Blog and Helpful Articles

The “Welcome to Medicare” Visit

When your patients reach the age of 65, they have a decision to make: sign up for Medicare Part B, enroll in an HMO, PPO, EPO or pick another type of insurance.  At age 65, patients may be  automatically enrolled in Medicare Part A – with no sign-up required – which covers hospital, skilled nursing facility, hospice and some home health services.  Medicare Part B, which covers physician and outpatient services, is voluntary and requires enrollment.  Read more about Medicare coverage here.

If your patients choose to go on Medicare, they will be eligible to receive many different types of medical services and screenings; these are payable services for your practice, as well, and beneficial to the provider.  These services are intended to promote health, prevention and detect early diseases. Most of the services do not require coinsurance and/or meeting the deductible waived and are available on the day the beneficiary’s Medicare Part B is effective; a few services, though, may only be covered if the patient is “high risk” or meets specific requirements.

Below are services for which your Medicare Part B beneficiaries are eligible, and which make your practice eligible for payment, too.

The first service we’ll review is the Initial Preventive Physical Exam (IPPE), which is commonly referred to as the “Welcome to Medicare” exam. Keep in mind that a beneficiary is only eligible for this service (CPT code G0402*) within the first 12 months of the Part B effective date and that it is covered only once per lifetime.   This visit can be performed by a physician (MD or DO), physician assistant, nurse practitioner or certified clinical nurse specialist.

Here are the required components of the IPPE. (click here for a detailed description of each):

  1. Patient’s medical and social history (including opioid use)
  2. Patient’s potential risk factor for depression
  3. Patient’s functional ability and safety level
  4. Exam
  5. End-of-life planning
  6. Educate, counsel, refer based on results of review and evaluation
  7. Education, counseling, and referral for other preventive services including a brief written plan/checklist

    *If an EKG with interpretation is done and documented at this visit, you can bill CPT code G0403, which includes the EKG and makes it unnecessary to report CPT 93000.

Another important service for Medicare beneficiaries is the Annual Wellness Visit, or AWV. Read more here.  Two CPT codes are important for the AWV:

  • G0438 for the initial, once per lifetime AWV
  • G0439 for subsequent AWVs, one visit every 366 days.  If you bill this code before the 366th day since the last AWV, the service will be denied.

During an IPPE or AWV, payment is also allowed (and billable) for an E/M Service (Evaluation and Management) when medically necessary and clinically appropriate. So, for example, if the beneficiary has a medical complaint, there is no need to schedule a separate visit or abandon the IPPE or AWV.  The provider must document the visit complaint and associated actions, and can bill the E/M level appropriate for that part of the visit. The biller will append a modifier to assure proper payment.

CMS covers many different preventive services for Medicare beneficiaries, such as alcohol misuse screening and counseling. You can learn more about these by reading our individual blogs in Coding & Billing category (titled “Did you know…”) or watching our YouTube video on this topic.

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CMS Urges Providers to Consider CPT 99483

In an recent blog, we explained a relatively new CMS service: the Cognitive Assessment and Care Plan Services​ (CPT 99483).  As explained, this code can be reported for a specific visit where the provider conducts a cognitive assessment to more thoroughly evaluate cognitive function and help with care planning for patients with cognitive impairment. 

The assessment, which is typically a 50-minute, face-to-face visit, includes a detailed history and patient exam, resulting in a written care plan to address neuropsychiatric symptoms, functional limitations and referral to community resources as needed.

Payment for this service in Florida, according to the Medicare Physician Fee Schedule, is:

  • $290.28 for providers in Locality 03
  • $300.09 for providers in Locality 04
  • $277.81 for providers in Locality 99

As important as the payment is the focus on helping the beneficiary by crafting a plan designed to deepen the dialogue concerning dementia and the services needed to keep the individual safe and in the home.   Effective January 1, 2021, this service is permanently covered via telehealth.

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How long does it take to get licensed as a home care provider in Florida?

There are three general stages in the licensure process for home health agencies and nurse registries:

  1. Time prior to filing the application
  2. Period of time between filing the application the scheduling of the licensure survey, and
  3. Time between the survey and the issuance of the license.

Each stage has separate requirements and schedules.

The first stage is completely dependent on the applicant and how long it takes to gather the necessary information to accompany the application. Obtaining zoning verification for the office location is dependent on the local zoning authorities and may take follow-up by the applicant. Developing the Proof of Financial Ability to Operate may take additional time, for those unfamiliar with the process.

The second stage is controlled by Florida Statutes in that AHCA has “30 days after receipt [to] notify the applicant in writing of any apparent errors or omissions and request any additional information…” If there is a request for more information, in the form of an “Omissions Letter”, the applicant will have 21 days to provide that information or the application will be “withdrawn from further consideration” and the $2,000 filing fee is forfeited. After the response to the “Omissions Letter” there is no statutory deadline for AHCA to reply. Once the application is in order with AHCA, the applicant will receive confirmation of such and information that the local area AHCA office will contact the applicant to schedule a survey. There is no statute or rule providing a deadline for this to be accomplished.

The third stage begins as the surveyor exits the applicant’s office after the survey. The survey results are reviewed by AHCA and a determination is made as to whether any “regulatory violations exist, or all prior violations found have been determined by the Agency to be corrected.” When the determination that a satisfactory survey is made, the application is deemed “complete”, which invokes the 60-day deadline for issuing the license.

In conclusion, there are several statutory deadlines and administrative rules interpreting those statutes which result in an indefinite time to obtain a home care organizational license. Certainly, the accuracy of the application and the quality of the policies and procedures, coupled with the applicant’s performance during the survey will remove many days from the process and avoid delays in processing the application. Expert and seasoned guidance in this process can prove to be a valuable business decision.

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The Annual Wellness Visit

The American Academy of Family Physicians defines the Annual Wellness Visit (AWV) as an opportunity to gain information about a patient, including medical and family history, health risks, and specific vitals. Its purpose is to review the patient’s wellness and develop a personalized prevention plan, not to serve as a head-to-toe physical examination. 

AWVs must usually meet several criteria and the clinician’s documentation must support them.  Below is a description of some of the items Medicare requires providers to address during an AWV. For a complete list, click here.

  • Health risk assessment that includes evaluation of and appropriate referrals for assistance with:
    • psychosocial risks, which includes areas such as life satisfaction, loneliness/social isolation and pain;
    • behavioral risks related to tobacco use, physical activity, nutrition, alcohol consumption and others; 
    • activities of daily living (ADLs) like dressing, feeding, toileting and grooming, as well as instrumental ADLs, which encompass using the phone, housekeeping, managing medications, and handling finances; and
    • risk for depression, falls and safety.
  • Documentation of health measures, such as body mass index, blood pressure and other factors relevant to the patient’s health history.
  • Past medical and surgical history as well as the providers and suppliers involved in the patient’s medical care.
  • List of recommended health screenings for the next five to 10 years.
  • A discussion of advance care planning, which considers the patient’s preferences for future care decisions in the event of illness or injury, identification of caregivers and explanation of any advance directive.
  • Review of current opioid prescriptions, discussion of alternative non-opioid treatments and a screening for potential substance use disorders.

Payors also have guidelines regarding the timing of AWVs.  Medicare, for example, covers the AWV once every 366 days, while some commercial payors just require that it be performed annually.

AWVs are encouraged or required by virtually all payors, and result in higher payment than an office visit.  Some insurers incentivize providers and/or members to have AWVs and in the case of Medicare beneficiaries, AWVs are also important for attribution of ACO members. 

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Did you know…. Medicare Pays for Cognitive Assessment & Care Plan Services?

Experts predict that the number of men and women with Alzheimer’s disease will triple in the next 30 years, with about one new case every 68 seconds.  Dementia and Alzheimer’s disease affect the individual – and his/her entire family – in ways we can’t possibly summarize in this short blog.  You can read more here.

Fortunately, Medicare covers a specific visit for providers to make a thorough assessment of a beneficiary’s cognitive impairment and develop a care plan to ameliorate the decline and maintain the individual’s quality of life.  Conducting a basic cognitive assessment is a requirement for the Annual wellness Visit (AWV) but if the provider detects cognitive impairment, he or she may perform a more detailed assessment and develop a care plan.  The key is that the assessment and care plan must occur in another visit. 

The cognitive assessment includes a detailed history and exam, and must include input from an independent historian, such as a parent, spouse, guardian or other person who can provide a reliable history when the patient is not able to.  The assessment takes 50 minutes in a face-to-face or telehealth (for now) appointment with the patient and independent historian to:

  • Examine the patient and specifically observe cognition.  This should include the use of standardized tests to stage any dementia and screening instruments to evaluate for contributing neuropsychiatric and behavioral issues like depression and anxiety.
  • Review the patient’s history and chart records, in addition to reviewing high-risk medications
  • Conduct a functional assessment of activities of daily living (basic and instrumental), including the ability to make decisions.  An assessment should include questions about home safety and motor vehicle operation
  • Assess the existence of caregivers and other support, as well as their ability to provide the needed care.  This is also a good time to discuss advance care planning and any palliative needs.

The information collected by the clinician is synthesized into a care plan that should include plans to address symptoms of cognitive issues, functional limitations and referral for community or other services for the individual and the caregiver, as needed.

Request our FREE summary sheet on this important Medicare service.

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Florida Ends Emergency Order on Controlled Substance Prescriptions

An emergency order signed at the start of the pandemic temporarily suspended the requirement of a physical examination of an existing patient for the purpose of receiving a controlled substance prescription for chronic non-malignant pain. This order terminated on June 26, 2021.  On July 1, 2021, the Florida Department of Heath clarified that:

  • Qualified physicians are required to conduct an in-person physical examination to issue a physician certification for any patient [e.g., for medical marijuana purposes].
  • Controlled substance prescribers are required to conduct an in-person physical examination to issue a renewal prescription for a controlled substance.

These changes are immediate; there is no grace period or phase-in. 

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What We’re Reading – Steps HR Needs To Take Today To Beef Up Cybersecurity

A recent article in HR Executive contained some important reminders for businesses in the US, which holds the title of “Worst-affected Country in the World” when it comes to data breaches.   HR data and employee personal identifying information are “the sweetest prize” according to one data expert, who says that hackers employ a combination of smooth-talking and technology to access it.  

Of course, those of us in healthcare have long been protective of our patients’ data and we have the HIPAA policy manuals to prove it, but some of the author’s suggestions are still worth noting.

  • Build a partnership between IT and HR to reinforce cybersecurity among the workforce, because after all, it goes beyond patient information, encompassing protection of business structures as well.
  • Conduct at least one “robust” security assessment each year.  This is a HIPAA requirement, which in fact, should be an ongoing activity, scaled to your organization.  But do you know if it’s done on a regular basis and what the assessment results indicate?  This brings us back to the first tip which is to include HR in developing better learning opportunities to reach workers.
  • Maintain an internal forum where employees can stay informed about marketplace trends.  Similar to how we spread the word to friends about the suspicious-looking text from the bank that was really a hacking attempt, the idea is to build widespread awareness of the new scams out there. 

The author goes on to encourage regular password changes – groan, hiss – among other suggestions.  Suffice it to say, with so many ransomware attacks in the news these days, this is an area that may very well rise to the level of terrorism, as suggested in the article. 

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Non-Skilled Home Health Agency Quality Assurance Program

Unlike a skilled home health agency, and those skilled agencies which are Medicare certified, Florida non-skilled home health agencies are not specifically required by Florida Statutes or Rules to have and maintain a quality assurance program, (QAP), or any process for examining the consistency of compliance with statutes and rules. Even though there is lack of definition from the statutes or rules which AHCA can enforce in this regard for a non-skilled home health agency, that does not mean that these types of agencies should not have a well-crafted and vigorously implemented QAP. 

The Florida Administrative Code defines a quality assurance program as follows:

“Quality assurance plan” means a plan which is developed and implemented by a home health agency to review and evaluate the effectiveness and appropriateness of service provision to patients and, upon identification of problems, requires specific action to correct the problems and deficiencies.

Merriam-Webster defines “quality assurance” as:

“a program for the systematic monitoring and evaluation of the various aspects of a project, service, or facility to ensure that standards of quality are being met.”

A QAP should have two perspectives: the overall processes of the agency that tie to administrative rules and/or best practices set out in policy, and the detailed aspects of key processes.  The goal of a robust QAP is to minimize the potential for deficiencies that may result in fines, sanctions and potentially dangerous gaps in care.  Of course, no one is perfect and time constraints, training failures and just human error can cause lapses in process, but by means of the QAP, you can spot instances of deviation from the proper manner of work or errors, investigate the reason for the errors and correct the process or provide training on the correct manner of work. 

Some agencies believe the goal is to not show any errors, and they circumvent a valid review by correcting failures so the audits can show perfection.  This is not reality and surveyors – who have walked in the agency administrator’s shoes – will be suspicious.  The QA process, in actuality, shows that you’re watching the processes that are important, that you follow a plan when you find a deviation, and you are quick to correct behavior. 

Think of a QAP like homework in school: you have to do it every day and if you don’t, you will fall behind with a backlog of work to do AND you will fail the test because you are not prepared. In the next installments on this topic, we will focus on two major subjects of a QAP: personnel and patient care.

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OSHA COVID-19 Emergency Temporary Standard for Healthcare Industry Takes Effect

The Occupational Safety and Health Administration (OSHA) released new COVID-19 guidelines – called Emergency Temporary Standards (ETS) – for all healthcare providers and those who provide support services.  The new rules are binding on all employers unless they meet one of several exemptions.  For most of our clients, the applicable exemptions may include:  if you’re a “non-hospital ambulatory care setting where all non-employees are screened prior to entry and people with suspected or confirmed COVID-19 are not permitted to enter those settings” and  “home healthcare setting where all employees are fully vaccinated and all non-employees are screened prior to entry and people with suspected or confirmed COVID-19 are not present.” 

While most of our clients have a screening process, you may not have evidence of 100% vaccination among the staff and you may also have an obligation to treat patients with or suspected to have COVID, so the ETS apply to you.  Per OSHA, a fully vaccinated individual – someone who received the final dose of the COVID-19 vaccine more than two weeks prior – is exempt from masking and physical distancing requirements, but you need a mechanism to determine vaccine status (and document that).

Below is a summary of high-level points for your plan, which must be oriented toward minimizing risk of transmission.

Providers need a designated COVID-19 safety coordinator.  This is the person who will conduct hazard assessments and make sure all your org’s COVID processes are being carried out successfully.  In all likelihood, someone has been acting as your COVID-19 point person, so that may be whom you officially designate; the key is to put it in writing. 

Speaking of writing… you need a COVID plan.  Most providers have been following a series of processes for the past 15 months, but the point is you need to have those in written form. Remember that the plan needn’t to be fancy; just create a document that summarizes your operational changes thanks to COVID. 

Daily screening.  Your company needs to be able to limit and monitor points of entry, screen patients and visitors for symptoms and follow a process to relocate those individuals away from the rest of your patient population.  Employees also need to be screened, and if someone in the workplace is COVID-19 positive, you need to notify certain employees within 24 hours.  If you’ve relaxed some of your screening process, this is the time to bring it back in full-force and document if for posterity – and OSHA.

Personal protective equipment (PPE). You must supply facemasks to your employees and make sure they wear them when inside your premises.  Of course, there are exceptions, such as if an employee is alone in a room or is eating/drinking at least six feet away from others or behind a physical barrier.  If you provide or allow employees to wear respirators, you will need to provide instructions for use, specify when they are to be used, conduct a user-seal check and provide training.  Note that this item is binding on the employer if your employee wears this on his/her own, not just if you require it. 

Paid leave (if you have more than 10 employees).  Regardless of whether you require vaccination or not, you must provide employees with paid “reasonable time” to be vaccinated and/or if they experience any side effects from the vaccination.  The official wording says “benefits to which the employee is normally entitled,” and “must also pay the employee the same regular pay the employee would have received had the employee not been absent from work, up to $1,400 per week, until the employee meets the return to work criteria.”  By now, I bet you can spot things that need to be in your COVID plan… like return to work criteria.  This may require discussion with a medical practitioner, or review of CDC guidelines so you can stipulate how and when employees may return to work.

Aerosol-generating procedures.  Be sure to include in your plan that only the employees essential for patient support and to perform the procedure are allowed to be present during it, and cover your requirements and process for cleaning and disinfecting the surfaces and equipment used in the procedure.

Physical distancing.  Have you relaxed physical distancing requirements?  Again, this is the time to reinforce keeping at least six feet apart when indoors.  Remember that fully vaccinated employees (as described above) are exempt from this requirement.

Cleaning and disinfecting.  By now, we’re all familiar with CDC guidelines for cleaning and disinfecting surfaces and equipment in patient care areas, but the plan requires that high-touch surfaces and equipment also be cleaned once daily.  OSHA also requires that you make hand sanitizer that is at least 60% alcohol readily available in handwashing facilities.

The OSHA guidelines contain much more information, so be sure to familiarize yourself with them, but this gives you a starting point from which to write your plan.  Here‘s a more readable summary from the National Law Review. The ETS take effect on July 6, 2021.

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Hospital Worker “Weaponizes” PHI

Not a week goes by without some compliance-related enforcement action announcement in the news.  The Department of Justice recently announced that a now-former hospital worker pled guilty to wrongfully accessing and distributing her ex-boyfriend’s medical records.  The 41 year-old woman admitted to using her log in credentials to access her ex-boyfriend’s medical record even though she was not part of the medical team assigned to his care.  She then took a picture of a medical photograph in the chart and sent the photo to someone who sent it to the ex-boyfriend and others through a messenger app.  The message included “taunting language and emojis.”

The woman was sentenced to five years’ probation, fined $1,000 and restricted for five years from working in any organization where she would have access to others’ private medical info.

This is a striking scenario because of the sheer likelihood that it could occur in any healthcare org.  Every company that trains its employees on HIPAA stresses the relevant aspects of protected health information (PHI):  need to know, medically necessary limits, proper use & disclosure, but what type of restrictions do you have on access?  Does your org provide care to, and maintain the PHI of, its own employees or other VIPs (e.g., dignitaries, public figures, employee family members)? What protections exist to prevent the employee/patient or other staff members from viewing those records?

Whenever feasible, it’s best to limit access of a patient’s PHI to only those team members directly involved in his/her care.  And while all patients have the right to view their own medical records, they must follow the process established by the practice to do so; the same applies to the practice employee in his/her role as patient. 

Regular reinforcement of the company’s HIPAA policies, with a sprinkling of scenarios from the DOJ’s enforcement actions, is an absolute necessity – not just the annual, general HIPAA training most companies provide.  Speaking of which, how good is your practice’s monitoring of training completion?  Some companies’ policies have no “teeth” and six months or more can go by before anyone notices delinquent trainees. 

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