Blog and Helpful Articles

Home Health Services Require Ordering Provider’s NPI

To receive payment for home health services, any Medicare-enrolled Home Health Agency must file claims containing the name and National Provider Identifier (NPI) of the physician who ordered the service. When billing for an ordered home health service:

  • The individual physician must be enrolled in Medicare or in an opt-out status. You can verify that the ordering physician is enrolled in Medicare by reviewing the Ordering/Referring Report on the CMS website.
  • The NPI used for ordering must be for an individual physician; it cannot be a group or organizational NPI.
  • The individual physician must be of a specialist type that is eligible to order. These individuals include:
    • Doctors of Medicine or Osteopathy
    • Doctors of Podiatric Medicine

Failure to meet the requirements mentioned above will result in denied claims once the automatic edits are activated. The anticipated date for activation is June 26, 2012. For additional information, review the Medicare Learning Network’s “Medicare Enrollment Guidelines for Ordering/Referring Providers” fact sheet.

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

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What We’re Reading – Six reasons physicians need to be on social media

Marketing dollars are scarce in any economy.  These days, dollars need to go farther and inexpensive marketing ideas can be found by using technology. Although a lot of referrals occur by word of mouth, prospective patients still use the internet and Google to find more information about their physician before making an appointment.  And with all the online info about facilities and health outcomes, they certainly check stats before deciding on a facility.  This article contains some solid information on why physicians need to use social media; some reasons are:

  • To tell your story
  • To find a community
  • To express opinions and commentary
  • To discover what you’re passionate about
  • To conduct social media marketing
  • To manage your online reputation and streamline your practice

Check out another article on the six things patients want from social media so you will have the full picture and be able to apply it to your practice.

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Emergency Preparedness Reminders for Home Health Agencies

Home health agencies have their hands full when it comes to emergency preparedness, especially with regard to hurricane survival.  The state requires that agencies prepare and maintain a written Emergency Management Plan (EMP) to assure an efficient response during a crisis. Most home health agencies prepare their EMP upon licensure and, in the absence of an accreditation requirement, rarely give it another thought. However, whether your agency is accredited and requires documented annual EMP review or not, it is a best practice to:

  • Read through your plan each year and make any changes that are needed.  Plans often refer to specific individuals by name.  Make sure the ones you’ve listed are still employed by your agency and that their contact information is current.  Remember that any ‘substantive’ change or a change in telephone numbers for individuals responsible for emergency coordination must be reported to your agency’s county Office of Emergency Management and to the local County Health Department.
  • Assess any assisted living facilities (ALF) or adult family care homes (AFCH) in which your patients reside.  Be sure you’re knowledgeable of the facility’s emergency preparedness plan and its intention to evacuate the residents to an alternate location.  Your agency is required to designate staff to continue to deliver care according to physicians’ orders to residents in an ALF or AFCH during and after the emergency.
  • Survey your direct care staff (employed and contracted) about their availability during an emergency, their individual plans to evacuate the area (if any) and ensure you confirm at least two modes of contact. Most agencies have a requirement for staff to check in, say twice a day, during an emergency in case they don’t hear from you, and also to monitor public service announcements for agency news.  Consider adding this to your policy and training.   
  • Review your office evacuation plan.  Most agencies maintain an evacuation binder which contains: an updated list of every active staff member with current contact information; a current census list; copies of the current medication profile and equipment list for all patients, as well as current physician, pharmacy and medical equipment supplier contact information. Obviously, if your agency serves ALF or AFCH residents, you should also have current contact information for the facility’s leadership.

The word ‘current’ is emphasized above for obvious reasons:  outdated and/or missing information on patients or staff members could result in an adverse outcome as well as liability, both of which are unnecessary and preventable.  During hurricane season, we urge agency clients to conduct sporadic checks of the evacuation binder to make sure that updated lists have been filed in a timely manner.

  • Ask field staff members to review emergency preparedness information with clients at the start of hurricane season.  Make sure all patients have a copy of the Agency for Healthcare Administration’s EMP Appendix B, and that they understand the definition of a ‘sufficient’ supply of food, water and medication.  Most important is the staff member’s review of the medications and medical supply needs of current patients, and to make sure the patient has a handy copy of these lists in case evacuation is needed. At this time, personnel should assess whether the patient’s hurricane plan is adequate given changing health needs.  Special Needs Shelters are a last resort, but staff should assess whether the patient’s status now demands evacuation.
  • Re-orient your staff on their roles and responses prior to the emergency; this includes field staff as well as office personnel.  Accredited agencies generally have a requirement to conduct disaster drills, and it’s important to conduct yours just prior to the start of hurricane season.  One caveat: in South Florida, we tend to focus on hurricane preparedness because of the likely threat.  However, consider a simulation of other types of emergencies, such as fires, bomb threats, chemical spills, etc.
  • Conduct a drill.  Wait a week or two after your training session to conduct the actual drill.  Avoid giving instructions; instead, assess for your team’s knowledge of the overall process and readiness. Make sure to objectively document your staff’s response and effect any remediation to minimize mishaps during an actual emergency. Obviously, patient contact isn’t necessary, but a staff member should state that he or she is simulating patient calls and explain the nature of those ‘pretend’ calls.

A few counties in Florida require agencies to have a written understanding with a partner agency to assist with patient visits in the event the ‘home’ agency cannot staff a case during a crisis.  Consider this best practice as a safety net to assure you have a back-up plan and that your patients receive the care they need.

The crash landing of the “Miracle on the Hudson flight” reminded us all of the need for continued focus on emergency preparation.  Whether or not you believe the passengers’ safety was due to Divine Intervention, one thing is true:  crew member preparation and response were also critical to their survival.

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What We’re Reading – Is your telephone hurting your practice? Phone do’s and don’ts

When you really think of it, a patient’s first impression of your practice occurs long before he or she meets the clinician.  It begins to be formed when the patient calls the doctor’s office to make an appointment or obtain information.  Is your office losing out on new potential patients or losing existing patients that are frustrated because they can never get someone on the phone?  If you can answer yes to either question or you’re unsure of the answer, this article offers good tips on how you can prevent this from happening.  The author also provides suggestions in case you want to tweak the processes you already have in place.  Here is a quick list of approaches detailed in this article, and which may help your practice be more successful in retaining patients:

  • The professional approach
  • What’s my line?
  • Where and how the phone is answered

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Antidiscrimination in the workplace: Title VII of the Civil Rights Act

The Civil Rights Act of 1964 is the cornerstone of federal antidiscrimination legislation. It was the nation’s first comprehensive federal law making it illegal to discriminate in employing anyone based on said person’s race, color , religion, gender or ethnicity.

Title VII of this Act was passed to ensure equality in hiring, promotions, transfers, compensation and other employment-related decisions. The provisions of Title VII make it illegal for most employers to engage in the following:

  1. Discrimination or segregation in all terms of employment based on race, color, religion, gender or ethnicity. (Please note that several state and local laws have expanded these protected classes to include sexual orientation, marital status and weight.)
  2. Classifying employees based on their protected class with the intent to prevent that class from employment opportunities or career progressions. For example, Title VII would protect an employee from being denied a promotion based on being of the Muslim religious faith.
  3. Discriminating against any employee because of pregnancy, childbirth, or related conditions.
  4. Not providing equal opportunity to participate in training programs which offer opportunities for advancement.
  5. Sexual harassment and harassment based on the other protected categories (race, religion, etc.). Tip: Employers should develop a policy prohibiting any form of harassment and should include an internal complaint procedure.
  6. Discrimination in compensation practices. Tip: Always base compensation on seniority, merit or performance and ensure that systems are in place that measure the quality and/or quality of work.

Title VII applies to most employers in the United States, and any organization meeting one or more of the criteria listed below is subject to the rules and regulation of the Equal Employment Opportunity Commission (EEOC), which is the agency specifically set up by the government to monitor and administer the Act.

  • Most private employers who employ 15 or more persons on their payroll for 20 or more weeks in the current or preceding year;
  • Federal, state and local governments;
  • Public and private employment agencies when functioning as employers and when referring individuals for employment;
  • All educational institutions, public and private;
  • Labor unions with 15 or more members;
  • Joint (labor-management) committees for apprenticeships and training;

Several exceptions exist in regard to the definition of discrimination, such as:

  • Work-related requirements – For example, if a company manufactures and ships an item that weighs 70 pounds, few women may be able to pass this requirement.
  • Bona fide occupational qualification (BFOQ) – This is a criterion that is reasonably necessary to carry out the function of the job. For example, excluding males from consideration would be a BFOQ if you were hiring a women’s bathing suit model.  Similarly, filmmakers who hire actors based on race, gender or ethnicity would invoke the BFOQ.
  • If your company has a seniority system in place that was not set up to discriminate.

The EEOC has field offices nationwide and individuals who believe they have been discriminated against can file a charge in any field office.

Coming next… The EEOC complaint process.

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Tracking the Details

AHCA, CMS and accrediting organizations require the continuous tracking of certain information, such as educational hours, license expiration dates and insurance coverage, just to name a few.   Home health agencies and nurse registries vary in their sophistication and mechanisms to avoid dropping the ball on these items.  Expired materials represent one of the most widespread and easily avoided deficiencies.  Here are some ideas:

Using software. Most agencies employ a software program to manage their patients.  This system produces the Plan of Care and may even track staff visits and billing efforts.  Most systems will also allow you to create a list of your personnel file requirements and track expiration dates.  For example, you can probably enter dates for the driver’s license, auto insurance, CPR and professional license.  The key is to be consistent and enter expiration dates for all required aspects of the personnel file.

The next step is to run a report from the software program on a regular basis.  We suggest that you use a four-to six-week window of time, depending on the size of your agency.  Example:  in mid-April, run the report of items expiring in June.  This gives you ample time to contact each staff member and request the updated information.  As items are received, remember to key the new expiration date into your system.  That way, when you run another report – say, two weeks before the end of May – you will only see the items that are not current.  You can contact the staff members once again, with the explanation that they will be removed from active patient care if their materials are not current by end of May. Taking action will help you avoid being cited on an unannounced survey.

Using a manual system. Some agencies’ software programs cannot accommodate this task, or the managers don’t know how to properly use the system.  While you obtain training and bring your system up to date, use a manual process to track expiration dates.  A few suggestions follow, depending on your comfort level and computer skills.

  • Use Outlook or another calendar program.  Key document expiration dates using the same four-to-six-week system mentioned above.  Example:  Sally’s CPR expires on June 3rd.  Enter a calendar reminder for May 1st and in the body of the reminder, list everyone’s materials that are expiring in June, and which require your follow-up. On May 1st, when you log into your Outlook, the reminder will pop up and you can begin contacting staff members.  You can set another reminder two weeks before end of the month and depending on your staff load, can enter a final reminder on June 2nd so that you can remove Sally from patient care at the end of that day.
  • Use Excel or other spreadsheet program.  Some agencies enter all the aspects of the personnel file in an Excel spreadsheet, and use a column for expiration dates (Click Link).  You can then sort the columns in date order, again, using the same four-to-six-week schedule mentioned above.
  • Use an expanding file.  Office supply stores have expanding files with the months of the year, and others with slots labeled 1 to 31, representing the days of the month.  In a manual system, you would place a notation or a copy of the expiring document in the appropriate slot.  Example:  Sally’s expiring CPR would be filed either in the June tab (if you’re using the monthly tab format) or in the tab labeled with a 3 (if you’re using the daily format because it expires on the third day of the month).
    • If using monthly slots, you will pull everything out that is in the June slot, again, in mid-April, and begin notifying the staff members.  This needs to be a regular task performed on the first business day of the new month.
    • If using 1-31 daily slots, the process is the same but with a twist:  every day, pull out the information filed in that day’s slot.  The challenge is that on the 3rd, you will pull out materials for January 3rd, March 3rd, April 3rd, etc. so you need to sift through and re-file the materials you don’t need at this time.  The other key is that items will be filed on dates that fall on the weekend or on holidays.  So on Monday, you will need to check the daily slots for Saturday and Sunday’s dates to make sure you don’t miss anything.  This is a much more cumbersome process, so if possible, we suggest you use the computer to simplify your job.

No system will work without consistency so it’s important to set up the process and then make sure your employees are following it.  Computerized systems lend themselves to auditing by the manager.  Simply run a report yourself at any point in the process to make sure no expired items are unattended.

Final point:  Tough love is needed to follow through on expiring documents.  Your staff needs to know without any doubt that you will remove them from patient care if they don’t comply with your requests.  It seldom happens more than once before employees get the message that you are not willing to risk your agency’s license or accreditation on their lack of compliance.

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5010 Update: Extension of Enforcement Discretion Period for Updated HIPAA Transaction Standards through June 30, 2012

(March 15, 2012) The Centers for Medicare & Medicaid Services’ Office of E-Health Standards and Services (OESS) is announcing that it will not initiate enforcement action for an additional three (3) months, through June 30, 2012, against any covered entity that is required to comply with the updated transactions standards adopted under the Health Insurance Portability and Accountability Act of 1996 (HIPAA): ASC X12 Version 5010 and NCPDP Versions D.0 and 3.0.

On November 17, 2011, OESS announced that, for a 90-day period, it would not initiate enforcement action against any covered entity that was not compliant with the updated versions of the standards by the January 1, 2012 compliance date. This was referred to as enforcement discretion, and during this period, covered entities were encouraged to complete outstanding implementation activities including software installation, testing and training.

Health plans, clearinghouses, providers, and software vendors have been making steady progress: the Medicare Fee-for-Service (FFS) program is currently reporting successful receipt and processing of over 70 percent of all Part A claims and over 90 percent of all Part B claims in the Version 5010 format. Commercial plans are reporting similar numbers. State Medicaid agencies are showing progress as well, and some have made a full transition to Version 5010.

Covered entities are making similar progress with Version D.0. At the same time, OESS is aware that there are still a number of outstanding issues and challenges impeding full implementation. OESS believes that these remaining issues warrant an extension of enforcement discretion to ensure that all entities can complete the transition. OESS expects that transition statistics will reach 98 percent industry wide by the end of the enforcement discretion period.

Given that OESS will not initiate enforcement actions through June 30, 2012, industry is urged to collaborate more closely on appropriate strategies to resolve remaining problems. OESS is stepping up its existing outreach to include more technical assistance for covered entities. OESS is also partnering with several industry groups as well as Medicare FFS and Medicaid to expand technical assistance opportunities and eliminate remaining barriers. Details will be provided in a separate communication.

The Medicare FFS program will continue to host separate provider calls to address outstanding issues related to Medicare programs and systems. The Medicare Administrative Contractors (MAC) will continue to work closely with clearinghouses, billing vendors, or healthcare providers requiring assistance in submitting and receiving Version 5010 compliant transactions.

The Medicaid program staff at CMS will continue to work with individual States regarding their program readiness. Issues related to implementation problems with the States may be sent to Medicaid5010@cms.hhs.gov.

OESS strongly encourages industry to come together in a collaborative, unified way to identify and resolve all outstanding issues that are impacting full compliance, and looks forward to seeing extensive engagement in the technical assistance initiative to be launched over the next few weeks.

For info or tips on Homecare Billing, contact Imark Consulting, Inc. at888-370-3339 or visit us at www.homehealthbilling.com

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What We’re Reading – Patient non-compliance adds millions to health care costs

Patient non compliance with medications adds as much as $317 million to the nation’s health bill. The issues contributing to patients’ failure to take their meds range from cost (16%) to worry about the medication itself (15%), but by far the most common reason is forgetfulness. According to this article, 69% of patients reported forgetting to take their medications as well as forgetting that they forgot!

Obviously, this problem has ramifications as patients’ conditions can quickly worsen and/or lead to other illnesses – a vicious cycle of expense and disease. The price tag is greater than what we spend treating cancer, diabetes and congestive heart failure combined.

So how do you help patients remember to take their medications? This article summarizes Express Scripts’ new computer program that helps providers predict which patients will be non-compliant. This allows the Pharmacy Benefit Company to identify other resources to help the patients comply with treatment regimens. The results of a recent pilot project aren’t conclusive, but the company is hopeful. During the pilot, the Express Scripts team was able to – for example – put the patient with a medication concern in direct contact with a pharmacist to allay any misgivings.

Finally, patients will be informed of payment assistance programs or other low-cost alternatives. This summer, Express Scripts will begin offering the program to employers and focus on patients with specific illness, such as high blood pressure, high cholesterol, diabetes, asthma and osteoporosis. In addition, with the employer’s permission, the company can call patients with a medication reminder.

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The Basics of HIPAA (Part 5)

This is the last installment in our five-part series on the Basics of HIPAA.  So far, we’ve reviewed the history behind the HIPAA law, who is required to comply with it, and what exactly is protected under this law.  Today, we’ll take a look at electronic information and HIPAA’s protection of this ever-growing field that affects health care.

Security

Although the Privacy Rule contains some security provisions, and its guidelines cover all types of PHI, the federal government added the HIPAA Security Rule to the existing regulation in 2003.  This area of HIPAA added specific provisions for protecting the confidentiality, integrity and availability of electronic PHI.  Electronic PHI (or ePHI) is defined as individually identifiable health information that exists or is transmitted in electronic form.

Because of the proliferation of electronic mechanisms for receiving, creating, maintaining and transmitting PHI, the need for additional and specific protection is very great.

Where the Privacy Rule appears to be more “black & white” with regard to its specific requirements, the Security Rule is the complete opposite.  The main concept behind the Security Rule is its ‘scalability;’ in other words, Security Rule processes must be adapted to the uniqueness of each organization and cannot have a “one-size-fits-all” approach. A provider that has primarily paper records and very little electronic PHI would implement the Security Rule very differently from a practice with an electronic medical record (EMR) system.  The extent of the information that exists or resides in electronic systems dictates the provider’s activities with regard to security of ePHI.

Many practices have gone on ‘auto-pilot’ when it comes to protecting privacy.  It’s not uncommon to see offices being mindful of the visibility of computer screens and paper medical records.  They are generally careful not to leave PHI face-up in high-traffic areas and actually, some offices have gone a little overboard, removing patient names from files and sign-in systems. (This is unnecessary, by the way.)

The Security Rule, on the other hand, is a living, breathing process that must become second nature to the compliant provider organization.  It would be naïve and dangerous for you to believe that an annual security assessment and a policy book on the shelf are enough to demonstrate compliance with this regulation.  Monitoring security of ePHI and spotting breaches – or issues that could potentially lead to breaches  – in security must be continuous.

Well, that concludes our five-part blog series on the Basics of HIPAA.  By now, we hope you feel more knowledgeable about some of the nuances of this important legislation.  Remember that as a healthcare worker – and as patient yourself – HIPAA offers protection and control of healthcare information and that compliance is a team effort.  If you have any general HIPAA questions or need any clarification, feel free to call our office, or speak with your supervisor.

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