Blog and Helpful Articles

“Removals” is not a bad word!

“You are leaving money on the table” is a common phrase Medicare Advantage providers hear from some auditors and even health plans regarding members’ risk scores. And that might be true. Some risk adjusted diagnoses may have fallen through the cracks even though the patient is being actively treated for all those unreported conditions. In this case, the patient’s risk score wouldn’t reflect an accurate picture of the financial impact of his or her health status on the medical practice.

After conducting countless audits through the years, CCG has found that even though some practices may under-report certain diagnoses, other conditions have been submitted in error due to lack of confirmation, insufficient documentation, and improper coding. A recent review involved 3,265 codes from two HCCs (18 Diabetes with chronic complications and 108 Vascular diseases), which were reported from 2016 to 2019; audit results revealed that only 19.7 % of the codes could be validated.  Therefore, a little more than 80% of the codes were retroactively removed and with them, the medical practice’s funding.

Some providers fear that removing erroneous or unsupported codes will subject them to extreme scrutiny. The truth is that not removing mistakenly reported diagnoses is not only financially, but legally, dangerous. Providers and Medicare Advantage plans have a legal responsibility to comply with CMS’s guidelines for reporting diagnoses. A recent example of the legal implications of a “one-sided” auditing process that only detects new diagnoses but doesn’t rectify erroneously reported conditions is the lawsuit against health insurance provider Anthem initiated by the Department of Justice (DOJ). To read about the DOJ’s lawsuit against Anthem, visit our previous blog here.

Removals are important because:

  • Providers have an ethical responsibility to maintain an accurate patient medical record.
  • The patient’s risk score must reflect only confirmed diagnoses for accurate reimbursement.
  • Failing to remove incorrectly reported diagnoses after having detected inconsistencies can be considered fraud.
  • Sending a removal report, when necessary, shows the provider’s intention to maintain an accurate risk score.
  • The practice compliance plan requires accurate coding.

The best ways to minimize removals are to have a strong MRA program and continuously educate providers on proper documentation practices. For more information on how to properly chart conditions and avoid having risk adjusted diagnoses removed due to insufficient documentation, you can read our reminders here.

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Business Opportunities in Times of Change

As of this writing, Florida’s unemployment rate is 10.4%, a decrease from May 2020.  The Florida Department of Economic Opportunity explained that the improved numbers show, “Floridians are searching for work and businesses are creating jobs.”  However, there is still a great degree of uncertainty as speculation grows about a second shutdown.  One thing is certain:  our nation has been rocked by the economic changes, massive layoffs and slowdowns, and what we thought were solid businesses are announcing partial and complete closures.

Perhaps you’ve thought or dreamt about opening a business as an alternative to leaving your fate in an employer’s hands.  Or maybe you’re in an industry greatly impacted by the pandemic and you’re weighing a change in direction in light of the question mark over our economy.  This is definitely a good time to consider a healthcare-related business.  A Deloitte study estimates that global healthcare spending will rise by five percent between 2019 and 2023. The growing aging population, prevalence of chronic conditions and other factors make home healthcare a good bet for the entrepreneurially minded.  Home Healthcare News recently reported that, because of COVID-19 concerns, more than half of family members are more likely to choose home care over institutional settings, and the trend is for greater hospital/SNF-to-home diversion models for long-term care.

Several types of home care business exist in Florida; your choice will depend on the services you want to provide, location/payor sources and available capital. This blog  briefly explains the nuances of different long-term care related businesses.

This economic climate may also provide right time to expand your agency or registry.  Are you receiving requests for services you cannot provide because of license restrictions?  Or do under-served areas offer opportunities to grow your business?  Consider opening an additional location or upgrading your license to include more services.

Call us today to explore your business options.

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What We’re Reading – Primary Care Remains Weakened in Fight Against COVID-19

All industries are being affected by COVID-19, from print companies and retail to hospitality and healthcare. We came across this article that shows that primary care, four months into this pandemic, continues to weaken based on a physician survey with respondents from 46 states and Puerto Rico.

The survey was completed between July 10th and July 13th and 564 clinicians specializing in family & internal medicine, pediatrics and geriatrics participated from settings and practices that varied in size. The study revealed that nine out of ten practices are having problems getting medical supplies they need, meeting patients’ growing health needs and even lack the funds to remain open. Only 13% of these practitioners say they are adjusting to this new way of life. The most shocking statistic is that less than four out of ten physicians feel confident and safe, with access to personal protective equipment (PPE), and 11% of staff have left over the last few weeks due to safety concerns. To read about all the results of the study, please refer back to the article.

Although the sample size was relatively small and may seem discouraging, there are some positives that have come out of this pandemic. The government has opened up Telehealth to include all Medicare Fee-for-Service (FFS) patients, not just those in rural areas, and other insurances have followed suit. Since the Department of Health & Human Services has extended the public health emergency until October 25, 2020, these continued telehealth visits will give providers and patients a way to stay safe but still be treated.

Your practice can promote these services while they are still covered – just remember to document that the patient gave consent for the telehealth visit on all progress notes, regardless of the insurance. Quick reminder: for your Medicare Advantage patients, the visit has to be “Audio and Video” to qualify.

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Succession Plans: Essential for the Small Business

Companies that involve their human resources department in their strategic plans will usually have a succession plan/strategy in place. This ensures that the business continues to function as seamlessly as possible in the event of a planned or unplanned departure of key employees in the organization. Although larger corporations usually have succession plans, at times they only focus on high level jobs, such as a CEO, and ignore the mid-level and other positions that are key to the successful operation of the company. A successful plan is not just for leadership and should be in place for all critical roles that an organization depends on, regardless of its size.

Smaller companies with less resources tend to work on a day-to-day basis and a “hope for the best” approach if and when a key player leaves the company.  An example is the IT person, who has all your server passwords, logons to all your accounts, etc. How would you handle an abrupt departure of that individual?

Understandably, it’s more of a struggle for small businesses to tackle this problem as individuals sometimes already juggle multiple roles. However, the lack of a succession plan can cripple your business when the unexpected happens. Businesses often find themselves making a desperate hire, who most likely is not a good fit, and this hire process could potentially start over and over again until you hit the “jackpot”.

Here are some simple ways to put a succession plan in place:

  • Ensure you have detailed job descriptions for all your roles. This is important as far too often we really don’t have a true picture of all the minute details that employees perform in their daily duties.
  • Identify the key and critical roles that will require succession planning.
  • Conduct employee skill assessments and explore the interests and aspirations of your employees. This will help you to identify areas of the company where you may be able to use their skills.
  • Identify individuals who would be good as a “next in line” for key positions, and create development plans for those persons. Involve the employee(s) in your development plans and make sure to stay on track and monitor the progress.
  • Consider initiating a robust cross-training action plan. This can help in two areas: 1. You may be able to transition a cross-trained employee into the open position, and 2. If you have a new hire and the individual they are replacing is already gone, it will give you the opportunity to offer efficient training and a good onboarding experience.

Keep in mind that while you are taking these great steps towards a good succession plan for your company, this is not a one-time document that you can lay to rest once completed. Instead the plan must be very fluid.  As new talent joins the company, strategic plans may change and you will constantly adjust your plan according the needs of the organization.

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You Might Be Owed Money for Telehealth Visits

Depending on when you accessed CMS’s telehealth billing guidelines, you may have submitted claims using a Place of Service (POS) of “02” regardless of where you rendered the service instead of POS 11 if in the office.  CMS recently announced that the POS 02 code applied a facility payment differential and lowered the payment of your claim.

Providers can now appeal the payment of any Medicare FFS claim for telehealth services, dated 3/1/20 or later, that used a POS 02.  The process for requesting the appeal is as follows:

This appeal must be requested in writing. Providers can request the appeal of a Part B claim through the following methods:

When requesting an appeal, you must specify the reasons you disagree with the initial determination.

  • When completing the fax form, indicate in the additional narrative “Revising billing related to COVID-19 telehealth claims”
  • When requesting via the redetermination function through the SPOT, indicate in the reason for the request “Revising billing related to COVID-19 telehealth claims” and be specific about what you want changed per detail line.

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ADA Changed Diagnostic Guidelines

From time to time, it’s important to revisit established diagnostic criteria for frequently encountered conditions because medicine evolves.  One such change occurred in the diagnostic guidelines for diabetes.  The standard was primarily one A1c of 6.5% or two fasting blood glucose results of 126 mg/dl or above.  However, last year the American Diabetes Association (ADA) published changes, which are summarized in its 2020 Standards of Care, that require two results in order to confirm the diagnosis.

The results can be obtained in one or two samples, and the second test should be completed “without delay.”  Call or email us to receive our updated Bulletin on Diagnosing Diabetes.

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What We’re Reading – Here’s how employers are changing benefits due to COVID-19

Although some companies have been hard hit by the economic effects of the COVID-19 crisis, experiencing closures or scaling back benefits, such as reducing or suspending 401(k) contributions, others are in wait-and-see mode or adding benefits for their employees.

This article summarized a study that found 47% of employers surveyed are enhancing benefits and 45% are expanding wellness programs. Over three-quarters of employers are providing access to virtual mental health services and others are proffering virtual services for remote workers, such as weight management and virtual workouts.

About one-third of employers are planning to add flexibility for paid time off (PTO), vacation and sick time and offer mechanisms to minimize lost days.  Some examples of the latter include increasing carryover limits, allowing negative balances and some may develop a donation program.

As summarized by the study’s architect, these positive changes are not only good for workers whose anxiety and stress might be off the charts right now, but also position the company as an employer of choice.

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Knowledge is Power: Why Open a Long-Term Care Related Business? (updated)

Perhaps you’ve been wondering if a long-term care related business makes sense in today’s economy and what the process entails.  This short blog series is intended to help new entrepreneurs understand a little more about the licensure process with the Agency for Healthcare Administration (AHCA) in establishing your Florida long-term care business.

First, let’s address the demographic factors that favor these businesses. The demographic changes affecting our country are inescapable and our healthcare system is feeling the strain.  The CDC reports:

  • 13% of the population is over the age of 65 and will increase to 19% by 2030;
  • In the same time period, the number of people over the age of 85 will grow from 5.8 million to 8.7 million;

As legislators attempt to stretch available dollars to cover the costs of caring for our aging population, there is more news:

  • About 80% of older adults have one chronic condition, and 50% have at least two. Infectious diseases (such as influenza and pneumococcal disease) and injuries also take a disproportionate toll on older adults. (CDC)
  • 45.3% of adults have two or more of nine selected chronic conditions, which include heart disease, hypertension, diabetes and cancer; these conditions are among the top five contributors for home health care utilization by Medicare beneficiaries.  (CDC)
  • The National Academy on an Aging Society projects that by 2040, the number of people in the U.S. with chronic conditions will increase by 50%.

Our aging population increasingly requires two types of care:  skilled care, such as nursing or rehabilitative therapy, and personal care which entails assistance with activities of daily living (ADLs) and instrumental activities of daily living (IADLs).  These acronyms represent activities we take for granted:  bathing and grooming, preparing meals and eating, using the bathroom or the telephone, and ambulating independently and safely in and out of the home.  Skilled care is provided in a hospital or nursing facility, but can also be carried out by licensed professionals in the patient’s home at a fraction of the cost.  The National Association for Home Care and Hospice (NAHC) adds to the case for home care by pointing out the 4000% cost difference between one hospital day and a home health care visit.

Click here to read about the different types of long-term care business options to find one that may be right for you.

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Long-Term Care: A Second Career for You

Uncertain economic times and dwindling retirement accounts sometimes lure individuals to pursue entrepreneurial ventures.  The motivations range from wanting to exert more control over one’s future and finances as well as serving people in need to the challenge of delivering high quality health care while lowering overall system costs.  Whatever the allure, various business structures exist to meet the urge to be self-employed in Florida:

  • Home health agencies providing skilled care – These agencies provide nursing care and rehabilitative therapy, are required to be accredited and are the only agency type that can bill for Medicare beneficiaries.  A new agency can take from nine months to a year to become fully operational.
  • Home health agencies providing non-skilled care – These organizations (which are sometimes called private duty agencies) provide assistance with personal care and activities of daily living, such as bathing, dressing, eating, toileting and ambulating.  No accreditation is required in Florida for non-skilled home health agencies, and these agencies have an estimated six-month start-up period.
  • Nurse registries – These companies musts provide all care via independent contractors and can provide nursing care as well as personal care services, but cannot provide therapies or bill Medicare for services.  Generally speaking, these organizations have lower capital requirements than home health agencies and can be operational in approximately four to five months.
  • Homemaker/Companion services – These organizations are subject to the least number of regulations and provide homemaking services, such as cleaning and laundry, as well as companion care.  This type of business can be operational in about six weeks.

Home health care has gone from an afterthought of the health care industry to its rightful place as a solid vehicle to lower healthcare costs, reduce re-admissions, improve patient care and preserve the independence of our country’s elderly. Given the demographic and economic factors in our society, these types of business can also provide a stable income stream.

Click here to read some facts that support a long-term care related business venture in today’s environment.

Call our office today to learn more about starting a long-term care business.

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What We’re Reading – DOJ Launches Lawsuit Against Anthem for Risk Adjustment Fraud

As detailed in this article, Anthem is facing a lawsuit initiated by the Department of Justice (DOJ) for allegedly failing to remove erroneously submitted diagnoses from CMS’s database despite knowing that inconsistencies might be present. The health insurance carrier commissioned a retrospective chart review process from third-party vendor to evaluate coding accuracy. The vendor identified conditions that were overlooked and could be coded, and also revealed conditions reported in error, which warranted removal from the member’s diagnostic profile. Anthem did not process the removals. Consequently, the risk score was “inflated” by incorrectly reported conditions that accounted for increased revenue of around $100 million per year from 2014 to 2018.   Even though Anthem refuses to acknowledge any wrongdoing, the plan is facing spending a long time in court rooms.

Physicians must recognize the importance of having a complete MRA program with a comprehensive auditing process that helps their practice to report diagnoses accurately; detect coding, documentation and submission inconsistencies; and notify the plan about any conditions that have been reported in error.

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