example: there are 8 different taxonomy codes for this specialty under Emergency Medicine, Family Medicine, Internal Medicine, Orthopaedics, Pediatrics, Physical Medicine & Rehabilitation, Psychiatry & Neurology and even Chiropractic. By definition, selection of the code does not require board certification per se; but it does require special education, training, experience and knowledge in the selected area. Therefore, it is important to carefully select any subclassification from the correct and most accurate level I classification.

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Case Studies: Taxonomy Errors that Affect Reimbursement and Functionality

As healthcare becomes more technologically integrated, accuracy in electronic claims submission data becomes critical to reimbursement. In today’s world, a slight variation can make the difference between full payment and denial. Because a provider’s taxonomy code resides in the NPI registry, it has a direct relationship to payer credentialing. The taxonomy code identifies any specialty or sub-specialty that a provider has. Examples of taxonomy errors and necessary updates are (1) when a resident or fellow graduates and becomes a board-certified or state licensed physician, (2) a provider obtains specialty credentials i.e. orthopaedist becomes a trauma, hand or spine specialist, primary care provider becomes a geriatrics or palliative care specialist or hospitalist, and so forth. There are numerous sub-specialties available nowadays that impact when a physician can act in a consultant role from a billing perspective.

Here are some case scenarios that can result in non-payment or lack of services:

  1. A registered nurse (RN) completed advanced training and is now a licensed Certified Registered Nurse Practitioner (CRNP). She worked in this role for several years before being told by a patient that the prescription she had given her for diabetes supplies was denied by the pharmacy. Upon researching the root cause of the denial, it was discovered that the CRNP had never updated her taxonomy code from RN to CRNP in the NPPES database. Only a healthcare provider can order Durable Medical Equipment (DME) and supplies for a patient.
  2. A general orthopaedist saw a patient in the office and asked a colleague with more specialized training to see the patient with him when faced with a complex orthopaedic problem. Both physicians (they had the same employer and billed under the same group NPI), tried to bill an evaluation and management code for the services they rendered. One claim was paid and one claim was denied as a duplicate service. Research revealed that although one physician specialized in trauma and the other in foot and ankle, both used the generic taxonomy code of 207X00000X. Had they each selected a more detailed code, they both would have been eligible to receive reimbursement for the services they rendered on the same patient, same day.

See Figure: 1

A geriatrics specialist consulted on numerous hospital patients at the request of the admitting hospitalist, an internist. All of the Medicare Part B claims and some commercial claims were denied for these hospitalized patients and the geriatrician could not understand why. Investigation of the claims showed duplicate claims for internal medicine subsequent hospital care, no designation of attending of record, and care denied as non-participating under specialty contracts. All of these situations resulted from the provider never updating his taxonomy code from Internal Medicine to Geriatric Medicine when he passed his boards 7 years prior. Even the specialty contract recognized him as primary care and disallowed his consults. In addition, the hospitalist had never updated his taxonomy code from “internist” to “hospitalist”, which added another aspect of billing inaccuracy to his claims.

  • A new graduate took a job as a hospitalist and was fully credentialed upon hire, several months after completing her residency program. As a “student” in a residency program, she had applied for her NPI and correctly selected taxonomy code 390200000X.

See Figure: 2

However, she neglected to update her taxonomy code to “hospitalist” as the primary designation and “internal medicine” as the secondary when she graduated and took the new job. This resulted in rejections and denials deeming her as ineligible to provide billable services.

  • A physician received an inquiry from state Medicaid questioning whether or not he was a sole proprietor or not. They were holding claims awaiting his response. A quick check of his NPI profile showed that it had not been updated since 2007, at which time he had indicated that he was a sole proprietor. Since his initial NPI application, he had become employed by a medical group and was billing under his individual NPI and group NPI. Once he accessed the portal and changed the response to sole proprietor to “no”, the credentialing issue with Medicaid was resolved.
  • Working the rejection and denial billing reports, a director noted a pattern in the rejections from various payors for one physician stating that the provider was not eligible to provide that type of service. Careful inspection revealed an outdated and incorrect taxonomy code on the provider NPI profile that was inconsistent with the services being provided.

See Figure: 3

With all of these issues, the providers technically have 30 days to notify NPPES of any changes. Not adhering to this guideline is a self-imposed penalty that exceeds any potential fines from NPPES since reimbursement can be negatively affected. Most likely because of the reimbursement consequences, NPPES rarely imposes fines for delayed updates to a provider NPI, although they maintain the right under federal guidelines.

Figures: Figures 1 2 3

Assessment

This critical information should be carefully reviewed upon hire and annually to ensure accuracy in reporting and billing. New taxonomy codes are added bi-annually so new sub-specialties may become available that would allow a healthcare provider to be more specific than previously. In addition, providers of all levels should be encouraged to be part of the process.

An NPI is a provider’s for life and is not dependent upon employer so they need to be engaged and part of the process. Most of the information on the NPPES website is accessible by the public. This means that if a provider puts a home address or home phone/cell phone number for contact, their patients now have access to this information. It is a best practice to use only business contact addresses and phone numbers for your NPI for this reason.

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9.13 NPI Logo and Business Card Gelling Ideas 24

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Summary

Taxonomy codes and other elements of NPI registration directly affect a provider’s ability to submit claims, order services, and receive reimbursement. This often overlooked and neglected piece of a provider’s NPI warrants regular review and updating when any changes occur, such as name change, office move, board certification, change in role, or shift in the specialty-focus of a practice, despite official certification. Last, but not least, the provider user name and password for NPPES and the NPI database are the same for the Provider Enrollment, Chain and Ownership System (PECOS), CMS Analysis & Information (A&I), and the EHR Incentives Program portal to report Meaningful Use and PQRS. As with all user names and passwords, they need to be maintained but carefully protected. It will save a lot of headaches for those who rely on these on-line service portals for their livelihood.

References

CMS Center for Program Integrity, Medicare Provider/Supplier to Healthcare Provider Taxonomy Crosswalk, November 2015.

National Plan and Provider Enumeration System, https://nppes.cms.hhs.gov/NPPES/Welcome.do

Washington Publishing Company, Health Care Provider Taxonomy Code Set, http://www.wpc-edi.com/reference/

ABOUT:

Susan Theuns, PA-C, CPC, CHC, is the administrative director of physician practices at MedStar Union Memorial Hospital in Baltimore, Maryland. In addition to her certifications, she holds degrees in Allied Health, Business Management and Leadership & Education. Theuns serves as a national advisor and is a contributing author for The Business of Medical Practice, 3rd edition. She is a member of the Baltimore, Maryland, local chapter.

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Compensation Trends for Allied Healthcare Professionals

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Beyond Physician Salary [Average by Position]

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  2. The 2015 Physician Pay Check-Up

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No More 10 and 90 Day Global Periods

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New Changes on the [CMS Payment Reform] Horizon
[By Dreama Sloan-Kelly MD CCS]

thDid you hear about the changes that are coming down the pike in regards to global services when billing for surgical procedures — be they in the office, in an ambulatory surgical center, or in the hospital?

CMS released their final 2015 Medicare Physician Fee Schedule (MPFS) ruling late last year. Embedded in this document was a proposal by CMS to get rid of both the 10 day and 90 day global periods! In fact, they want to do away with global period billing all together and have all procedures paid based on the work required to do the procedure itself — thereby billing for all post-surgical visits separately using E/M codes.

According to the final ruling, CMS proposes to transform all 10 day global services to ZERO global days starting in 2017. They will do the same in regards to 90 day global services starting in 2018. And, according to the U.S. Department of Health and Human Services (HHS) and the Office of Inspector General (OIG) they have “identified a number of surgical procedures that include more visits in the global period than are being furnished”. They go on to say that they are “also concerned that post-surgical visits are valued higher than visits that were furnished and billed separately by other physicians such as general internists or family physicians”. Based on the final ruling, they plan to begin the transition as previously stated in 2017 after they have considered all comments.

The ruling goes on to state, “as the agency begins revaluation of services as 0-day global periods, we will actively assess whether there is a better construction of a bundled payment for surgical services that incentivizes care coordination and care redesign across an episode of care”. So let’s talk reality and my take on this change.

Over the past few weeks I have read a lot of articles on this subject from various pundits in the industry — they are actually arguing that this change will mean increased reimbursement when you combine the separate payment for the procedure itself along with the visit by visit billing for the post-surgical follow up care when compared to the current reimbursement rate.

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Personally, I think they are all wrong for the following reasons:

Procedure Reimbursement Amount: This is the wild card. They are going to use the same RVU system that has always been used to calculate payment — but I guarantee you the payment for the procedure will not be anywhere near the reimbursement for the global package. I think the closest we could get to estimating the reimbursement rate of the procedure is to figure out what the current surgical care only rate would be (ie. as if you appended Modifier 54 to the procedure code). Beware that this rate would still encompass the pre-surgical evaluation — which I am assuming would be carved out since that is a part of the current global package they are trying to phase out.

Post Op Visits: Getting a patient to comply with medical visits is hard enough — now adding in the fact they would have to pay a copay each time — most often a specialty co-pay is going to make it even harder. Patient’s understand their follow up visits are currently covered in the cost for the surgery, and hence they tend to show up to these visits knowing they do not have any out of pocket expenses. If the proposed change comes to fruition many of the post-surgical visits may become cost prohibitive for a lot of patients and actually lead to a decrease in the number of follow up visits the patient actually schedules. Once the patient starts to feel better their motivation to return dwindles.

Lower Reimbursement Rate for Post-Surgical Visits: It is clearly stated in the CMS ruling that it is felt the post-surgical follow up care visits are paid at a higher rate than what a regular E/M visit would be paid for had the patient been seen by a primary care provider or an internist. That simple statement confirms to me that when the new procedure rate is combined with the individual visit payment rate, the overall reimbursement rate will be less than what is currently being paid.

So, how do you prepare?

First, stay on top of all bulletins coming from CMS in regards to this issue. Most of your medical societies and/or specialty societies have taken clear positions in regards to this matter — so be sure to stay in the loop and become a part of the process.

Run a report that allows you to pinpoint the average number of post-surgical follow up visits for your most billed procedures. This will give you an idea of the average number of follow up visits for particular procedures you know you will bill for if this transition does occur. Does this mean this number will be exact — NO — I would factor in a decrease of 15-20% for visits across the board based on the dynamics I previously described.

Lastly, begin creating a policy in regards to post-surgical follow up care that can act as an education tool for the patient, teaching them the important benefits of being compliant with their post-surgical care schedule and also warning them about the possible increase in out of pocket cost. Being transparent can go a long way into easing patient’s fear and encouraging their follow through.

As always I have included documentation for your library of information — you can find the CMS 2015 MPFS final ruling fact sheet HERE! I also created a brief video presentation on this hot topic HERE

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Thoughts on an Emerging Hybrid [Two-Tiered] Medical Payment Model

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The Changing Reimbursement Paradigm Shift

[By Dr. David Edward Marcinko MBA CMP™]

[By Prof. Hope Rachel Hetico RN MHA CPHQ CMP™]

David and HopeCurrent medical payment and reimbursement structures involve the submission and payment of medical CPT® coded claims.

So, some doctors feel they need to “up-code” to maximize revenue; or “down-code” for fear of having a claim denied.

Moreover, this pay-for-quantity model is slowly being relegated to the past in light of current P4P, ACO, and values based reimbursement models that favor modern payment-for-quality initiatives.

Tug-of-War System

Obviously, contradictory business goals bastardize the system into a payer versus provider tug-of-war, with patient care as a potential bargaining chip.

Instituting quality metrics should be included in this equation, and, a hybrid reimbursement model may be a viable option while integrating quality care metrics and reducing costs for all stakeholders.

A Two Tied System

This hybrid reimbursement system might use a two-tiered payment structure something like this:

  1. For the first payment, claims would be paid at hypothetical rate of 60% within one week of submission; partially decreasing office ARs, and favoring the time-value of money [TVM] equation.
  2. The second payment, consisting of the remaining zero to 40% of some total maximum allowable fee, is then paid quarterly. It would be based on scores like patient satisfaction, quality metrics, and stewardship of healthcare resources by analyzing a statistically valid sample of patient encounters taken from the electronic health record [EHR].

Green Dollars

Assessment

Such a hybrid payment system would remove unnecessary steps, like re-submitting claims and would lower the operational and administrative costs of healthcare claims processing.

These changes would decrease operational office costs and drive quality stewardship of the diminishing healthcare dollar.

Conclusion

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How Hospital Billing Impacts the Patient Experience

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It’s About … the Invoice

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Here, Connance visually shows how hospital billing process is directly correlated to the patient experience.

Assessment

Patients who encounter problems with their physician’s billing office are less likely to recommend that physician/clinician to others.

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Medical Office Fee Strategies for Disgruntled Patients

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Adroitly Handling a Tough but Common Office Situation

[By Dr. Gary L. Bode MSA CPA]

A common scenario, in medical practice, is patient disgruntlement over professional fees.

The Scenario

This scenario should not occur in front of other patients. Many receptionists find that genuine, cute little quips like, “I know it seems high, but (wink), I’m expensive to maintain,” defuse the situation by gentling pointing out the overhead factor.

The Balk

When a patient balks at fees, gently and politely imply that we could inquire if the local plumber was available to do the exam, procedure or surgery.

Assessment

This brings training and relative cost issues into play while making them smile.  Costs are high, but justifiable.

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Snarky Example of a Medical Practice RAC Audit

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RAC Repayment Demand – Query

I just received a demand for payment from the RAC program for $32.46. I treated a patient with a non-displaced fibula fracture with a BK CAM boot and crutches. I coded 99212-25 and 27786,73610 on 1-29-09.  The audit claims the evaluation and management is part of the fracture care.

Should I appeal for $32.46?

Back then (3 years ago), my records were hand-written and not as comprehensive as they are now with EHR. Am I exposing myself to further inquiry by sending my admitedly inadequate records?

Doctor Name Withheld

Conclusion      

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Is Informatics the The Curse of Healthcare Reform?

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Medical Coding Complications and Greed

[By Darrell K. Pruitt DDS]

Coding complications in government healthcare ALWAYS favor the house — CMS guarantees it with lawsuits and whistleblower rewards that could attract dishonest employees. Are you careful who you hire?

Complications 

Complications in healthcare informatics – including 5-digit CPT® code mistakes as well as foul-ups that involve physicians’ “voluntary” 10-digit National Provider Identifier numbers – ALWAYS grant insurers more time to pay past-due bills owed to their clients and their clients’ doctors.

Call me Cynical 

Call me cynical, but if interest rates climb ever higher as predicted, watch for unexplained, proportional increases in coding errors to help fund insurance CFOs’ bonuses while raising the cost of healthcare even more without improving value. Is it any wonder why Americans don’t get the quality of healthcare we purchase compared to citizens in other countries? Tax-payers in my neighborhood are begging for in-network providers who put their patients’ interests ahead of insurers’ as much as allowed by insurers’ self-serving rules – without committing fraud. As a general rule, healthcare stakeholders accommodate parasites more than principals.

CPT® Codes and Patient Care 

Accurate CPT® coding may have nothing to do with patient care, but CMS makes it nevertheless important to physicians. Whereas the most innocent NPI foul-ups reliably delay payment and never turn out well for providers, the new fraud and abuse provisions of the Patient Protection and Affordable Care Act [ACA] can cause an innocent coding mistake on a Medicare claim to land the doc in court with charges of fraud depending on the quality of employees one hires – but only if the error favors the provider and not the payer. In June, David Burda posted “Attorney tells audience to brace for a storm of whistle-blower lawsuits” on ModernHealthcare.com.

http://www.modernhealthcare.com/article/20100623/NEWS/306209989/-1

Of Whistle-Blower Lawsuits

Burda reports that healthcare attorney Joanne Judge, a partner with Stevens & Lee in Reading, Pa., predicts a significant increase in whistle-blower lawsuits simply because the new law makes it far too easy for a dishonest employee to file an unwarranted lawsuit. No longer is there a requirement for the whistleblower, who stands to win money from his or her patriotic effort, to directly witness the crime. That kind of idea could catch on in this economy.

computer-hardware1

“The new law also converts accidental Medicare overpayments to providers into potential false claims, Judge said. She said the law considers an overpayment as fraud if the overpayment isn’t identified by the provider and returned to the government within 60 days. Judge said that will require providers to beef up their internal billing systems to detect an overpayment as soon as possible and then send Medicare back its money.”

Assessment 

What can possibly go wrong with that plan? Thorough background checks on all new employees is increasingly important, doc. For my employment security issues, I’ve learned to depend on Richard at Investigation Resource Service out of Dallas. He’s never let me down (This is not a paid ad).

Conclusion

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Understanding CPT® Code Payment Components

Determinations More Complex than Most Believe

By Staff Reporters

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Currently, there are more than 10,000 physician services designated by the current procedural terminology (CPT®) or healthcare common procedure coding system (HCPCS) codes.  Each reflects the three major cost drivers of a particular procedure:

  • Physician work effort or the relative value unit (RVUw) of medical providers’ work efforts, pre-service, intra-service and post-service time.

Patients may exhibit anxiety when examined orduring procedures resulting in the need for additional timeand effort by the physician to respond to and prepare for the examination or procedure. This uniformly adds moretime and stress to the pre-service and intra-service period as doctors respond to constantly changing behavior, questionsand level of cooperation in varying specialties.  Follow-up communicationwith employers, family, friends and concerned others requires increased post-service times.

  • Practice expenses (RVUpe), including non-physician costs but excluding medical malpractice coverage premiums.

The practice expense component of the resource-based relative value scale (RBRVS) includes clinicalstaff time, medical supplies, and medical equipment.  Often, the costsof supplies and equipment are not proportional to practicesize.  Major factorsaffecting practice expense are the volume of telephone, cell, or Internet management services, and the case management and administrative work required. For example, high patient turnover requires more examination rooms to maintain physician efficiency. High volume requires moreclerical staff to deal with larger patient-flow volume and resulting phone calls, difficultiesdressing and undressing patients, and is marked by increasedcomplexity and time in collecting laboratory specimens.  Thesefactors must be accounted for in any resource-based practiceexpense study and in the resulting practice expense calculationsfor medical services; and

  • Malpractice (RVUm) representing the cost of liability insurance.

The RBRVS system assigns RVUs to cover the malpractice expensesincurred by physicians. These malpractice RVUs, originally calculatedfor office-based physicians, may systematically undervaluethe practice liability costs for some specialties. The prolonged statutes of limitation on some legalactions may result in increased malpracticerisk exposure for physicians providing such services [i.e., pediatricians]. The differences in exposure may not be calculated in theRBRVS system, and were not included in initial studies.  Specialty specific survey data for malpractice expenseshould be used for this component when assigning final RVU valuations.  Without specialty-specific CPT® codes, however, there was no wayto do this objectively.

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Become a Whistle Blower in the Healthcare Industrial Complex

Have You Ever Worked in the Medical Profession?

By Ann Miller; RN, MHA

[Executive-Director]

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If you ever worked for a private medical practice, health insurance company, third party administrator or payer, hospital, public health clinic, VA or anywhere else in the healthcare space, we’d like to hear from you.

Tell the Medical Executive-Post about your work conditions, doctors or nurses, management shenanigans, or the politics and your observations of what is happening at your healthcare organization. Gossip, insider information, knowledge, personal opinion, insight or related hearsay – both positive and negative – is sought.

The clinical, financial, legal, insurance, pharma or administrative scenes are all fertile grounds for exposure and transparency. You may remain an anonymous tipster, or we will publish your identity upon request for additional credibility.

Please email MarcinkoAdvisors@msn.com or call us at: 770.448.0769

Please contact us today: MarcinkoAdvisors@msn.com

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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.

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Brian Kelly [KMOX News-Radio] Interviews Dr. Marcinko on Hospital Merger

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Forest Park – St. Alexius Hospital Merger Contentious

By Hope R. Hetico; RN, MHA

[Managing Editor]

Our own Dr. David E. Marcinko was interviewed on February 10th 2010, at 8:45 pm EST, by Brian Kelly of KMOX News Radio, in St. Louis MO.

As most of us were saying good-night, Dave was discussing a recently announced local hospital closure, with associated hospital merger.

Link: http://www.kmox.com/Brian-Kelly/5386938

The Closure-Merger

According to media sources, hundreds of people lost their jobs at a St. Louis hospital in existence for more than a century. And, up to 300 people who worked at Forest Park Hospital were notified of termination this spring. Success Healthcare, of Boca Raton Florida, the company that owns Forest Park Hospital also owns St. Alexius Hospital in South City.

Link: http://www.successhealthcare.com

St. Alexius will take over some of Forest Park’s services, following the merger expected to take effect April 11, 2010.

Video Link: http://www.fox2now.com/news/ktvi-forest-park-st-alexius-hospital-merger-021010,0,4625691.story

Financial Cause and Effects

A major cause of closure was cited as lost-revenue sources, in the amount of $24 million, from various government payers for the next two years, along with an increase in uncompensated care losses.

Typically, such federal and state governmental payers include Medicare, Medicaid, Indian Health Services, the Prison Health System and related low-income child health care state services [SCHIPs]. Exact payer break-down or financial performance data was not released at the time of the interview.

Link: http://www.kmox.com/pages/6331817.php?contentType=4&contentId=5561698

Mergers and Acquisitions

According to Dr. Marcinko, any merger and acquisition situation has the possibility for business duality; success or failure.

The first thing to consider is the potential for redundant or complimentary services. Redundancy is usually a job killer in the short-term, while complimentary services may jump start job growth in the long-term.

Moreover, acute care as delivered in the ER and OR is usually a revenue-center, while other chronic-need hospital services may be cost-drivers.

Success or failure then, may very well depend on the extent such service-line integration and synergy has been considered by management; and if such projections ultimately prove accurate”.    

Hospitals and Recessionary Best Practices

A related interview with Dr. Marcinko:

Link: http://www.arkansasmedicalnews.com/best-practices-stimulus-can-help-hospitals-in-recession-cms-738

Assessment

Declines in hospital based diagnosis-related-group [DRG] payments, and CPT® code payments for providers via SGR projections, are affecting healthcare institutions and doctors nationally.

Link: https://healthcarefinancials.wordpress.com/2009/09/17/understanding-the-medicare-prospective-payment-system/

Link: https://healthcarefinancials.wordpress.com/2009/03/27/obama-on-the-sgr-physician-payment-formula/

Why are many hospitals financially struggling today and how will healthcare reform affect the situation; good or bad? What about the growing and aging population, and advances in IT and genomics; all considered cost drivers.

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On the Elimination of Medicare Consultation Codes

Is it Budget Neutral?

By Brian J. Knabe MD, CFP, CMP

http://www.CertifiedMedicalPlanner.org

The New Year 2010 has brought some changes in the Medicare Physicians Fee Schedule.  For many specialists, the most significant change is the elimination of consultation codes, 99241-99245 in the outpatient setting and 99251-99255 for inpatient care.  Physicians can still provide consultations and bill for these services – using codes for routine new or established patient visits (99201-99205 and 99211-99215).

Reported Revenue Neutrality

It has been reported that this change has been made in a revenue neutral manner.  Reimbursement for all E/M codes has been increased in order to make up for the removal of consultation codes.  The increase is approximately 6% in the outpatient setting and about 2% for inpatient codes.

Of Averages and Outliers 

The result of these changes might be revenue neutral overall, but the outlier effect on many specialties and individual physicians can be significant.  Specialists who obtain most of their income from procedures will see less of an effect on their income.  This includes dermatologists, surgeons, and gastroenterologists.  Less procedurally-oriented specialists, particularly those who rely upon Medicare as a primary payor, are seeing the most significant effect.  For example, neurologists and hematologists will likely see double-digit declines in revenue.

Private Payers 

While private payers have not yet adopted these changes, billing codes must be adjusted when filing a claim with a commercial insurer when Medicare is the secondary insurer.  If a consultation code is used in these instances, the primary payer will pay their portion of the bill, but Medicare will deny secondary coverage.  There is no indication yet that commercial insurers are dropping the consultation codes altogether, but if history is any indication, they will likely eventually follow the lead of Medicare.

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Assessment 

Physicians can take certain measures to decrease the impact of these changes on their revenue stream.  It is increasingly important to understand how the complexity of a patient visit affects the appropriate level to be billed.  Prolonged service codes are also available (99356 and 99357) to enable physicians to bill appropriately for more complex and time-consuming evaluations.

Conclusion

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Off Road Touring in Boston with Dr. Marcinko

How Doctors Get Paid

By Dr. David Edward Marcinko; MBA, CMP™

[Publisher-in-Chief]

Just before the Christmas Holidays, I flew up to Boston at the invitation of a pharmaceutical company to lead a managerial workshop entitled: “How Doctors Get Paid” [Treatment is only the beginning in the Changing Billing and Medical Reimbursement Climate].

Our goal was to inform drug representatives, and their regional managers, what value added information physician offices might expect from the pharmaceutical industry of the future.  

Topics of Discussion

The two hour interactive workshop included team projects, flip chart exercises, a mock role-playing session and the customary [hopefully energetic] ppt presentation. Other topics of discussion included:  

  • Health insurance payment evolution
  • Collapse of Medicare
  • Rise of managed care
  • Medical records documentation
  • ICD-9 and 10, HCPCS, DRGs and CPT® coding
  • ABNs, super-bills and HCFA 150 forms
  • Billing methodologies
  • Healthcare fraud, abuse and related policies
  • Capitation, HSAs, concierge medicine and RACs
  • Futuristic health 2.0 payment mechanisms, and more.

Assessment

Rest assured; these folks were a very knowledgeable and aggressive group; not like your father’s “detail men” of yore! They seek to … talk the talk, and walk the walk, of the Health 2.0 era.

Many thanks again to Helen, and Jon D, for the invite.

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A Doctor – Economist’s Solution for Health Reform

My Laundry Wish List for all US Healthcare Stakeholders

By Dr. David Edward Marcinko; MBA, CMP™

[Publisher-in-Chief]Fox News

As President Obama speaks, prods and cajoles, and Congress returns to session to begin work again on HR 3200-3400 or similar, I believe that for any healthcare reform effort to work successfully for the American people – not necessarily be adopted – we need to consider the following in no particular prioritized order:

  • Insurance portability uncoupled from patient employment
  • Health insurance regional exchanges with inter-state purchase competition
  • Doctor, drug, DME and hospital pricing and payment transparency for HSAs, and all of us
  • Modifying or eliminating AMA owned CPT Codes®; a huge money maker for them
  • Abandoning ala’ carte medicine for values-based outcomes
  • Reduce JCAHO influence; encourage competition from Norwegian Det Norske Veritas [DNV]
  • Reduce big-pharma influence thru-out the entire medical education, career and care pipeline
  • End DTC advertising from big-pharma
  • Promote wholesale drug purchase competition, MC bidding and generic drugs
  • Encourage evidence-based medicine, not expert-based medicine
  • Less pay for medical specialists with a  re-evaluation of the hospitalist concept
  • Advance the dying art of physical diagnosis, teach and embrace Paretto’s 80/20 rule for clinic issues
  • Reduce lab test, diagnostic imaging and testing
  • Encourage private 24/7/365 medical offices and clinics; and on-site and retail clinics
  • Abandon P4P, medical homes and disease management ideas
  • Give more economic skin-in-game to patients relative to health benchmarks
  • Concretize the “never-event” prohibitions and include a list of patient health responsibilities
  • More pay for primary care docs and internists
  • Adopt digital records and cloud computing for patients
  • Phase in true eHRs incrementally; and abandon CCHIT for open source SaaS
  • Promote Health 2.0 social media.
  • Augmented scope of practice, numbers and pay for NPs and DNPs, etc
  • Reduce pay for CRNAs and increase it for staff RNs
  • Develop step down triage and treatment units to reduce the number of full service ERs
  • Increase medical, osteopathic, dental, optometric and podiatric medical school classes
  • Increased practice scope for dentists, podiatrists and optometrists
  • Make some sort of catastrophic HI mandatory, much like auto insurance for all
  • End pre-existing conditon health insurance contract clauses
  • More choice  and end of life control for the terminally ill patient
  • Increase marketplace competition with fewer political and financial “externalities”.
  • Teach basic healthcare topics in school and encourage physical exercise
  • Health and insurance education should be, but is not, the “answer” for Americans
  • Protect borders and discourage undocumented illegals
  • Adopt medical malpractice tort reform
  • Make all stakeholders fiduciaries 
  • No public “option” unless you like food stamps, Section 8 housing, public transportation and schools
  • Budget deficit neutrality
  • Joe Wilson is both a bright guy – and a jerk
  • Slow down!

Assessment

Recently, while in the Baltimore/Washing area, I was asked by several reporters to opine on the healthcare debate; which I did so freely having never been known as the shy type. And, regular readers will note that many of these items have been used as posts or comments on this ME-P. Unfortunately, my “laundry list” interview was pre-empted by two local but boisterous town-hall meetings with respective passionate politicians. It was redacted no doubt, but never broadcast. Thus, I missed the potential for my “five minutes” of fame. C’est la vive!

Conclusion

There you have it; direct and straight forward. And so, your thoughts and comments on this Medical Executive-Post are appreciated. Feel free to review our top-left column, and top-right sidebar materials, links, URLs and related websites, too. Then, be sure to subscribe to the ME-P. It is fast, free and secure.

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Understanding Deviations in Medical Billing

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Appreciating Normative Comparisons

[By Patricia A. Trites; MPA, CHBC, CPC, CHCC, CHCO ]

tritesDeviation in medical billing can be detected through utilization data that insurance companies produce on all providers that submit a claim for payment of services.

Insurance companies track utilization through a variety of parameters, including CPT codes, ICD-9-CM, or number of referrals. Different programs utilize certain benchmarks to trigger a review.

Example

For example, a physician who sees patients in the office from 8:00 a.m. until 8:00 p.m., seven days a week and has the highest billing amounts in the region can be subjected to a review. This doctor’s activities would be scrutinized. The utilization review department would probably flag this doctor’s provider number and request more information on a sampling of his or her claims, based on the volume.

Utilization Review

Some utilization review activities may occur due to the type of services that a doctor may offer. For example, if a cardiologist should suddenly start billing for a large number of incision and drainages of abscesses, this might trigger a review, since that might not be a typical scope of service for this doctor in this locality. The same could be said for a pathologist, triggering a review due to the high volume of wound care or ulcer debridement.

Audit Trigger Thresholds Vary

Thresholds vary from locale to locale regarding what triggers an audit. There are consultants who have suggested querying the local carrier for provider specific information regarding utilization activity to compare against community performance. Some Carrier Advisory Committee (CAC) representatives have indicated that this may bring undesirable attention from the Medicare program and trigger an audit. Consult professional associations. and, if possible; local CAC representatives to obtain most current information in your area.

Conclusion

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Why Coding Professionals?

More on the NPI, the AAPC, Censorship and Quality Health Care

By Darrell K. Pruitt; DDS

pruittFor those who have been following me recently on Twitter (Proots), you know that unlike me, John Hamm has not yet been kicked off of DrBicuspid, and is awaiting a response from Dr. David J. Pettigrew – a dental coding expert with 14 years of experience as Chief Dental Officer for BCBS of New Jersey. I can only shadow the conversation because, as I said, I was kicked off.

Through John Hamm, I sent word to Dr. Pettigrew that he should just shut up and not enter into a discussion about the NPI number. Pettigrew told Johnhamm that I should come onto the DrBicuspid forum and say that in front of everyone. Of course, I am unable to do that because as shameful as it is to my family, I am still banned from posting anything on DrBicuspid.

For real-time developments concerning Dr. Pettigrew’s public defense of the NPI number, it would be better to follow that chunk of drama on Twitter or DrBicuspid. I’ve got other things cooking here. Can you smell it yet?

As you can see, sports fans, I have had Internet contact with a new class of fat, slow-moving healthcare IT stakeholders, and I haven’t been building long-term relationships fortified by good will – if you know what I mean. 14 years of employment at BCBS of New Jersey fails to impress me much.

American Academy of Professional Coders

Those who have studied alphanumeric science have a national organization called the American Academy of Professional Coders [AAPC] which represents business consultants in a growing healthcare niche. Most are employed by providers who are too busy actually performing healthcare to play games with insurance companies for the money owed them. Like SEO professionals who know gimmicks to increase a client’s page rank in relation to competitors, or perhaps a bolus of bad news from a special bastard, professional coders maximize providers’ profits by keeping on top of the ever-changing hoops involved in paying doctors almost all that is owed them following a shorter than average delay.

ICD-10 is Coming 

Learning coding is job security these days because in a few years the mandated ICD-10 codes will force even dental offices to hire IT staff, which also cuts down on the nation’s unemployment. I’ve taken a peek at the ICD-10, and it makes the ICD-9 look like simple algebra. I’d stick with well-trained coding professionals. They’ll cost more but you do want to approach making a profit, don’t you?

Of Censorship

I submitted the following stinker to be posted on the AAPC Website. To their credit, it was posted almost immediately. That could be a good sign … OOPS! Several minutes later it went back under moderation. I think someone is having problems with it. You’ll have to read it to understand why. It’s tricky to let go of, yet if it remains posted, it looks like a concession. Some poor slob in the AAPC is in a bad position. I hope you are enjoying this as much as I am.

-Darrell

“A recent change to Medicare policy made by the Centers for Medicare & Medicaid Services (CMS) helps ensure claims processing isn’t delayed when the only missing information on the CMS-1490S form is the provider or supplier’s National Provider Identifier (NPI).

CMS Transmittal 1747, Change Request 6434, issued May 22, notifies A/B Medicare Administrative Contractors (MAC) and carriers of editorial changes to Medicare policy in Pub. 100-04, Medicare Claims Processing Manual, chapter 1 regarding the monitoring of claims submission violations and the handling of incomplete or invalid claims.

In either case, as stated in the transmittal, “If the beneficiary furnishes all other information but fails to supply the provider or supplier’s NPI, the contractor shall not return the claim but rather look up the provider or supplier’s NPI using the NPI registry.”

http://www.aapc.com/news/index.php/2009/06/missing-npi-no-reason-to-deny-says-cms/

“How does an NPI number improve patient care?”

By D. Kellus Pruitt DDS – posted on AAPC Website, 6.4.09

Boxing Gloves I see that nobody from the American Academy of Professional Coders has yet attempted to answer my question. Some visitors to the AAPC Website who have followed the comments to the article “Missing NPI Won’t Delay Processing – CMS” (no byline) may think the lack of an answer is odd – that is if they happen to notice. The novice professional coder who still does not know much about HIPAA could easily assume that since the article itself is almost a week old, the lack of a response to my question is nothing more than the natural fading of interest. At some point, people logically move on to newer posts and other parts of their lives.

But I know a secret.

Based on nothing more than glaring silence from anonymous officials of AAPC, I know that my question of whether the NPI number improves care did not go unnoticed by a few knowledgeable and sharp individuals. They know enough not to touch a transparently trick question. The answer of course is:

The NPI number does nothing to improve patient care (Gasp!)

There’s more. Five years ago informatics experts (coders), promised that the ten digit identification number for providers will speed payments lightning fast. When is the last time you heard that fib? I cannot fault abundant optimism, AAPC, but by now you are surely aware that physicians have had to wait for a year or more for payment because of foul-ups at NPPES. Some have had to take out loans to pay the salaries of coding professionals and other new IT members of their staffs.

Improving Healthcare?

And as far as “improving” patient care? That would be worse than a fib. That would be called a harmful lie that upsets me in a very personal way. I know where it is documented that dental patients have been forced to leave dentists they preferred simply because one-third of the dentists in Texas do not have NPI numbers. BCBSTX requires that their clients only see dentists who have the numbers. Otherwise, the client has to pay their dental bill in full and BCBSTX isn’t even obligated to refund the employer the insurance premium. Yet BCBSTX sales reps tell these employers that their employees can see any Texas dentist they choose.

I’m sorry. Sometimes I ramble.

To keep it fair, I will ask if there is anyone who would like to point out the benefits of the NPI number. Your AAPC members and many others, including enthusiastic newbie coders, are interested in hearing from leaders of the organization. Many careers are built upon the complexities caused by digitalization and informatics. I don’t blame you for the complications. After all, you don’t make the rules – you just get along with them really well. It’s like our unavoidably complicated tax code and accountants. Accountants call themselves professionals. So why the hell shouldn’t you?

The Medical Executive-Post

Let me say that I am grateful that you believe enough in transparency that this comment remains posted. It wouldn’t surprise me if someone briefly considered deleting it until they discovered that it will be on the PennWell forum and probably on the Medical Executive-Post anyway. And of course, we can all see that you chose the honorable thing to do.

NPI Fallacy

The NPI fallacy reminds me of a scene in the Mike Judge movie “Idiocracy,” when a character 500 years in the future named Frito is asked why fields are fruitlessly irrigated with a politically-correct brand of green colored sports drink instead of water. Frito, who got his law degree from Costco, doesn’t even have to suffer minimal thought before he quickly repeats what he’s heard so many times, “’Cause it’s got ‘lectrolytes.”

Grnerod finds it incredible that I don’t have an NPI number. “How on earth are you billing and getting paid without an NPI?”

I told him (?) that I don’t work if I don’t get paid. Call me an old school radical.

Conclusion

And so, your thoughts and comments on this Medical Executive-Post are appreciated. What are your feelings on the NPI situation? Does it really improve health care, or not? Feel free to review our top-left column, and top-right sidebar materials, links, URLs and related websites, too. Then, be sure to subscribe to the ME-P. It is fast, free and secure.

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Negotiating Physician Fee Schedules

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Better Data for Improved Fixed Compensation

[By Christy Clodwick; MHA]

biz-book1It is known that most health plans operate with fixed fee schedules. While these fee schedules have little or nothing to do with RBRVS, and most are based on a percentage of what Medicare pays, the question is: “are they tied to levels that are more than 3 or 4 years old?”  Physicians who have no negotiating tools or a plan in place, and who question the methodology that the payers are using, are (too casual-left) with a ‘take it or leave it’ response from the health insurance provider.

Gathering the Data

A good solid foundation of data is necessary to negotiate better reimbursement rates successfully. The practice administrator or accountant (not 1 in 100 accountants can actually do this) should have this information readily available, especially if the office has an automated billing system.

Steps to Preparing a Fee Analysis

First and foremost, the medical management team in charge of this project will need to determine the most commonly used CPT® codes for the practice.  The bulk of primary care or family practice physician fees should be derived from the revenue of the office visit, hospital and preventive medicine codes. This in turn may limit the number of codes for the study. The frequency of each CPT code should be listed over a 12 month period.  If applicable, laboratory fees should also be included to see if there are fluctuating reimbursement schemes for these services. The codes on the list should account for at least 75% of the total practice charges.

Determining Top Payers and Reimbursement by Payer

It is known that Medicare and Medicaid use established fee schedules and do not negotiate, therefore the focus should be on the other major payers that make up the bulk of the reimbursement. In this process, make sure that the payers in the report are the practice’s top payers. The practice administrator will also need to determine the reimbursement for each code that is sent to the various payers’ list in the report. The administrator or team leader (the average GP has 3-4 employees, so I don’t think there would be a team leader, here). For this project we can use the Explanation of Benefits EOB that is received from each payer that has been selected for the report.  When including this data, make sure the allowed amount, not the paid amount, is referenced. After this information has been gathered, each payer’s reimbursement rate will need to be calculated as a percentage of Medicare’s reimbursement rate. Medicare’s current rates for any geographical area can be found through the “Medicare Physician Fee Schedule Look-up” tool at:

Link: https://questions.cms.hhs.gov/cgi-bin/cmshhs.cfg/php/enduser/std_alp.php?p_sid=1reSKuxj

This site also provides a reference to Relative Value Unit, (RVU) that Medicare assigns to each code.

RVU Conversion Factors

It is important for the practice administrator or manager to understand the RVU conversion factors and how they work, simply because most payers are in the beginning stages of using this method. To calculate a payment for service you multiply a particular CPT Code by the Medicare conversion factor for that code. For an example we will use the code 99214 – office visit. The Relative Value Unit for that Code is 2.2. The Medicare conversion factor for the same code is $37.34.  The calculation would result in a rate of $82.15.  Geographical adjustments must be taken into account when performing these calculations. The next step in this process would be to review the fees for each code listed in the report. Calculate each fee as a percentage of Medicare’s rates. You will find different statistics for each payer.

dhimc-book1

Apply the Rules and Process

Follow these basic rules when applying this new process:

First, if the charges are being reimbursed at 100%, the fee may be too low. At this point, raising the fee for that code would be acceptable (Usually not the case). Next, If several fees are in this category, the practice should just set all its fees to a percentage of Medicare reimbursement across the board, such as 125 percent (many managed care plans pay at less than MC, i.e., 80% MC). Finally, a tiered fee schedule would be applicable if the payers seem to pay more for certain procedures or diagnostic studies. That would set evaluation and management codes at 125 percent of Medicare reimbursement while charging 150 of Medicare reimbursement for other procedures and diagnostic tests.

Assessment

The medical practice administrator should make sure that, no matter which fee schedule is best suited for the practice, it is updated annually to prevent loss of any increases that may occur per payer.

Conclusion

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On Continuity of Medical Care and HIMSS

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Considering Pay-for-Retention [P-4-R]

By Darrell K Pruitt; DDSpruitt5

Here is the question on lots of minds these days; how can we change the way medical providers are paid so they are both incentivized and adequately compensated to provide consistent, high-quality, patient-centered medical homes?

My Novel Idea

Here is a solid, common sense idea; increase providers’ pay gradually according to how long the doctors retain patients – who are free to choose any doctor they wish.  Consistency is the mortar of a medical home [i.e., pay-4-retention]. 

An Ounce of Prevention 

If prevention, which predates eHRs by thousands of years, is more than just a modern buzzword, the nation can still shave much more expense from health care by promoting continual, personalized care for consumers than from digital health records alone – void of prevention incentives. Who in the audience still cannot understand that concept? Think of it this way. How do business leaders in the land of the free retain the best employees? They pay bonuses. Even waiters get tips to encourage interest in providing service consumers will return for. What do US physicians get?  Guaranteed cuts in their Medicaid payments over the next decade. Physicians no longer encourage their children to become doctors. Surprised? Scared? 

Consumers Should Rule 

In place of consumers ruling their healthcare in the US, well-positioned, giant stakeholders have persuaded lawmakers to offer physicians bonus money (that will later be taken away), not for curing patients, but for using digital records “in a meaningful manner.” It’s called “Mark and Michael Leavitts’ Clicking for Cash.”  Since the rules are made up along the way, they change like the weather. That is why the larger and more progressive medical facilities pay bonuses to retain their best “Coders” and other informatics specialists who keep up with the current Ingenix-styled games in order to maximize profits. It is my opinion that health care IT’s complexity works well with the economic stimulus plan to improve employment in the nation. Entrepreneurial stakeholders will continue to be movie-star popular right up until the complete collapse of Medicare.  Then they’ll be impossible to find www.HealthDictionarySeries.com

HIMSS 

Have you ever heard of HIMSS?

“The Healthcare Information and Management Systems Society (HIMSS) is the healthcare industry’s membership organization exclusively focused on providing leadership for the optimal use of healthcare information technology (IT) and management systems for the betterment of healthcare.”

– From the HIMSS Web site.

HIMSS Annual Meeting 

A week ago, HIMSS convened its annual convention in Chicago. The keynote speakers for the four day event were actor Dennis Quaid; followed by the Chairman and CEO of Kaiser Foundation Health Plan, George C. Halvorson; then the economist and former Chairman, Board of Governors of the Federal Reserve, Alan Greenspan, and finally; Jerry M. Linenger, MD, MSSM, MPH, PhD, Captain, Medical Corps, USN (Ret.), NASA Astronaut, and Space Analyst, NBC News. As one can tell, healthcare IT has lots of momentum. In fact, Dave Roberts, the HIMSS vice president for government relations confidently told Bob Brewin on NextGov.com

“The e-records initiative is an entitlement program like Social Security.” 

http://www.nextgov.com/nextgov/ng_20090406_1509.phpdhimc-book9

Another Entitlement Program – Entitlement for Whom

In Regina Herzlinger’s 2007 book “Who Killed Health Care?” the Harvard School of Business professor argues that entitled stakeholders, including a few ambitious members of HIMSS, are destroying health care in the name of reform. In the first half of her 260 page book, she spells out entrepreneurial malfeasance in simple well-annotated terms. In the last half, she describes why Consumer-Driven Health Care [CDHC] makes sense to her. Professor Herzlinger does not specifically mention the words “medical home” in her book, yet she emphasizes the importance of continuity of care. To promote continuity, she suggests that managed care insurance policies be extended to three years duration and longer.  Although she also does not mention dentistry, it is obvious to me that since chronic illnesses like diabetes are exacerbated by poor oral health, continuity of care in dentistry is of special importance.  It occasionally takes years to improve some patients’ oral health care. And sometimes we fail.

Assessment 

If these assumptions about continuity of care are accurate, it follows that the physical and economic health of the nation depends on long-term medical insurance contracts with employers and freedom-of-choice in providers. So is prevention worth holding ourselves accountable to consumers for once? Maybe it is just me, but I think unprecedented truth in healthcare will soon emerge regardless of stakeholders’ needs for confusion and obscurity.  It is called consumerism.  And it goes hand-in-hand with the Hippocratic Oath, the free-market and common sense.

Conclusion

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More about Healthcare Organizations [Financial Management Strategies]

Our Print-Journal Preface

By Hope Rachel Hetico; RN, MHA, CMP™hetico1

As Managing Editor of a two volume – 1,200 pages – premium quarterly print journal, I am often asked about our Preface.

A Two-Volume Guide

As so, our hope is that Healthcare Organizations: [Financial Management Strategies] will shape the hospital management landscape by following three important principles.

What it is – How it works

1. First, we have assembled a world-class editorial advisory board and independent team of contributors and asked them to draw on their experience in economic thought leadership and managerial decision making in the healthcare industrial complex. Like many readers, each struggles mightily with the decreasing revenues, increasing costs, and high consumer expectations in today’s competitive healthcare marketplace. Yet, their practical experience and applied operating vision is a source of objective information, informed opinion, and crucial information for this manual and its quarterly updates.

2. Second, our writing style allows us to condense a great deal of information into each quarterly issue.  We integrate prose, applications and regulatory perspectives with real-world case models, as well as charts, tables, diagrams, sample contracts, and checklists.  The result is a comprehensive oeuvre of financial management and operation strategies, vital to all healthcare facility administrators, comptrollers, physician-executives, and consulting business advisors.

3. Third, as editors, we prefer engaged readers who demand compelling content. According to conventional wisdom, printed manuals like this one should be a relic of the past, from an era before instant messaging and high-speed connectivity. Our experience shows just the opposite.  Applied healthcare economics and management literature has grown exponentially in the past decade and the plethora of Internet information makes updates that sort through the clutter and provide strategic analysis all the more valuable. Oh, it should provide some personality and wit, too! Don’t forget, beneath the spreadsheets, profit and loss statements, and financial models are patients, colleagues and investors who depend on you.ho-journal9

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Assessment

Rest assured, Healthcare Organizations: [Financial Management Strategies] will become an important peer-reviewed vehicle for the advancement of working knowledge and the dissemination of research information and best practices in our field. In the years ahead, we trust these principles will enhance utility and add value to your subscription. Most importantly, we hope to increase your return on investment [ROI] in some small increment.

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Conclusion

And so, your thoughts and comments on this Medical Executive-Post, complimentary e-companion are appreciated. If you would like to contribute material or suggest topics for a future update, please contact me. Subscribers, have we attained our goals and objectives, as a work-in-progress in this preface statement?

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Defining Current Procedural Terminology [CPT®] Codes

What they are – How they work

By Staff Reportersdhimc-book

The American Medical Association’s Physicians’ Current Procedural Terminology® is contained in the CPT user guide. The maintenance of these codes is the responsibility of the American Medical Association with consultation from the AMA CPT Editorial Panel, Advisory Committee, and the AMA CPT Health Care Professionals Advisory Committee. Procedure codes in the CPT user guide are reviewed and revised annually. The Health Care Financing Administration’s – now CMS – Common Procedure Coding System [HCPCS] lists three levels:  

Level I National Codes

CPT codes are five-character, all numeric configurations (e.g., 99215). Contact the American Medical Association to obtain a current copy of the CPT® Users Manual.

Level II National Codes

The HCPCS Level II National codes are contained in the HCPCS user’s guide and are published in the Federal Register. The maintenance of these codes is the responsibility of the Health Care Financing Administration [CMS]. Procedure codes in the HCPCS user guide are reviewed and revised annually. HCPCS codes are five characters with one alpha and four numeric configurations (e.g., A0042). Contact any publishing company that provides medical coding reference books to obtain a current copy of the current HCPCS User Manual.

Level III Medicare Local Codes*

Historically, local Medicare carriers developed local procedure codes which were published in the local Medicare Newsletters. The maintenance of these codes was the responsibility of the local Medicare carrier. Medicare local procedure codes were all five-character configurations with the following alpha/numeric configuration: one alpha, (W, X, Y or Z) with four numeric configurations (e.g., Y5523); and two alphas, (W, X, Y or Z) same character with three numeric identifiers (e.g., XX001). Contact your local Medicare carriers to obtain their Medicare Newsletters.

* Note: Due to HIPAA (Health Insurance Portability and Accountability Act) requirements, Medicare Local codes and the Office of Medicare Assistance Program Unique [OMAPU] codes were replaced with national standard procedure codes. 

Assessment

For more terminology information, please refer to the Dictionary of Health Economics and Finance.

Conclusion

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Evaluate our 2-Volume Institutional Print Guide

Healthcare Organizations [Financial Management Strategies]

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Our 1,200 pages, 2-volume, quarterly institutional print guide Healthcare Organizations [Financial Management Strategies] is available on a 30-day, risk-free trial.

You may contact http://www.STPub.com at (604) 983-3434, fax (604) 983-3445, or e-mail at custinfo@stpub.com to place an order, or ask questions regarding pricing and/or availability.

All shipments arrive within 5 to 10 days. Prepayment is required for all international shipments and a small courier charge will be added to the subscription price.

After hours, we suggest you review the STP website FAQs section for answer to your inquiry: www.stpub.com/pubs/custinfo.htm

Assessment

Rest assured, Healthcare Organizations: [Financial Management Strategies] will become an important peer-reviewed vehicle for the advancement of working knowledge and the dissemination of research information and best practices in our field. In the years ahead, we trust these principles will enhance utility and add value to your subscription. Most importantly, we hope to increase your return on investment [ROI] by some small increment.

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Note: The guide is sponsored by www.MedicalBusinessAdvisors.com with contributions from www.CertifiedMedicalPlanner.com and is edited by ME-P’s Dr. David E. Marcinko and Professor Hope R. Hetico; RN, MHA. Definitions and terms supplied by www.HealthDictionarySeries.com

Conclusion

And so, your thoughts and comments on this Medical Executive-Post are appreciated? Reviews from current journal-guide subscribers are encouraged and appreciated.

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Big Blue and UHG’s New Health Plan Model

Innovative Model -or- Just another Paradigm Shift

By Staff Reporters56372274

According to Reed Abelson, and David Kadlubowski of the electronic New York Times [NYT].com edition, on February 6, 2009, a new medical practice business plan and health care insurance reimbursement model could allow family physicians to practice medicine the way they used to practice. How so?

Exit UHG

The giant insurer UnitedHealth Group is testing a new model of health care that some policy experts say holds great promise, but has yet to prove itself. An earlier trial of the model by UnitedHealth, in Florida, never got off the ground because doctors refused to participate.

Enter IBM

This time however, the insurer is teaming up with seven doctors’ groups to make another attempt, in Arizona, at the prodding of one of the state’s big employers, and IBM. UnitedHealth will try giving doctors more authority and money than usual in return for closely monitoring their patients’ progress, even when patients go to specialists or require hospitalization.

Link: http://www.nytimes.com/2009/02/07/business/07medhome.html?_r=3&ref=health

Moving toward Value-Added Models and Episodes of Care

The insurer will also move away from paying doctors solely on the basis of how many services they provide via CPT® codes and will start rewarding them more for overall quality of patient care [value added and/or episodes of care model].

Link: https://healthcarefinancials.wordpress.com/2009/01/28/a-medical-payment-paradigm-shift

Assessment

One comment heard through the grapevine was “caveat and vendor emptor”; while another sarcastic observer wondered if this was the same “Useless Healthcare Group that we all despise?” And, who is to define the term “medical quality -or- value added care”?

Conclusion

And so, your thoughts and comments on this Medical Executive-Post are appreciated. Early-adopter insight and reports from Arizona participating practitioners is appreciated.

Speaker: If you need a moderator or speaker for an upcoming event, Dr. David E. Marcinko; MBA – Publisher-in-Chief of the Executive-Post – is available for seminar or speaking engagements. Contact: MarcinkoAdvisors@msn.com  or Bio: www.stpub.com/pubs/authors/MARCINKO.htm

Our Other Print Books and Related Information Sources:

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Healthcare Organizations: www.HealthcareFinancials.com

Health Administration Terms: www.HealthDictionarySeries.com

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Medical Coding Definitions

Understanding CPT® Methods

By Patricia Trites; PhD

www.HealthcareFinancials.com

The American Medical Association Physicians’ Current Procedural Terminology manual (commonly known as the CPT® manual) is the recognized coding manual used by healthcare providers to bill third party payers.

CPT Codes

No quantitative values are assigned the CPT® codes contained within the CPT® manual.  Each third party payers determines a value, whether a direct dollar or unit value, for each CPT® code.  Each CPT® code represents a service, procedure, test, or study. 

The CPT® manual attempts to define each of the codes specifically by individual descriptive phrases, and generally utilizing guidelines, rules, and definitions related to code groupings: medical, surgical, pathological, and diagnostic services.  Third party payers develop for internal use additional protocols, guidelines, rules and definitions.

Assigned Values

The value assigned to each CPT® code is based on a determined amount of work, practice expense and risk inherently bundled into the service or procedure.  Each procedure or service is further defined as a body of work made up of multiple lesser components all valued within the main CPT® code. 

Case Example:

As an example, if the surgical lengthening of a leg tendon is the main procedure to performed, it would be assigned a unique CPT® code. Within the tendon lengthening code definition and assigned value would be included (bundled or “packaged”) seemingly obvious lesser procedures available to the surgeon in achieving the ultimate goal of the tendon lengthening. These lesser procedures include the incision itself, retraction of vital structures, tying off small vessels, suturing the tendon in a lengthened position, closing the soft tissue in layers, suturing the skin, application of a dressing, and application of a posterior splint. 

Modifications

While some surgeons in a particular case may not need to tie off small vessels because no vessels interfered with the surgical exposure, or maybe they had to tie off two more vessels than they usually have to do, or they may elect not to apply a posterior splint, or the procedure takes twenty minutes more because a required instrument falls on the floor and needs to be re-sterilized, the overall code value of the tendon lengthening procedure does not change. 

Essentially with the exception of minor modifications, one way or another, the main procedure remains essentially the same. Those minor modifications or variations in technique would be included in what would be called the global surgical description and allowance. Not all potential secondary or minor procedures need to be performed to fully reimburse the primary procedure.

Billing Fragmentation

The fragmentation, breakdown or unbundling of the main or primary procedure through the billing of each secondary procedure is billing abuse at best, intentional double billing at worse. Bundling is also addressed in the Correct Coding Initiative [CCI] issued by the Centers for Medicare and Medicaid Services [CMS]. This is a quarterly publication that lists the procedures and/or services that cannot be billed on the same day for the same patient.

Assessment

Healthcare providers intentionally billing unbundled services may be committing fraud or abuse.

Conclusion

Your thoughts and comments are appreciated.

Practice Management: http://www.springerpub.com/prod.aspx?prod_id=23759

Physician Financial Planning: http://www.jbpub.com/catalog/0763745790

Medical Risk Management: http://www.jbpub.com/catalog/9780763733421

Healthcare Organizations: www.HealthcareFinancials.com

Health Administration Terms: www.HealthDictionarySeries.com

Physician Advisors: www.CertifiedMedicalPlanner.com

Speaker: If you need a moderator or speaker for an upcoming event, Dr. David E. Marcinko; MBA – Publisher-in-Chief of the Executive-Post – is available for seminar or speaking engagements. Contact: MarcinkoAdvisors@msn.com  or Bio: www.stpub.com/pubs/authors/MARCINKO.htm

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