Blog and Helpful Articles

What We’re Reading – Work-Life Balance

The term “Work-Life Balance” has created a lot of buzz over the last few years. Employers have expended tremendous effort to determine the best way to incorporate this concept into a healthy work environment, especially as it relates to employing and retaining millennials.

The onset of the COVID-19 pandemic has forced a significant amount our workforce to now work from home and this article presents an interesting outlook to this work-life balance that has now become a reality, albeit temporary, for many.

Life as we knew it continues to change, and we look forward to getting back to normal. However, it will be interesting to see how much of this affects how we move forward and if this experience will increase remote working, which pre-COVID, was already a rapidly growing phenomenon.

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CMS Suspends Advance Payments to Part B Providers

As explained in the most recent Fact Sheet, CMS is suspending payments to Part B providers through its Advance Payment Program. This decision comes on the heels of a significant reinfusion of funds to provider relief efforts.   The $175 billion available to providers from the Coronavirus Aid, Relief, and Economic Security (CARES) Act and Paycheck Protection Program and Health Care Enhancement Act (PPPHCE) Acts is being distributed by the Department of Health & Human Services through the Provider Relief Fund, and it is expected that additional funds will be disbursed by the same means.

CMS will be re-evaluating all pending and new applications received and reassessing the formulas by which is makes disbursements.  In addition, several outstanding questions remain unanswered, such as how will providers return unused or unwanted funds.

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Repayment Proposals for Advance Payments (AP) During COVID-19

As explained in a prior blog, CMS will grant providers advance payment of three-months of Medicare claims, with repayment due by the 120th day of issuance of payment.  After that time, interest will attach to the unpaid balance and CMS will apply 100% of the payment for new claims to the unpaid balance.  The interest rate varies and will be based on prevailing rates at the time.

Since this payment process is also available to Part A providers, several advocacy groups have proposed different provisions for the unpaid balance.  The American Medical Association (AMA) is proposing:

  • Postponing the recoupment for one year after issuance of payment
  • Reducing the per-claim recoupment to 25% instead of 100%
  • Extending the repayment to two years instead of 120 days
  • Waiving interest due during the extended payment period
  • Authorizing more than one advance payment

No decisions have been made on repayment proposals as of this writing.

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CMS Issues Recommendations to Re-Open Health Care Systems in Areas with Low Incidence of COVID-19

On April 19, the Centers for Medicare & Medicaid Services issued new recommendations specifically targeted to communities that are in Phase 1 of the Guidelines for President Trump’s Opening Up America Again with low incidence or relatively low and stable incidence of COVID-19 cases. The recommendations update earlier guidance provided by CMS on limiting non-essential surgeries and medical procedures. The new CMS guidelines recommend a gradual transition and encourage health care providers to coordinate with local and state public health officials and to review the availability of Personal Protective Equipment (PPE) and other supplies, workforce availability, facility readiness, and testing capacity when making the decision to re-start or increase in-person care.  You can read more about it here.

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What We’re Reading – More than half of ACOs likely to leave Medicare Shared Savings program

While everyone is understandably focused on the day-to-day aspects of the COVID crisis, some attention needs to be directed to the long-term effects on risk-based providers who are tasked with caring for the principal population most at-risk for the virus:  the elderly.  The author of this article summarizes a survey where 80% of the ACOs expressed concern about their financial performance for 2020, and 56% indicated the possibility of leaving the Medicare Shared Savings Program.

Many of the traditional methods, such as wellness visits, regular exams and chronic care management, used by ACOs to manage high risk populations are not so feasible in the  COVID environment.  Elderly patients with multiple chronic conditions – the very ones for whom the principles of managing risk have shown cost savings – can quickly decompensate and require expensive care.

MedPAC has proposed to CMS to “skip” 2020 so ACO providers can focus on caring for patients without worrying about their financial performance.  While no solution or mitigation has been officially proposed, the looming May 31 deadline for providers to terminate ACO contracts is guaranteed to make this a hot topic very soon.

Update:

On April 30, 2020, CMS announced some expanded flexibilities for ACOs as a result of the COVID-19 crisis:

  • ACOs whose agreements end on December 31, 2020, will have the option of extending their participation.
  • ACOS in the BASIC track in 2020 can elect to stay there for 2021.
  • ACO shared losses due to the public health emergency (PHE) will be adjusted for the total months of the PHE & percent of beneficiaries affected.
  • HHS will increase the weight of the COVID-19 DRG by 20%.
  • CMS will exclude from ACO benchmarks all Part A & B fee-for-service (FFS) payment amounts for COVID-19 episodes of care triggered by inpatient service. The episode of care is defined as starting in the month the inpatient stay begins, all months of the inpatient stay and the month following the end of the inpatient stay.

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CMS Expands Telehealth Coverage

**This blog was updated in June 2020.  Click here to read the most current information.

As a result of the COVID-19 public health emergency, the Centers for Medicare and Medicaid Services (CMS) expanded the provisions for coverage of telehealth (TH) visits for Medicare beneficiaries. The attached summary contains some frequently asked questions we have received from clients regarding the billing of TH services.  If you have a question that is not listed, please feel free to call the office (954-578-3331) or email us at info@askCCG.com.

 

 

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What We’re Watching – Telemedicine Update: Professional Insurance

We watched an excellent webinar from law firm McDermott Will & Emery that covered professional liability insurance in the era of telemedicine and digital health. The title is Telemedicine Update: Professional Insurance.

As we know, our healthcare system has been making great inroads in telemedicine, with the proliferation of companies providing virtual visits and healthcare systems establishing telehealth programs.  In the past, telemedicine was an episodic service. It has rapidly become more of a “subscription” model where providers see the same patient multiple times via electronic means. Typical medical malpractice policies have exclusions for any kind of cyber event, which includes issues such as ransomware, and tech or system failures. In addition, only a select few carriers even include bodily injury due to technology errors.

Because technologically delivered services are rated differently by insurance carriers, there is concern that insurance premiums will rise since insurance companies will look to mitigate potential losses due to COVID-19.  In addition, upon renewal, providers may find new exclusions in their policies, specifically coverage for any losses related to pandemics.

The webinar presenters suggest that providers check current malpractice insurance policies to assess their coverage for bodily injury related to technology/telemedicine.  In addition, they suggest providers make the professional liability carrier aware of their telemedicine activities and assure coverage for any resulting bodily injury.

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Advance Payments (AP) During COVID-19

Many providers are feeling the financial pinch as a result of the business changes brought about by the COVID crisis.  Chief among them is a disruption in claims payment from the Centers for Medicare and Medicaid Services (CMS) for services provided to beneficiaries. Fortunately, it is possible for providers to request an accelerated or advance payment during the period of time declared a public health emergency.

This document from CMS outlines the eligibility and process, but in a nutshell:

  • The provider needs to have billed claims to Medicare during the 180 days prior to the request for AP.
  • You can request an AP of up to 100% of the Medicare payments for a three-month period.
  • Providers should continue to submit claims after receiving the AP and will receive payment even if the repayment has not yet begun. This means that essentially, you will have the AP funds and still receive payment for your current services, which should alleviate some financial distress.
  • Repayment of APs begins 120 days after the issuance of payment. It is important to remember that payments to providers will continue during the 120 days of receiving the AP despite no repayment.

Please read the official explanation and process to request an AP here:FACT SHEET ACCELERATED and ADVANCE PAYMENT Final update

 

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Now is the Time for Longer-Term COVID-19 HR Planning

As the COVID-19 pandemic evolves and remote working becomes the norm, Human Resources professionals attempt to balance the needs of all employees: both management and their direct reports. As HR departments all over the country navigate their individual needs based on industry, there are some basic necessary components needed for “survival” during this period.

  • Open Communication & Transparency. Employees are nervous about the future and it is important that we do not over-promise but communicate that the company is doing everything possible to pursue all avenues of relief to keep the organization going.
  • Planning and Focus. After the scramble to reorganize, set up remote working where possible and possibly even restructure, the next step is to plan for the future should this new way of working extend beyond our immediate expectations. Have we planned a continuation of changed duties and are these changed duties sustainable?
  • Accountability. How do we engage our staff and manage their productivity? Companies have been using various means of communications, such as virtual meetings, chat rooms to allow teammates to collaborate on projects, and daily spreadsheets to manage and track the work being done. Either way, it is important to find ways to keep your staff accountable while being able to encourage engagement.

As management, we acknowledge that we truly do not have all the answers, and we are fearful of the unknown. It is however our job to tackle the obstacles and lead with calm and patience as we navigate through these tumultuous times.

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What We’re Reading – Physician Stress & Burnout

Studies of physician burnout aren’t new, but for all the awareness of the last dozen years, the problem doesn’t get any better.  An updated study summarized in the February 2020 issue of The American Journal of Medicine shows that physician burnout is a growing problem with implications for practitioner and patient health.

The article states that 44% of physicians feel burned out, and that 14% report suicidal thoughts, for which most do not seek treatment.  Information technology-related stress tops the list of culprits, cited by 70% of survey respondents.  The article explains that physicians are generally not satisfied with electronic medical record (EMR) systems, and that users spend more time on clerical tasks, adding to their feelings of burnout. Surprisingly, primary care physicians (PCPs) reportedly spend an average of two hours interacting with an EMR for every hour of patient contact, and 37% of patient appointment time is devoted to EMR interaction. The author also stated that the relationship between EMR time and burnout was very strong.

Physician burnout results in decreased productivity, affects physician health, can lead to worsened patient outcomes and satisfaction and can exacerbate the shortfall of physicians predicted for 2025.

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