Acevedo Consulting Incorporated's Eye on Compliance Eye on Compliance is a quarterly newsletter prepared to inform our clients and friends about important topics and firm news. Volume 1, Issue 3 - September 2016 |
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CMS Introduces the Merit-Based Incentive Payment System: Here's Why It Is Not As Scary As It Sounds by: Katherine Becker, JD, LLM, CHC, CHPC, CPC Associate Consultant On April 27, 2016, a proposed rule was passed for the new Centers for Medicare and Medicaid Services (CMS) initiative called the Merit-Based Incentive Payment System (MIPS). This is the next step as CMS attempts to move away from fee-for-service payments towards quality-based payments. It might sound overwhelming to think that you will have to learn yet another quality program, but the good news is that the components of MIPS will actually look very familiar. You may have heard that PQRS and Meaningful Use are going away, but the truth is they are going away in name only. Rather than running multiple quality programs, CMS is trying to streamline their efforts under MIPS and allow providers to be scored on their overall performance in the quality initiatives rather than earning separate penalties under each program. MIPS will be comprised of four different categories, three of which will already exist – PQRS, Meaningful Use and the Value Based Payment Modifier. The first performance year for MIPS is 2017 and the first providers eligible to participate will be physicians, physician assistants, nurse practitioners, clinical nurse specialists and nurse anesthetists. Continue Reading |
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Responding to an Audit by: Jean Acevedo, LHRM, CPC, CHC, CENTC President and Senior Consultant Originally published in the Florida Society of Rheumatology Newsletter, June 2016 Have you noticed that everybody seems to be looking? Looking at your documentation, that is, to see if it supports the CPT codes you’ve billed. Over the last year there has been an increasing number of third party payer audits. Not just the “usual” Medicare audits either, but a number of Medicaid and managed care audits too. That Dubious Distinction of Being Chosen Most payers, whether Medicare or not, are looking at the data. And, comparing how your billing pattern compares with that of your peers. Do you have a higher number of a particular level of service than your peers? Is modifier -25 appended to a higher percentage of your Evaluation & Management Services than your peers? Is there something different about the number of units for administered drugs/biologics being billed? Are you now using ultrasound guidance for almost all injection procedures? You get the idea. Now, just because the data shows an aberrancy does not mean you’ve done anything wrong. That being said, being “different” can prompt a payer audit, so it’s important for all physicians, nonphysician practitioners and staff to understand the documentation requirements for the services provided in your practice. While you may not be able to prevent an audit from happening, a good understanding of payer requirements and solid documentation practices can indeed minimize the chance of a repayment of monies already received (and spent!). Continue Reading |
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Does Your Organization Run Exclusion Checks? If Not, You May Be At Risk You may not realize it, but if you were to unknowingly employ a biller, nurse, or anyone else who has been listed on the exclusion list you could face large fines. To minimize the risk of employing a sanctioned or excluded individual or entity, organizations are encouraged to follow the Office of General Inspector’s (OIG) guidance. The OIG requires that employees and/or vendors should be screened to ensure they have not been excluded from a Federal health care program. Organizations should ensure that individuals do not appear on the OIG List of Excluded Individuals (LEIE) or the U.S. General Services Administration (GSA) System for Award Management (SAM) prior to employment or engagement and annually thereafter. While the OIG does not require the individual or entity be checked more than annually (unless you have entered into a Corporate Integrity Agreement (CIA); however, they have recommended that in order for organizations to help prevent the liability of risk associated with the employment of an unlicensed or sanctioned individual that these checks are performed more frequently (i.e., quarterly, monthly, etc). In addition, when determining how far downstream one should conduct these screenings, the OIG recommends that organizations determine for each job category or contractual relationship whether the item or service provided is directly or indirectly, in whole or in part, payable by a Federal health care program. If the answer is yes, then that individual or entity should be verified. This includes volunteers, students and interns. The risks of employing such excluded individuals is hefty. This is evidenced by a recent settlement of $179,484 by a nursing home in the Mid-west whom employed a housekeeper and health information specialist who had been excluded. If you need assistance with this task the Acevedo team would be happy to assist you. |
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2017 ICD-10 Changes Released Effective October 1, 2016 The 2017 changes to ICD-10 have been announced with an effective date of October 1, 2016. With approximately 1,900 changes to ICD-10-CM alone, organizations are encouraged to review the new, revised, and deleted codes and/or guidelines that may have an affect on daily operations. The changes can be found here. Additionally, CMS announced on August 18 that beginning October 1, 2016,"CMS review contractors are able to use coding specificity as the reason for an audit for a denial of a reviewed claim to the same extent that they did prior to October 1, 2015". CMS went on to say that "The provider community should code claims to the degree of specificity supported by the encounter and the medical documentation". For more information, click here. The Office of Civil Rights Issued A New Rule On Discrimination… Making Most Organizations Out of Compliance. On May 13, 2016 the Office of Civil Rights issued a rule interpreting Section 1557 of the Affordable Care Act which addresses discrimination. The rule requires practices to have policies regarding limited-English speaking patients, disabled patients as well as discrimination regarding gender. Practices will also be required to have notices of non-discrimination posted in at least the top 15 non-English languages spoken in the state where the entity is located or does business. The new rule also requires that all staff are trained on non-discrimination policies. These new standards have many organizations scratching their heads on how to determine and subsequently address the need to post notices in 15 languages. Aside from that how will internal policies and training schedules need to be altered? All of this and more is being considered as the Acevedo Consulting team makes revisions to the compliance programs we create for clients to ensure they address these new standards. If you need help updating your current policies or need a new compliance plan, reach out to Acevedo Consulting to see how we can help. |
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Firm News: Please help us in congratulating Associate Consultant, Candice Fenildo, for recently becoming Certified in Health Care Compliance (CHC) through the Health Care Compliance Association (HCCA). Acevedo Consulting's "Medical Director Contract Review Checklist" was published in the December 2015 Update of HCCA's Health Care Auditing and Monitoring Tools. The California State University Institute for Palliative Care Educational Series Acevedo Consulting's Jean Acevedo partnered with Dr. Janet Bull to create a "Billing for Palliative Care Services" Educational Series. This series was designed to provide a comprehensive overview of opportunities to bill Medicare for the provision of community-based palliative care. For more information, click here. Acevedo Consulting Webinars: Physician Documentation and Coding for Hospice and Palliative Care: Complexity vs. Time September 27, 2016 12-1pm EDT Evaluation and Management Refresher; The Basics Reviewed October 11, 2016 12-1pm EDT Billing for Social Workers in Palliative Care November 8, 2016 12-1pm EDT Missed Opportunities: Medicare Preventive & Screening Services November 29, 2016 12-1pm EDT Register Here |
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Community Events Featuring Acevedo Consulting: HIPAA - How to Avoid Becoming a Worst-Case Scenario DannaGracey and Acevedo Consulting September 21, 2016 12:00-1:00 pm - webinar Care Coordination Training Program Palm Beach County Medical Society September 30, 2016 1:00-3:00 pm West Palm Beach, FL ICD-10 Documentation and Coding Tips for Rheumatology The National Organization of Rheumatology Managers & Crescendo Bioscience October 4, 2016 12:00-1:00 pm EDT - webinar October 6, 2016 12:00-1:00 pm CDT - webinar E&M Services: Understanding the Nuances Within Hospice Care The Carolina's Center October 7, 2016 2:00-3:30 pm - webinar Physician Reimbursement Opportunities South Carolina Medical Association October 14, 2016 - 8:00-3:00 pm - Columbia, SC Welcome to Medicare, Annual Wellness Visits and More AAPC Palm Beach Chapter October 15, 2016 - West Palm Beach, FL 2017 ICD-10 Update: Review of 2017 Changes and a Refresher on Frequently Missed Conventions. Broward County Medical Association October 25, 2016 - Fort Lauderdale, FL Network of Floriday Otolayngologists Annual Meeting - QRUR Presentation and Workshop
- Quality Metrics and The Impact on Payments
November 11-12, 2016 - Key Biscayne, FL |
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