Wednesday, August 10, 2011

August 2011

Medicare Annual wellness visits and ekg’s

Medicare does not have a separate CPT code to bill an EKG on the same day as a Medicare Annual Wellness Visit (G0438 & G0439) like they do for an IPPE (G0402). Thus, to bill an EKG with either a G0438 or G0439 you will need one of the “normal” diagnosis indications.

GOOD OFFICE FINANCIAL POLICIES

By 2010, more than 54 percent of large employers offered their employees at least one high-deductible health plan, according to a Rand Corporation survey (http://www.rand.org/pubs/external_publications/EP20110086.html).

Patients are responsible for increasingly larger portions of their medical bills – in fact patients’ financial responsibility is the largest it’s been since medical insurance came onto the scene in the mid-20th Century. Copayments, coinsurance and deductibles have never been higher. We have seen deductibles now as high as $5,000 per year! If you are relying solely on your billing staff to respond to this trend, you won’t be successful. Your patients are your worst payers – and asking them for money long after the fact only results in higher postage costs and accounts receivable. Requiring your front office to perform date-of-service collections is essential for financial success.

Here are seven (7) steps to successfully dealing with today’s reimbursement environment.
Check eligibility 1-2 days before the patient’s appointment. This allows you to confirm the patient is covered, who the insured is, amount of co-pay, deductible, and/or coinsurance. Critical information if you want to be paid. It also spells the difference between charity care and bad debt!
Set expectations. Develop a financial policy to distribute to patients when they arrive & make it available on your website, if you have one. Hang tasteful but clear signage in the front office. Don’t beat around the bush by printing signs that say, “Our Practice Expects You to Pay Your Copayment.” Instead, be direct with signs that read, “Your Insurance Company Requires You to Pay Your Copayment.” Send the message professionally, but make it clear that you expect to receive payment at the time of service. If the patient owes a co-pay, ask for payment prior to seeing the provider, not after.
Know how to ask. There is an art to collections, and a large part is knowing how to ask for money. Instruct your staff to stop asking patients, “Would you like to pay?” Replace that request with “How would you like to pay today?” Be sure to ask for past open patient balances at the same time. As they ask for payment, staff must make eye contact with the patient (or guarantor) and use his/her name during the conversation. Print a statement for all patients at check out that reflects any payments they have made as well as any remaining balance due. Giving these statements to patients at check-out is essentially free (no postage), and it reinforces your expectations of getting paid. It also eliminates the excuse patients so often give to your business office: “I never received a statement.”
Accept all forms of payment. Allow patients to pay by cash, debit or credit card. Personal checks could be an option, but consider using a check verification service if you encounter bad checks. Look at the commission rates on credit card services to make sure you get the best deal possible from card merchants. Don’t hesitate to steer your patients to a particular form of payment. For example, you might get a better rate when patients use debit cards for amounts under $20, but a more favorable rate when patients use credit cards for amounts over $20. Of course, you should not hesitate to accept any form of payment, but it doesn’t hurt to request a particular type of payment depending on which is more advantageous to you. Most patients won’t care one way or another because it is you, not they, who gets charged the commission going to the card processing company.
Consider pre-authorized credit cards. Pre-authorized cards allow you to accept pre-payments via credit card without encountering the hassle and danger of storing the patient’s credit card information. These systems capture and store credit card information for you to use later when the claim has been adjudicated. These systems also allow you to set up payment plans securely and seamlessly.
Determine what to ask for. If you have a contract with an insurance company, review it to determine whether you can request the payment of the coinsurance and unmet deductible at the time of service. Despite the well-entrenched urban myth that circulates in the medical practice industry, most insurers do allow you to collect the patient’s copayment, coinsurance and unmet deductible at the time of service. Once you’ve identified any exceptions, ask the patient for these payments prior to seeing the provider. For coinsurance and unmet deductibles, you’ll need to know what services the patient is receiving (because allowances are based on CPT® codes). Thus, you’ll need to perform this collection activity as patients check out of your practice. Some insurers offer a web-based look-up tool to locate the correct rate. Develop a spreadsheet that lists your top CPT® codes and the corresponding allowances for each code by each of your major payers for your check-out staff to look up the codes on this spreadsheet.
Collect a deposit from the uninsured. For patients who do not carry insurance, request a minimum deposit. Set the “deposit” as your full charge, a reduced flat rate, or an average of the copayment that would be expected of your commercially insured patients. You may choose to collect different deposit amounts from new patients versus established patients (typically, deposits required of new patients are higher because there is no relationship or history with your practice), but be consistent within the categories. For patients who can’t afford to pay, offer a financial hardship policy that grants discounts based on the level of hardship. The key to making this work is to take a consistent approach to charging deposits – and have a written hardship policy that you follow consistently.
These days, more insured patients owe higher deductibles, copayments and coinsurance amounts. You can no longer afford to let these patients walk out the door of your practice without paying. Administrative costs and low collection rates make after-the-fact collections a losing proposition for most medical practices. Update your practice’s operations and financial policies and look for other ways to improve the revenue cycle in your practice so that you collect 100 percent of patient time-of-service payments due every day.

August 1, 2011

Workwell

WorkWell is a third-party workman’s comp physical therapy administrator who started in Pennsylvania in 1982 and is now entering the NJ market for some large employers. Each of you has signed their agreement.

CPB was able to negotiate more favorable terms than originally proposed:
$75 per diem (was $70) based on providing at least 4 modalities.
Payment to be made in 45 days (was 60).
If they change your fees, you can opt out immediately (previously no provision).

Billing:
When the patient is scheduled they will provide the patient’s Social Security # as their policy #. Please be sure to forward that to CPB.
Billing needs to be at weekly. More often is better, of course.
All claims require a copy of their “Physical Therapy Notes” form be attached to the claim. WorkWell requires the PT notes have times clearly documented along with the procedures done that day.
We have also negotiated a way to submit these electronically to get the payment clock running sooner.

CLIENT BULLETIN PRIMARY CARE SUPPLEMENT
August 1, 2011

Medicare Preventive Services

In the June 1, 2011 edition of the Highmark Medicare Services “Medicare Report,” page 5,
( https://www.highmarkmedicareservices.com/bulletins/partb/med-reports/pdf/mr0611.pdf )

Medicare specifies what is included in both an Initial and Subsequent AWV. Please note that providing “smoking cessation” counseling (G0436 & G0437) is included with at least the G0438 and will be denied when billed together.

What is Included in an Initial AWV with PPPS (G0438)?
The initial AWV providing PPPS provides for the following services to an eligible beneficiary by a health professional:
• Establishment of an individual’s medical/family history.
• Establishment of a list of current providers and suppliers that are regularly involved in providing medical care to the individual.
• Measurement of an individual’s height, weight, BMI (or waist circumference, if appropriate), BP, and other routine measurements as deemed appropriate, based on the beneficiary’s medical/family history.
• Detection of any cognitive impairment that the individual may have as defined in this section.
• Review of the individual’s potential (risk factors) for depression, including current or past experiences with depression or other mood disorders, based on the use of an appropriate screening instrument for persons without a current diagnosis of depression, which the health professional may select from various available standardized screening tests designed for this purpose and recognized by national medical professional organizations.
• Review of the individual’s functional ability and level of safety based on direct observation, or the use of appropriate screening questions or a screening questionnaire, which the health professional may select from various available screening questions or standardized questionnaires designed for this purpose and recognized by national professional medical organizations.
• Establishment of a written screening schedule for the individual, such as a checklist for the next 5 to 10 years, as appropriate, based on recommendations of the United States Preventive Services Task Force (USPSTF) and the Advisory Committee on Immunization Practices (ACIP), as well as the individual’s health status, screening history, and age-appropriate preventive services covered by Medicare.
• Establishment of a list of risk factors and conditions for which primary, secondary, or tertiary interventions are recommended or are underway for the individual, including any mental health conditions or any such risk factors or conditions that have been identified through an IPPE, and a list of treatment options and their associated risks and benefits.
• Furnishing of personalized health advice to the individual and a referral, as appropriate, to health education or preventive counseling services or programs aimed at reducing identified risk factors and improving self-management, or community-based lifestyle interventions to reduce health risks and promote self-management and wellness, including weight loss, physical activity, smoking cessation, fall prevention, and nutrition.
• Any other element(s) determined appropriate by the Secretary of Health and Human Services through the National Coverage Determination (NCD) process.


What would be Included in a Subsequent AWV/PPPS (G0439)?
In subsequent AWVs, the following services would be provided to an eligible beneficiary by a health professional:
• An update of the individual’s medical/family history.
• An update of the list of current providers and suppliers that are regularly involved in providing medical care to the individual, as that list was developed for the first AWV providing PPPS.
• Measurement of an individual’s weight (or waist circumference), BP, and other routine measurements as deemed appropriate, based on the individual’s medical/family history.
• Detection of any cognitive impairment that the individual may have as defined in this section.
• An update to the written screening schedule for the individual, as that schedule is defined in this section, that was developed at the first AWV providing PPPS.
• An update to the list of risk factors and conditions for which primary, secondary, or tertiary interventions are recommended or are under way for the individual, as that list was developed at the first AWV providing PPPS.
• Furnishing of personalized health advice to the individual and a referral, as appropriate, to health education or preventive counseling services or programs.
• Any other element(s) determined by the Secretary through the NCD process.

July 2011

Medicare routine services

Routine services such as a TB test are not covered by Medicare. In such cases, an Advanced Beneficiary Notice (ABN) is NOT required and payment can be collected on the date of service.

Medicare eRx & EHR Vendor Codes

Just a reminder, the eRx & EHR vendor codes for Medicare is required to be billed on the same claim as the E&M code it goes with. It cannot be billed later per Medicare rules. A few more points:
You cannot collect both the eRx program incentive and the EHR incentive.
You can be penalized under the eRx program and still receive the EHR incentive.
The only way to avoid the eRx penalty is to report the G8553 code a sufficient number of times within the time frame specified. Participating in the EHR program does NOT exempt you from this requirement.

Useful related websites:
Meaningful Use Attestation Calculator: http://www.cms.gov/apps/ehr
CMS Attestation Page: https://www.cms.gov/EHRIncentivePrograms/32_Attestation.asp#TopOfPage

Spring 2011 HHS OIG Semi-annual Report to Congress

This report was recently released and contained examples of hospitals, physicians, therapists, etc. who were found to have committed various types of healthcare fraud. Following are a few examples from the report:
· Pennsylvania—John Kristofic, a physician, was excluded for a minimum of 20 years based on his health care fraud conviction. Over a 5‐year period, Kristofic submitted false and fraudulent claims to Medicare, TRICARE, the Federal Employee Health Benefit (FEHB) program, and private insurers for treatment and services which were not rendered because Kristofic was not in the office or the patients were being treated by other physicians on the dates claimed. Kristofic was sentenced to 1 year and 1 day of incarceration and ordered to pay $1 million in restitution.”
· Florida—Orthopedic surgeon Steven J. Lancaster agreed to pay $101,000 to resolve his civil monetary penalty liability for allegedly soliciting kickbacks from a medical device manufacturer. The Government contends that Lancaster offered to leverage his product usage and ability to influence purchasing decisions through his position as Chief of Orthopedics at Baptist Medical Center Beaches Hospital in exchange for a personal services contract worth a guaranteed $40,000.

CMB’s Compliance Plan actively works to help prevent such issues for our clients when we become aware of any possible concerns.

Medicare EHR Incentive payments

In order to qualify for the full payment incentives of $44,000 over a 5-year period an EP's initial year of reporting must be 90 days in either 2011 or but no later than October 1, 2012.

The 90-day requirement is applicable in 2013 and beyond for the initial year of reporting; however the payment incentives are reduced after 2012. If an EP's initial reporting year is 2013 the EP may report on a 90-day period but s/he will only qualify for a maximum of $39,000 in payment incentives. If the initial reporting year is 2014, the payment incentives are reduced to $24,000. And in 2015 there are no more payment incentives and the payment penalties kick in at -1%.

Tricare

Beginning June 1, 2011 the Department of Defense (DoD) is removing Social Security Numbers from all ID cards and replacing them with a new DoD Identification number and a DoD Benefits number.
We have been informed by our clearinghouse that these newly assigned numbers, however, will not work for Claim submission or Eligibility so continue to use the insured’s Social Security Numbers as the Member ID. If you are presented with one of these new cards, request the Insured’s Social Security Number for Claim Submission and Eligibility.

Centers for Medicare & Medicaid Services (CMS) BAnking change

On 6/17/11 CMS announced it “has converted its banking contracts with JP Morgan and U.S. Bank to Federal Acquisition Regulation (FAR) contracts. These banks serve all the Medicare contractors. Accordingly, CMS has instructed the banks to close all bank accounts and letters of credit associated with the old configuration and contracts.

Normally, Medicare checks are valid for a 12-month period after the payment date on the check and then they are automatically stale-dated, at which point they become void. CMS needed to close some of the old bank accounts prior to the end of the 12-month period due to contractual requirements. Some checks drawn on these old bank accounts may be presented for payment within the next two to three months, but will be returned and annotated “account closed.” If providers encounter this situation, they may contact the Provider Contact Center and have the checks reissued under a new appropriate account number. If the provider receives a fee for the check being returned as unpaid please bring that to the attention of the Provider Contact Center and they will address that issue as well for the provider.”

CLIENT BULLETIN PRIMARY CARE SUPPLEMENT
July 1, 2011

Medicare Preventive Services

There is some confusion about billing the 3 Wellness visit codes. Neither code has a co-pay or deductible so is particularly helpful during the first 3 months of the year when all Medicare patients must meet their annual deductible.

Medicare has recently prepared 2 guides (a copy of each has been enclosed) to assist with:
· What is required for each code, and
· When they can be billed.

The Initial Preventive Physical Examination (IPPE)
“In addition to the new AWV, Medicare also provides coverage for the Initial Preventive Physical Examination (IPPE), commonly known as the "Welcome to Medicare" Visit (WMV). Medicare has provided coverage for this exam since 2005; it is provided as a one-time service to newly-enrolled beneficiaries. The IPPE is an introduction to Medicare and covered benefits, with a focus on health promotion and disease detection. The IPPE must be performed within the first 12 months after the beneficiary’s effective date of their Medicare Part B coverage. It contains a number of components that focus on prevention, including a complete medical/social/family history, a focused physical examination (i.e. body mass index, blood pressure, visual acuity), an assessment of functional ability, and counseling.”

The Annual Wellness Visit (AWV) – New for 2011
“Under the Affordable Care Act, Medicare beneficiaries may now receive coverage for an Annual Wellness Visit (AWV), which is a yearly office visit that focuses on preventive health. During the AWV, healthcare providers will review a patient’s history and risk factors for diseases, ensure that the patient’s medication list is up to date, and provide personalized health advice and counseling. The first AWV also allows the provider to establish a written personalized prevention plan. This new benefit will provide an ongoing focus on prevention that can be adapted as a beneficiary’s health needs change over time.”

Effective for dates of service on or after January 1, 2011, Medicare will pay for an AWV (G0438 or G0439) for a beneficiary who is no longer within 12 months after the effective date of his or her first Medicare Part B coverage and who has not received either an IPPE (G0402) or an AWV providing PPPS within the past 12 months.
Medicare pays for only one first AWV (G0438) per beneficiary per lifetime, and pays for one subsequent AWV (G0439) per year thereafter.

When you bill the IPPE (G0402) and perform an EKG, you can also bill a G0403 if you also do the interpretation and report. If you only do the tracing with someone else doing the interpretation and report, use G0404. If you are doing the interpretation and report for another provider, then you can bill G0405. Let Rich know if you need these codes added to your charge form.

Examples:
A patient comes to you during the first 12 months of their Medicare coverage (traditional Medicare, not Medicare Advantage) for a preventive visit. During the first 12 months you must use G0402 for the visit. If an EKG is also performed as noted above, you can bill G0403.
A patient comes to you beyond their 12 months of initial Medicare coverage for an Annual Wellness visit and who received an IPPE (G0402) visit during that time. As long as 12 months have passed since the IPPE, then you can bill the G0438.
A patient comes to you beyond their 12 months of initial Medicare coverage for an Annual Wellness visit and who did not receive an IPPE (G0402) visit during that time. The G0402 cannot be billed but as long as 12 months have passed since the IPPE, you can bill the G0438.
The subsequent Annual Wellness Visit code, G0439, can be billed 12 months after the G0438 was last billed. If you have a new patient be sure to ask whether he/she received previous IPPE or AWV services before attempting to bill

For all of the examples above, you can also treat a patient for non-preventive issues on the same date and bill the appropriate E&M code. “Medicare payment can be made for a significant, separately identifiable medically necessary E/M service (Current Procedural Terminology [CPT] codes 99201-99215) billed at the same visit as the AWV when billed with modifier -25. That portion of the visit must be medically necessary to treat the beneficiary’s illness or injury, or to improve the functioning of a malformed body member.”

Be sure that your office notes clearly show both services as separate and distinct from the other and meet all the requirements for each code billed. On the charge form, be sure to indicate which diagnoses are linked to each code.

One last suggestion. We have had a number of patients who have called to ask about the Wellness charges. Medicare, as do most other insurers, has historically focused on illness and injury rather than prevention and wellness. It will help patients understand both the additional service you provided, as well as their billing, if you take a moment to explain the value of the wellness service to their health and longevity.

If you develop a severe case of insomnia and enjoy reading as “therapy,” here is the link to download the entire 298 pages of the Medicare Guide to Preventive Services:
http://www.cms.gov/MLNProducts/downloads/mps_guide_web-061305.pdf