Blog and Helpful Articles

Florida Legislature Reduces HHA Quarterly Report Fines

In 2008, in order to combat the increasing amount of fraud by home health agencies, the Florida legislature instituted a mandatory quarterly reporting by all agencies of the following:

  1. Number of insulin-dependent diabetic patients receiving insulin injection services
  2. Number of patients receiving home health services from the home health agency AND a licensed hospice provider
  3. Total number of patients receiving home health services
  4. The names and license numbers of nurses (RN’s or LPN’s) whose primary job responsibility is to provide home health services to patients and received remuneration in excess of $25,000 for the three months of the quarter

The data from each quarter’s report is shared with the federal Centers for Medicare and Medicaid Services (CMS) and added to other sources of information to develop anti-fraud campaigns.

A home health agency’s failure to submit the quarterly report results in a $5,000 fine.  According to the Professional Staff of the Committee on Appropriations of the Florida Senate, “from January 1, 2009 through December 31, 2012, there were a total of 1,407 fines imposed. For the most recent state fiscal year, fines of $932,750 were imposed by final order.”  The magnitude of the fines has, among other things, caused some small agencies to close.

Moreover, private duty agencies are not able to provide services to Medicare members, and most are paid by the client’s private funds or long-term care insurance.  The Home Care Association of Florida claims that of the 380 private duty agencies fined in Florida, 200 went out of business after being fined.

Good news!  Effective July 1, 2013, the law has since been amended to:

  • Reduce the fine amount levied against HHAs that fail to file a quarterly report to the AHCA, within 15 days after the end of each calendar quarter, from the current fine of $5,000 to a fine of $200 per day up to a maximum of $5,000 per quarter; and
  • Exempt HHAs that do not bill Medicare or Medicaid, and are not owned by a health care entity which bills Medicare or Medicaid, from the fine for failing to file the quarterly report.

Home health agencies that bill CMS are still required to submit the quarterly report but the change in the fines allows some flexibility for those agencies that miss the deadline by a few days.

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What We’re Reading – Medical practice action plan: Overcome regulation overload

When you think of all the changes coming down the pike, it gets a little overwhelming, but don’t panic…. this article will ease some of the pressure and give you an action plan to make these transitions more bearable and/or manageable.  The major changes on the horizon are the conversion to ICD-10, Meaningful Use for incentive programs for Medicare and Medicaid, and last but certainly not least, the switch from paper charts to electronic health records (EHR) if you haven’t already made that change.  Following these steps can relieve some of the stress in your practice:

  • Assessment: Inventory what needs to be done – Make a list of all the projects that need to be accomplished and utilize the tool most hospitals use for patient care: a status board.  It’s a great means for keeping track and prioritizing those projects so everyone stays on the same page.
  • Formulation: Develop a game plan – Now that you have the list of the outstanding projects, assess your staff and identify the employees best suited to oversee each task.
  • Treatment: Check projects off the list – Once you have the key people set for each assignment, prioritize the jobs that need to be accomplished first or the ones that can “kill two birds with one stone.”
  • Follow-up: Stay organized and on task – In any situation, follow-up is always a key element.  You don’t want the ball to drop after all your hard work in implementing these changes.  So whether you do the monitoring, or you hire someone outside of your practice to tackle this – such as a consultant – make sure your office is making progress with the changes so you can stay on track with regulatory deadlines.

Change is inevitable and right now, it might seem like you’re the target in a huge game of dodgeball.  But with a little pre-planning and follow-up, you can win the game!

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2012 Top Ten Home Health Survey Deficiencies

According to the Home Care Association of Florida, the State of Florida Agency for Healthcare Administration’s (AHCA) top home health agency survey deficiencies are:

Tag

Short descrption
H302 Treatment orders
H350 Clinical records
H306 Plan of Care
H320 Plan of Care
H230 Personnel – Registered Nurse
H315 Acceptance of patients or clients
H304 Written agreement
H231 Personnel – Registered Nurse
H248 Personnel – HHA and CNA
H356 Clinical records contents

 

Attend our webinar entitled “2012 Top Ten Home Health Survey Deficiencies” to learn more about each citation and receive suggestions for remediation.

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Palmetto RAP Suppression:

Palmetto GBA plans to suppress RAP payment to home health agencies with a large number of auto-cancelled RAPs.  Here is an excerpt from their most recent communique:

“Providers are given the greater of 120 days after the start of the episode or 60 days after the paid date of the RAP to submit the final claim.  If the final claim is not submitted with the specified time, the RAP will auto-cancel and the provider must resubmit the RAP before submitting the final claim.  It is expected that instances where the RAP is auto-cancelled for no submission of a final claim should be minimal.

Palmetto GBA is monitoring the number of RAPs that are auto-cancelled due to providers not filing a final claim.  In accordance with Medicare regulations, contractors have the authority to revoke a provider’s privilege to receive payment on the RAP.  Therefore, providers identified with a high number of RAP auto-cancels due to no final claim will be notified that their RAPs will be set to pay at zero percent.  The payment suppression will continue until a Corrective Action Plan is submitted and the provider can demonstrate improvement in timely billing of final claims.  We will not be withholding the RAP payment; we will simply not pay RAPs for these aberrant providers.  The affected providers will only be paid for final claims.

Other providers that are identified to have RAPs auto-cancelled for no final claims that are below the acceptable threshold will be notified that their current billing practices are unacceptable and their RAPs are being monitored.  If improvement is not noted within a reasonable amount of time, future RAPs may be set to pay at zero percent.”

Details are slowly emergining, but here is what we know thus far:

  • RAP payments are being suspended for 298 home health agencies because they failed to submit final claims for 100 or more RAPs between January and April.  The agencies’ performance will be monitored and RAP payments restored if improvement occurs.  The targeted agencies had 100 or more RAPs auto-cancelled with some as high as 1300-4000.
  • Palmetto is the only MAC suppressing RAP payments at this time.  However, all MACs have the authority to do so.

Providers who wind up having their RAPs suppressed have an opportunity to exit RAP suppression if they show sufficient improvement in the number of RAP’s that are auto-cancelled.

For tips on Home Health Billing or more info regarding this article, contact Imark Consulting, Inc. or www.homehealthbilling.com.

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Hospital-Acquired Medical Practices: Buyer Beware?

An article in Futurescan 2012: Healthcare Trends and Implications 2012-2017 outlines the huge shift in favor of hospital-owned medical practices.  Those of us who’ve been around the block a time or two   can’t shake the déjà vu of the 1990s or the disastrous outcome.  This time, though, the outcome of a medical practice acquisition plan can be different as hospital systems vow to heed Santayana’s adage, “Those who cannot remember the past are condemned to repeat it.”

Some big factors in favor of a positive medical practice purchase experience include: the healthcare landscape looks almost nothing like it did in the ‘90s; physicians appear less resistant to hospital employment, perhaps due, in large part, to demographic factors; the market is open to novel compensation programs such as pay for performance/outcomes; and hospital management teams are adapting to the new normal by including physicians and embracing technology specific to the physician practice realm.

However, no different than undertaking any investment, knowledge is power, and it helps to know what you’re getting into.  A successful medical practice acquisition plan must include a thorough assessment of the ‘acquiree’ before the deal is done – in fact, before the deal progresses much past the early stages.

Business metrics can vary widely and be completely unrelated to the technical proficiency or clinical quality of the physician and his or her patient care.

Some medical practices are well-oiled machines and the owner’s motivation for acquisition is a win-win; the transition is smooth and the result is a high-performing practice that causes no headaches for its parent organization.  At the other end of the spectrum are distressed medical practices that have closeted skeletons disguised as inefficient operations, poor physician engagement, improper or ineffectual management and perhaps even clinical deficiencies.    Their keen interest in new ownership may stem from years of mistakes and neglect, culminating into trickling cash flow, liability issues and an unwillingness to change.  The bulk of practices, however, lie somewhere in the gray area in between:  they provide good care, are financially satisfactory in the provider’s eyes, but the lure of the parent organization’s benefits is hard to resist.  These businesses can still present acclimation challenges to the parent which may result in substandard financial performance for well beyond the traditional three-year grace period.

A solid review, conducted by a skilled practice manager with a solid track record and who is external to the parent organization, can pay dividends to:

  • The physician in understanding the strengths and weaknesses of the practice’s operations in concrete, financial terms.  An external assessment paves the way for the parent org to begin the transition to a different operational model and can help the physician thrive in a bundled payment or P4P system.
  • The hospital in having a blueprint of prioritized issues to target for optimal performance and profitability.  In addition, an external eye can assess the physician’s and staff’s willingness to become part of the hospital’s care continuum and conform to the parent’s requirements.  A smoother transition and aquiree acclimation are likely to result as well.  After all, a protracted battle between the practice and the parent will certainly have ripple effects that impact patients and employees, in addition to the parent organization’s image and reputation.

Any assessment worth its salt must cover financial areas, such as fee schedule and revenue sources; billing and collection policies, practices and processes; accounts receivable; managed care contracts and performance; and coding compliance.  The operational assessment should include a review of all processes and patient flows in addition to staffing levels and composition.

Caveat emptor may be the operating principle when buying a car, but fortunately, Florida’s laws can protect us from a lemony Cadillac.  Obviously, no such law exists in the complex world of health care acquisitions.  The outcome of a practice assessment may not influence the hospital’s strategic decision to acquire a practice, and it’s certainly possible to rebound from a ‘nightmare’ purchase.  However, forewarned is forearmed; our patients deserve the best chance for high quality care and service and to avoid the fallout from a troublesome acquisition.

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Temporary Delay in Implementing Ordering and Referring Denial Edits

Due to technical issues, the implementation of the Phase 2 ordering and referring denial edits is being delayed.  These edits would have checked claims for an approved or validly opted-out physician or non-physician.  If either of these were missing or incorrect, claims would deny.

CMS will advise of the new implementation date in the near future.  In the interim, informational messages will continue to be sent for those claims that would have been denied had the edits been in place.  Click here to read the announcement on the CMS website.

For tips on Home Health Billing or more info regarding this article, contact Imark Consulting at 888-370-3339 or www.homehealthbilling.com.

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Coleman Consulting Group presents a webinar on the “Basics of ICD-10-CM Coding”.

Don’t be lulled by the extension granted by HHS for transition to ICD-10-CM. This is the biggest change to hit the medical coding world in over 30 years, and the experts predict that coders’ productivity will be severely impacted. This presentation is an overview of the difference between the ICD-9-CM system and ICD-10-CM and discusses how providers can begin to prepare for the transition scheduled in 2014.

1 CEU

Price: $49.00  *** Summer Special $19.00

Session length: 60 minutes

Who should attend: Coding staff, managers, and anyone who wants to understand how ICD-10-CM differs from ICD-9-CM.

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7 Ways to Maintain Patient Interaction in the Age of the EHR

A common criticism of EMR (electronic medical records) use in medical practices is that it causes doctors to become less engaged and impersonal.  This causes frustration for all parties – patients and physicians – because doctors didn’t sign up for computer duty and patients expect a doctor’s full attention during visits.

Software Advice, a website that reviews medical software (here), recently did a survey on how to improve doctor-patient interactions in the EMR era.  They listed the top seven tips received on maintaining quality relationships:

  1. Position your computer between you and the patient:  No brainer here.  Face the patient during interactions.  Take the time to plan where your equipment will go so that this is possible.
  2. Invest in mobility: Whether it’s a small rolling desk, small tablets or other lightweight tools, choose equipment that helps you move around.  A laptop may cost an extra buck but can be worth the investment.
  3. Delegate as much as possible: The objective is to interact with the patient as much as possible.  Have staff members enter the medical history, medications, prior procedures, etc. prior to the patient’s visit so you don’t have to during the appointment.
  4. Dictate as much as possible: Talk with the patient while scribes enter the information or use dictation software.  These allow you to focus more on the patient.
  5. Ignore the computer when first enter the room: Chat with your patient for a few minutes before you start recording information in the digital record.
  6. Ask about previous complaints: If the patient information is pre-loaded, look over it before entering the room.  If they have open complaints, ask them about the issues to close them out in the emr.  This reaffirms to the patient that you care.
  7. Finish the chart in the room: This can help to answer any other questions that might come up so patients feel they have been listened to.

EMRs take some getting used to.  Once a physician develops a rhythm with the software, every patient interaction becomes easier.  Practice makes perfect.

For info or advice for software buyers and demand generation software vendors, contact Software Advice at 800-918-2764 or visit us at www.softwareadvice.com/medical

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CMS is holding some provider payments

The Centers for Medicare & Medicaid Services (CMS) has identified technical issues with certain parts of the April 2013 quarterly systems release.  For claims with dates of service or “through dates” on or after April 1, 2013, the issues affect (1) all Home Health final claims, (2) outpatient Critical Access Hospital (CAH) and Rural Health Clinic (RHC) claims where dollars have been applied to the beneficiary deductible, and (3) the remittance advice summary payment amount for Medicare Advantage inpatient prospective payment system (IPPS) claims with indirect medical education (IME).  Actual payments and the claim-level payment amounts on the remittance advice are correct for these Medicare Advantage IPPS IME claims.  Final home health, outpatient CAH and RHC, and Medicare Advantage IPPS IME claims with dates of service or “through dates” prior to April 1, 2013, are unaffected.

In addition, for claims pending with or received by the Medicare claims administration contractors on or after April 1, 2013, the issues affect (1) all claims for assistant-at-surgery services, and (2) all Ambulatory Surgical Center claims.  As a result of these issues, CMS has instructed its Medicare claims administration contractors to hold all of these specific claim types until April 14, 2013, when system fixes are expected to be implemented.  These claims will be released into processing on April 15, 2013.  The claim hold should have minimal impact on provider cash flow because, under current law, clean electronic claims are not paid sooner than 14 calendar days (29 for paper claims) after the date of receipt.

CMS regrets any inconvenience and is working to resolve these issues as quickly as possible.

For info or tips on Homecare Billing, contact Imark Consulting at
888-370-3339 or visit us at www.homehealthbilling.com

 

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