Thursday, March 4, 2010
March 2010
The Red Flags statute is scheduled to go into effect on June 1, 2010. On Tuesday, March 23 at 8:00 am (prior to office hours) CPB is sponsoring a program at our office in conjunction with MSNJ on implementing the Red Flags program. The program includes handouts that will put you about 90% of the way to compliance.
If you are interested in attending, please RSVP no later than noon on Monday, March 15th. A light breakfast will be provided.
SOFTWARE UPDATES
One of the concerns we are hearing recently is patients who forget their appointments. Our software vendor has just released an “Auto-Dialer” product that can be used with our appointment system to automatically call pts a day or 2 prior to their appt as a reminder.
They also released another new product called a “Digital Pen” which also is used with our appointment system. If you chose to use this product, CPB would cover the cost.
Both of these products would improve the efficiency of your office and cash flow (patients who show up create $$!). Please give Rich a call if you are interested.
HITECH ACT
As everyone knows from our email or other sources, the HITECH Act went into effect Wednesday February 17th. This information was also emailed to all CPB clients (if we had an email address).
While it covers a number of issues, the one that relates directly to billing is the ability of a patient to require you to “not to disclose an item or service paid for entirely out-of-pocket by an individual to a Health Plan for payment or health care operations purposes, unless such disclosure is required by law.” In other words, you cannot bill insurance for that service.
We do not expect this to occur very often, but a few things are important when it does.
· Your financial policy needs to be revised to clearly indicate that you will comply with their request but it requires payment on the date of service. Each pt needs to sign the new financial policy. If you have the CPB version, let me know and we’ll send the latest version to you.
· It may be helpful to add a sign to your office waiting room “Patients who do not want their insurance billed, the office requires notice prior to being seen and payment in full is required today.”
· Be sure to collect full payment that day and record it on the Charge form.
· On your Charge Form, it is critical that you clearly indicate in big, bold letters “Do Not Bill Insurance.” We will then enter the charge and patient payment, then remove the insurance so it does not get billed.
If there are any questions, please call me.
February 2010
PROVIDER MEDICAL RECORD SIGNATURES - UPDATE
Highmark Medicare has now agreed that “Electronically Signed” signatures are now acceptable.
Medicare 2010 eRx Program
The 2010 program has some small changes from the 2009 program making it easier to participate.
· Only 1 code is now used: G8553: “At least 1 Rx created during the encounter was generated and transmitted electronically using the eRx system.”
· Only 25 or more unique visits (reporting the code 25 times) are required, with a minimum of “10% of an eligible professional’s Medicare Part B charges”. The codes counted include all of the office visit codes (99201-99215), plus Home, Rest Home, and Nursing Home visits.
· Still requires a “qualified electronic prescribing (eRx) system.”
· The G8553 MUST be submitted with the E&M code at the time it is billed for claims reporting. The G8553 cannot be sent at a later date and still count.
· Payment will be 2% of “allowed charges for professional services covered by Medicare Part B.” If you are also performing other testing in your office and billing globally (meaning both the technical & professional components), then we read this to mean that the 2% will not include the technical component portion of payments.
If you decide to participate, CPB (i.e., Rich) will need to know in advance so we can add the G8553 to your charge master and make sure the data entry staff are also aware. Clients for whom we maintain their charge form, we will add the code for you.
Please call with any questions.
2010 MEDICARE PHYSICAL, OCCUPATIONAL & SPEECH THERAPY CAP
The Therapy Cap for 2009 is $1,860 through December 31, 2010. However, as of January 28th, the Medicare Cap Exceptions process for independently practicing physical, speech and occupational therapists has not been extended beyond December 31, 2009. Our software is tracking each patient’s progress. Patients who near the Cap have the option of transferring their care to an outpatient hospital setting or signing an Advanced Beneficiary Notice and accepting responsibility for the balance.
Friday, January 22, 2010
January 2010
CMS and other insurers are VERY active with pro-payment and post-payment audits (CERT & RAC) and are carefully reviewing medical record documentation. One of the critical requirements that is checked on EVERY medical record is the presence of an acceptable provider signature. This type of denial is easy to avoid. In the December Highmark Medicare Report, page 3 (top) it states:
“Also, note that in keeping with standard auditing principles, items such as signatures, attestations, and other addendums which are added to the medical record after the date of the Additional Documentation Request (ADR) letter will generally not be considered as acceptable documentation. Furthermore, providers who exhibit a pattern of adding documentation after ADR requests could be subject to corrective action.
If you receive a request for medical records from the CERT contractor or Highmark Medicare Services, it is critical that the signed physician order for all diagnostic tests be included. Without the order, the services could be determined to be medically unnecessary and the claim will be denied.”
We have also been told by Highmark Medicare that “Electronically Signed” signatures are not acceptable – each document/note/order must have a handwritten signature.
Thus, before sending any documentation to Medicare or any other insurer, it is critical that all providers, physician and non-physician, are sure their signature is on EVERY document/note/order and that it be recognizable as their signature. CPB will be glad to review all documents for completeness prior to sending them to an insurer. See the separate article from the Highmark Medicare Medical Director in your MCO packet.
DEFINITION OF “NEW PATIENT”
We occasionally are asked what constitutes a new patient. The definition of a new patient is found on the first page of the narrative instructions at the beginning of the E/M section of your CPT manual where it states: "...A new patient is one who has not received any professional services from the physician, or another physician of the same specialty who belongs to the same group practice, within the past 3 years."
As you can see, the billing tax ID, change in office location, joining another practice, whether you need to set up a chart or not (maybe the first with the patient was in the hospital setting).....none of those things make any difference for determining new vs established. The only criterion is whether you've seen the patient in the past 3 years (36 months) or whether anyone else of your specialty in the same practice you're with at the time of the appointment has seen the patient within the past 3 years.
Though it isn’t necessarily a "federal guideline," the Medicare program does follow it. And, since it's part of the CPT definition of the service, it's applicable to all payers (including self pay) unless the payer tells you in writing they have an alternate definition for "new patient."
2010 PART B DEDUCTIBLE
The Centers for Medicare & Medicaid Services (CMS) announced the Part B annual deductible for 2010 is $155.00 (it was $135 in 2008 & 2009). With the poor economy, it is more important than ever to make every effort to collect all co-pays, deductibles (if known), and co-insurances on the date of service. The key is getting the payment before they receive your services, or at worst, before they leave your office.
2010 MEDICARE PHYSICAL, OCCUPATIONAL & SPEECH THERAPY CAP
The Therapy Cap for 2009 is $1,860 through December 31, 2010. However, as of December 28th, the Medicare Cap Exceptions process for independently practicing physical, speech and occupational therapists has not been extended by Congress beyond December 31, 2009. Patients who near the Cap have the option of transferring their care to an outpatient hospital setting or signing an Advanced Beneficiary Notice.
Medicare PROVIDER Participation Status – DATE CHANGE
As you are probably aware the current Medicare Fee Schedule is set to decrease by 21% unless Congress acts to change it. One option that providers have is to change from participating to non-participating status. If you wish to consider becoming non-par due to the potential fee decrease and, for physician, the elimination of consults, it can be done until 3/17/10. Call me if you want to discuss financial ramifications. Non-par status offers about a 9-10% increase in what patients can be charged compared to the par fee schedule. There are some significant caveats to consider, including the need for patients to pay on the date of service (please call Rich to discuss), and patients will need to be notified ASAP.