Trizetto Moving to the Cloud

I wanted to pass along the following communication from Trizetto to help you with a smooth transition.

Please share it with your insurance and billing team so they can plan accordingly. Remember, claims will not go, and EOBs will not be accessible during the time-frame of 11:59 p.m. CST on March 14, 2019 until approximately 11:59 p.m. on March 17, 2019.

If you are not a Trizetto/Gateway EDI client, you can disregard the information below.

Sincerely,

Lisa Barnett

“Increasing your collections through better billing and documentation.”

=====================

Important Message from Trizetto Electronic Claims Submitter

RE:  Microsoft Azure® Migration

Dear Valued Client,

In order to ensure the most secure, reliable and highest performing platform for our services, TriZetto Provider Solutions, a Cognizant Company, will migrate data from our St. Louis data storage facility to the Cloud-based Microsoft Azure® platform.

Why Are We Migrating?

A cloud-based data center will align data transport security protocols to industry standards while also providing significantly enhanced information security and opportunities for growth. We believe the benefits of this migration far outweigh the costs, and that our clients will benefit greatly from this transition. Benefits include:

  • Increased speed
  • Consistent, reliable storage capabilities
  • Higher levels of security

How Will Your Organization Be Affected?

The transition of data will have a direct impact on our clients. Because of the migration, clients will experience an extended outage starting at 11:59 p.m. CST on March 14, 2019 until approximately 11:59 p.m. on March 17, 2019. During this time all applications will be inactive and no incoming transactions will be accepted for processing.

TPS is working diligently to ensure a seamless transition. We have chosen to put this project into effect over a weekend to minimize impact to our clients. We apologize for any inconvenience this may cause.

If you have any questions or concerns, please reach out to our customer service team at 800-556-2231 or physiciansupport@cognizant.com. Thank you for your patience and support during this time.

-TriZetto Provider Solutions

Health Account Savings Plans: Assisting Your Patients To Stay on Their Treatment Plan

Welcome to your best chiropractic year!

Commercial health insurance carriers such as United Health Care and Anthem BCBS can offer their customers, who are also your patients’ employers, two different health account savings options:

  • Health Reimbursement Arrangement
  • Health Savings Account

An employer can also directly offer the benefit of their employees signing up for a Flexible Spending Account.

Let’s dig into each one!

What is a Health Reimbursement Account? (HRA)

A Health Reimbursement Account (HRA) is an account that your patient’s employer funds to help the employee pay for covered healthcare services. The patient cannot put monies into an HRA, as the account is owned by the employer. This includes paying for services (chiropractic office visits) that apply to the patient’s deductible. The patient can begin using their HRA on the first day of the plan year. Since the patient’s employer controls the fund, the employer has the ability to make the rules on when and how the patient can use the money. Additionally, there are coinsurance-only HRA plans available, whereby the patient’s employer will pay only coinsurance amounts.

The patient does not have to pay taxes, state or federal, on HRA monies, so it is a tax savings. The HRA cannot earn interest as it is not a personal bank account.

How do you, Doctor, get paid? Once claims are submitted to the insurer, the insurance carrier will pay, as long as the patient has funds in the account. You will typically, but not always, receive two EOBs/remittances for the same DOS. This is usually due to that first charge going to the patient’s PCP and then getting denied and forwarded to the employer. Referrals from the patient’s PCP to your office is not a requirement tied to an HRA.

There is only one account set up for all covered dependents on a plan. The employee does not report the HRA monies to the IRS.

Takeaways:

  • Get in good standing with your community’s businesses and industries so chiropractic can stay included on their coverage and benefits, and you can get those referrals!
  • Billing Tip: Make sure you are posting to the most recent, newest remittance.

Health Savings Account (HSA)
A Health Savings Account is a savings plan set aside for taxpayers who enroll themselves in a high-deductible health plan. They can be offered by your patient’s employer as an employee benefit, or the patient may elect to sign up independently. The benefit here is that the funds are not subject to tax liability upon deposits. Moreover, if there are monies left in an HSA, they can roll over into the next year. When your patient’s health plan offers this type of plan, they are provided with a debit or credit card to make their eligible health service purchases. Both the patient and their employer can contribute to the fund. The patient must report this account to the IRS when they do their taxes.

Takeaway:

Health Savings Accounts are not owned by the patient’s employer. All taxpayers with high-deductible health plans are eligible and must report this account to the IRS when doing taxes.

Employer-based Flexible Spending Accounts (FSA)
An Flexible Spending Account is a special account the patient puts money into to pay for certain out-of-pocket expenses such as medical related, dependency related, and a limited dental and vision plan. This arrangement also has a tax-free benefit. The list of all eligible expenses can be found on the IRS website at: https://www.irs.gov/newsroom/irs-plan-now-to-use-health-flexible-spending-arrangements-in-2019

The employer owns this account.

A frequently asked question I get is, does an FSA cover massage?
Answer: Yes, it does with the ordering physician (chiropractors included) writing a note of necessity for the massage therapy.

When there are monies left over in the account at the end of the year, the employer has two options they can offer their employees:

  1. The patient can set aside the monies and use it up to two-and-a-half months into the new year, or
  2. The employer can allow the employee to carry over up to $500 from one year to the next.

Takeaway:
There are several eligible out of pocket expenses that an FSA will cover. Click on the IRS link for more information: https://www.irs.gov/newsroom/irs-plan-now-to-use-health-flexible-spending-arrangements-in-2019

SUMMARY
If your patients struggle to keep their appointments due to financial concerns ask them if they have one of these savings accounts that might be able to supplement payment of their care and keep them on their treatment plan.

Oh, one further heads-up to our profession just finding its way down the pipeline . . . you may have or will be receiving a letter from a TriWest Family Alliance group out of Arizona promoting their billing services on behalf of VA offices. This letter is being distributed nationwide. Please note we have researched this, and credentialing and contracting with this group is optional. If you already have a contract with your VA, you may continue treating VA patients as usual. There is no change in their referral of patients to you, or the preauthorization process.

If you have any further questions, don’t hesitate to reach out to either myself or Dave.

Please feel free to forward this article to your insurance department.

Adios for now!
Lisa

“Increasing your collections through better billing and documentation.”

Medicare, Yada, Yada, Yada: Fraud, Waste and Abuse Training.

OK, I admit it. Medicare is not the most glamourous topic to write about, nor does much of it pertain to our world of the chiropractic profession as we know it. However with that said, I am doing due diligence for you and fulfilling my duty to inform you of the necessary requirements a Covered Entity must follow (that’s us included!) to keep the Office of Inspector General off our backs and to help you take preventive measures so you’re not sending back reimbursement money you earned from providing patient care.

Because . . . based on my observations in the field – and this is a review for those of you who read our PM&A articles and utilize our library- how many of you know, for example, what a Part C Medicare plan is? How many of you know that all Part C providers are required to undergo annual Fraud Waste and Abuse training?

Second example: How many of you are aware that Medicare, starting in April of this year and going into April of 2019, is sending all of their beneficiaries new ID cards in an effort to do away with social security numbers for the sake of safeguarding identification?

So how do my two examples above directly impact you, your practice, and your bottom line?

Let’s circle back to the first example. A Part C Medicare Plan is known as a Medicare Advantage Plan. It oftentimes covers more services than a straight Medicare plan does. HMO/PPOs such as Humana and Blue Cross Blue Shield have developed their own Medicare Advantage Plans and offer them to their policyholders, your patients. A patient who signs up for an Advantage Plan must also be enrolled in Medicare A (hospital), and Medicare B (outpatient provider services). Medicare Part C providers to date have been required to, annually, undergo what is called Fraud, Waste and Abuse Training. Let’s take each of the three words and define them from the Medicare and Medicaid world.

  • Fraud is known intent to deceive in order to collect money from the Medicare program illegitimately.
  • Waste is overutilization of services or other practices that, directly or indirectly, result in unnecessary costs to the healthcare system, including the Medicare and Medicaid programs. It is not generally considered to be caused by criminally negligent actions, but by the misuse of office and/or practice resources.
  • Medicare Abuse includes practices that result in unnecessary costs to the Medicare program such as over or underutilizing services. You are probably familiar with the Quality of Care initiatives such as MIPS/MACRA and the EHR incentives, implemented to help combat abuse. Common types of abuse include:
    • Billing for unnecessary services
    • Overcharging for services or supplies
    • Misusing billing codes (upcoding) to increase reimbursement*

*Downcoding is also a misuse of billing codes. Stop doing it. Although not intended to increase reimbursement it is a red flag to Medicare, and your services will be questioned as to if they were “medically necessary.”

Back to the training . . . I urge you now to complete this training by the end of December. It is intended for doctors and staff. Download the PowerPoint below, read thoroughly and after completion have each staff and doctor sign off to attest, they read through the PowerPoint. The sign-off can be as simple as logging signatures and completion date in a notebook or a spreadsheet. It is not necessary to print out the PowerPoint. Oh, and many insurance contracts require this training as a contract obligation to be part of their network as well. You can access Medicare’s training PowerPoint here: Fraud, Waste and Abuse

Referring back to the second example of new Medicare cards. You can review our previous article and checklist here: New Medicare Beneficiary Indentifiers to be Assigned Your Patients

Your staff should be asking Medicare patients for their new cards, making a copy, and making sure the address in your practice management program matches the address the Social Security office has on file. If there is a mismatch like the patient has moved and not updated their address, you will have problems getting reimbursed. Make sure your Insurance Profiles in your programs have the new Medicare IDs.

Stay tuned for more helpful articles like this. If you have any questions on the above, contact me! I’m here to help.

Lisa Barnett
920-334-4561
lisa@pmaworks.com

And remember . . .
“The Future Will Be Our Results” (Clarence Gonstead, D.C.)

Start Preparing NOW – New Medicare Beneficiary Identifiers to be Assigned Your Patients

Beginning in April 2018, through April 2019, The Centers for Medicare and Medicaid Services will re assign all Medicare Beneficiary Identification (MBI) Numbers, and re-issue cards to your Medicare patients and Medicare Railroad retired patients. Social security numbers will no longer be used. Instead, a grouping of numeric-alpha characters, such as 1EG4 TE5-MK72, will be assigned.

Things to Keep in Mind:

  • The new cards will not change your patient coverage or benefits.
  • New patients who start on Medicare in April and beyond will be assigned only the new number.
  • Correct patient addresses are critical for getting claims processed and getting you paid. The patients’ mailing addresses you have on file MUST match the addresses the Social Security office has on file.

We have put together a simple, quick ready checklist to keep you ahead of the game.
Email us at services@pmaworks.com
for your FREE copy today!

If you have any further questions, we’re here to help make sure you get reimbursed in a timely manner. These changes are coming. Give us a call!

Happy New Year!
~Lisa

Lisa Barnett
Services Consultant/Coach
920-334-4561
lisa@pmaworks.com
www.pmaworks.com

 

New ABN Form Effective 06.21.2017

New ABN Form and Implementation Instructions

Frequently asked questions and answers for the ABN form

New ABN English 2017(PDF) – Form CMS-R-131 goes into effect June 21, 2017. You may begin using the new one now(April 2017), but on and after June 21 per CMS, you may not use your current ABN.

New ABN 2017 (DOC) Form CMS-R-131 goes into effect June 21, 2017. You may begin using the new one now(April 2017), but on and after June 21 per CMS, you may not use your current ABN.

New ABN_Spanish 2017(PDF)-Spanish Version Form CMS-R-131 goes into effect June 21, 2017. You may begin using the new one now(April 2017), but on and after June 21 per CMS, you may not use your current ABN

ABN-Use(Doc) How and when to use the Advanced Beneficiary Notice for Medicaid Services

Script-for-ABN-form(DOC)– Script for explaining the form to the patient

Final Revised ABN-2012- Advanced Beneficiary Notice for Medicare Services – expires June 21, 2017.

Has Your Office Been Target by Medicare for an Audit?

Ms. Lisa Barnett with Petty, Michel and Associates specializes in preventing Medicare Audits. She has helped those who have already been targeted find a fast and safe way out of trouble.

You are not alone…. Things do Happen…..
You are busy and possibly you have overlooked a certain requirement. Your computer has gone through updates and you have not kept up. Or possibly your documentation is simply inadequate in the eyes of medicare or the government.

Whether you are faced with a prepay audit or a post payment audit. I can help !

With 10 years of experience in the chiropractic industry and with documentation; and a chiropractic advocate for 30 years I care and I want to help.

Call today for your complimentary phone consultation and record review. 920-334-4561

Are You One of the 8500 Who Received a Letter From Medicare? Keep Calm and Don’t Panic

Have you received a fax or letter from Center for Medicare/Medicaid Services regarding Comparative Billing Reports?  Don’t panic – call me and I will provide an onsite assessment at your practice to ensure your documentation, billing, and coding stay compliant.

Call Lisa:  nine two zero 334-4561

Email Lisa:  lisa@pmaworks dot com

MACRA- New Info on Medicare!

rs-medicare-info-icon

New Info on Medicare!

Happy Holidays Chiropractic Friends!

First snowfall always seems to bring renewed energies and hope – my wish is you experience this, too.

Are you ready for January 2017? Ready or not, here it comes. Today I want to introduce and give you some of the latest and greatest on what’s happening with the new Medicare reimbursement model also beginning our new year.

To start with, six new acronyms to introduce to you: MACRA, MIPS, CHIP, APM, SGR, CPIA

  • MACRA: Medicare Access CHIP Re-authorization Act of 2015
  • MIPS: Merit-Based Incentive Payment System
  • CHIP: Children’s Health Insurance Program
  • APM: Advanced Payment Model
  • SGR: Sustainable Growth Rate
  • CPIA: Clinical Practice Improvement Activities

Here’s a bit of background for you regarding the initiative. In April 2015, President Obama signed into law the Medicare Access and CHIP Reauthorization Act 2015 (MACRA). This is an act to transition Title XVIII of the Social Security Act to the Medicare sustainable growth rate and strengthen Medicare access. How? By improving physician payments and making other improvements, like the Children’s Health Insurance Program. We could say MACRA is the umbrella to the program.

What is the purpose of the change in reimbursement model? The purposes include simplifying reporting for the convenience and ease of the providers participating; decreasing the current costs of healthcare, allowing patients the best quality of care; and to make patient information sharing safe and easy. The blueprint for pay for performance is the Merit-Based Incentive Payment System, and the goal is to create an acceptable payment system for physicians and the program.

Who are the stakeholders in the broader MACRA program? They include beneficiaries (your patients), businesses, payers, providers, and state partners.

Are you eligible to participate?

Both participating and non-participating providers are eligible to participate if you meet both of the following criteria: 1) Have seen 100 or more unique patients in a year, and 2) Have billed for covered services at $30,000 or more a year. You are exempt from participating in 2017 if 2017 is your first year as a Medicare provider. You are also exempt if you do not meet one of the two criteria above.

How will it work?

CMS has indicated through various webinars that they will notify via written communication if you are or are not eligible to participate. Once you learn of your eligibility, the program will require participating providers to report on three categories for the Merit-Based Incentive Payment System:

  • Quality (i.e., Physician Quality Reporting System, also known to you as PQRS but with some tweaks).
  • Practice Improvement, focusing on clinical quality measures. For examples, patient outcomes; patient engagement and compliance; adherence to your practice systems and guidelines.
  • Advancing Care Information (this is the technical component; i.e., Meaningful Use and minimum five measures recorded in your practice’s healthcare technology).

Additionally, if you are eligible to participate and choose not to, there will be a negative adjustment of 4% to your Medicare reimbursement. If you are eligible and do choose to participate, you may receive a positive adjustment of 4 to 9% depending on your level of reporting involvement, as well as a minimum 0.5% bonus for exceptional performance if your final reporting score meets or exceeds a certain point value.

You will have two reporting options: You may report for the entire 2017 calendar year, or you may report for the partial year, one quarter, and may begin no later than October 2, 2017.

PM&A will continue to monitor any changes to the above information.

In addition, I will be conducting onsite MACRA readiness assessments at chiropractic offices and am available to visit yours. Please contact me if you are interested in learning more!

Best,

Lisa Barnett, Consultant
Petty, Michel & Associates

Call: nine two zero.334.4561

Email: Lisa@pmaworks dot com

Changes to ICD-10 Codes That May Affect Chiropractors

We know all too well how keeping abreast of all the changes in the insurance world can sometimes be overwhelming for your practice so we wanted to simply help you out by sharing some recent information regarding ICD-10 codes.

ChiroCode Institute recently published the changes to ICD-10 Codes that are going into effect October 1st.  While there are thousands of code changes, we have listed below the codes most relevant to chiropractors.  To download a printable copy of this list click here [ICD-10-Changes-Oct-2016]

  • G56.03  Add   Carpal tunnel syndrome, bilateral upper limbs
  • G56.13  Add   Other lesions of median nerve, bilateral upper limbs
  • G56.23  Add   Lesion of ulnar nerve, bilateral upper limbs
  • G56.33  Add   Lesion of radial nerve, bilateral upper limbs
  • G56.43  Add   Causalgia of bilateral upper limbs
  • G56.83  Add   Other specified mononeuropathies of bilateral upper limbs
  • G56.93  Add   Unspecified mononeuropathy of bilateral upper limbs
  • G57.03  Add   Lesion of sciatic nerve, bilateral lower limbs
  • G57.13  Add   Meralgia paresthetica, bilateral lower limbs
  • G57.23  Add   Lesion of femoral nerve, bilateral lower limbs
  • G57.33  Add   Lesion of lateral popliteal nerve, bilateral lower limbs
  • G57.43  Add   Lesion of medial popliteal nerve, bilateral lower limbs
  • G57.53  Add   Tarsal tunnel syndrome, bilateral lower limbs
  • G57.63  Add   Lesion of plantar nerve, bilateral lower limbs
  • G57.73  Add   Causalgia of bilateral lower limbs
  • M21.611  Add   Bunion of right foot
  • M21.612  Add   Bunion of left foot
  • M21.619  Add   Bunion of unspecified foot
  • M21.621  Add   Bunionette of right foot
  • M21.622  Add   Bunionette of left foot
  • M21.629  Add   Bunionette of unspecified foot
  • M25.541  Add   Pain in joints of right hand
  • M25.542  Add   Pain in joints of left hand
  • M25.549  Add   Pain in joints of unspecified hand
  • M26.60   Delete  Temporomandibular joint disorder, unspecified
  • M26.601  Add   Right temporomandibular joint disorder, unspecified
  • M26.602  Add   Left temporomandibular joint disorder, unspecified
  • M26.603  Add   Bilateral temporomandibular joint disorder, unspecified
  • M26.609  Add   Unspecified temporomandibular joint disorder, unspecified side
  • M26.61  Delete  Adhesions and ankylosis of temporomandibular joint
  • M26.611  Add   Adhesions and ankylosis of right temporomandibular joint
  • M26.612  Add   Adhesions and ankylosis of left temporomandibular joint
  • M26.613  Add   Adhesions and ankylosis of bilateral temporomandibular joint
  • M26.619  Add   Adhesions and ankylosis of temporomandibular joint, unspecified side
  • M26.62   Delete  Arthralgia of temporomandibular joint
  • M26.621  Add   Arthralgia of right temporomandibular joint
  • M26.622  Add   Arthralgia of left temporomandibular joint
  • M26.623  Add   Arthralgia of bilateral temporomandibular joint
  • M26.629  Add   Arthralgia of temporomandibular joint, unspecified side
  • M26.63  Delete  Articular disc disorder of temporomandibular joint
  • M26.631  Add   Articular disc disorder of right temporomandibular joint
  • M26.632  Add   Articular disc disorder of left temporomandibular joint
  • M26.633  Add   Articular disc disorder of bilateral temporomandibular joint
  • M26.639  Add   Articular disc disorder of temporomandibular joint, unspecified side
  • M50.02   Delete  Cervical disc disorder with myelopathy, mid-cervical region
  • M50.020  Add   Cervical disc disorder with myelopathy, mid-cervical region, unspecified level
  • M50.021  Add   Cervical disc disorder at C4-C5 level with myelopathy
  • M50.022  Add   Cervical disc disorder at C5-C6 level with myelopathy
  • M50.023  Add   Cervical disc disorder at C6-C7 level with myelopathy
  • M50.12  Delete  Cervical disc disorder with radiculopathy, mid-cervical region
  • M50.120  Add   Mid-cervical disc disorder, unspecified
  • M50.121  Add   Cervical disc disorder at C4-C5 level with radiculopathy
  • M50.122  Add   Cervical disc disorder at C5-C6 level with radiculopathy
  • M50.123  Add   Cervical disc disorder at C6-C7 level with radiculopathy
  • M50.22   Delete  Other cervical disc displacement, mid-cervical region
  • M50.220  Add   Other cervical disc displacement, mid-cervical region, unspecified level
  • M50.221  Add   Other cervical disc displacement at C4-C5 level
  • M50.222  Add   Other cervical disc displacement at C5-C6 level
  • M50.223  Add   Other cervical disc displacement at C6-C7 level
  • M50.32   Delete  Other cervical disc degeneration, mid-cervical region
  • M50.320  Add   Other cervical disc degeneration, mid-cervical region, unspecified level
  • M50.321  Add   Other cervical disc degeneration at C4-C5 level
  • M50.322  Add   Other cervical disc degeneration at C5-C6 level
  • M50.323  Add   Other cervical disc degeneration at C6-C7 level
  • M50.82   Delete  Other cervical disc disorders, mid-cervical region
  • M50.820  Add   Other cervical disc disorders, mid-cervical region, unspecified level
  • M50.821  Add   Other cervical disc disorders at C4-C5 level
  • M50.822  Add   Other cervical disc disorders at C5-C6 level
  • M50.823  Add   Other cervical disc disorders at C6-C7 level
  • M50.92   Delete  Cervical disc disorder, unspecified, mid-cervical region
  • M50.920  Add   Unspecified cervical disc disorder, mid-cervical region, unspecified level
  • M50.921  Add   Unspecified cervical disc disorder at C4-C5 level
  • M50.922  Add   Unspecified cervical disc disorder at C5-C6 level
  • M50.923  Add   Unspecified cervical disc disorder at C6-C7 level

ICD-10 Reference:

Gwilliam, Evan M, DC MBA BS CPC CCPC NCICS CPC-I CCCPC MCS-P CPMA, ChiroCode Institute

If you have any questions regarding these changes Petty, Michel and Associates would be glad to help guide you in the right direction.  Please email to services@pmaworks.com or call us at 414-332-4511.  We are here to help!

The Importance of Compliance in a Chiropractic Office – HIPAA, Covered Entity, OSHA, HITECH

Lisa J. Barnett

Lisa J. Barnett

HIPAA, Covered Entity, OSHA, HITECH – – Compliance. What’s happening in the world of compliance and why do you as a chiropractor need to be educated and remain in the know? Find out below . . .

First and foremost, according to the Health and Human Services (HHS), chiropractors are included in the covered entity category, and this is regardless of whether or not you have received Electronic Health Records incentive monies. Covered entities are required by federal law to comply with all areas of protected health information and employee safety standards. Impact of non-compliance? In February 2016, a covered entity was fined $239,800 for non compliance.

Further, according to a March 2016 survey among small practices designated as covered entities, 60 percent of the 900 plus professionals surveyed are still unaware of pending compliance audits, and 58 percent have not appointed a securities/privacy officer in their practice. Audits to our profession are forthcoming, and we cannot opt out. Keep reading on how to safeguard yourself and your practice. Also keep in mind that it takes approximately 40 to 50 hours to develop and secure a compliance program.

The three main areas of compliance you need to be aware of, educated in, and be an active participant include: HIPAA, OSHA, and IT Securities.

Health Insurance Portability and Accountability Act
The Health Insurance Portability and Accountability Act (HIPAA) law of 1996 was enacted to improve the portability and accountability of health insurance coverage, and it brought individual privacy rights to patients and requires that we notify them of their rights. It also serves to eliminate fraud, waste, and abuse in healthcare. The focus here is to safeguard your practice by securing personal (patient) health information (PHI) and personal identifiers, be it paper or electronic (ePHI). This can include data encryption, secure messaging, compliant Cloud storage, compliant software, and unique password setups. One of the areas I assess when I visit a clinic is locating where the patient paper files are kept and if they are well out of viewing from others.

Your HIPAA requirements to be compliant at the clinic level include:

  • Designating a compliance/privacy officer whose primary responsibility is to ensure compliance with the regulations
  • Establishing and implementing at least annually, training programs for all employees and doctors.
  • Implementing appropriate policies and procedures to prevent intentional and accidental disclosure/release of PHI or ePHI. Encrypting your data for example will lower your chances of ransomware or cyberattacks.

OSHA
The United States Occupational Safety and Health Administration (OSHA) Act was signed by President Nixon in December 1970. It is designed to protect worker safety and promote healthy work environments. Some of you Docs have been involved in workplace safety and onsite workplace assessments in factories. Kudos to you! You were advocating OSHA’s mission by: Educating your client and their employees on workplace safety by conducting posture and ergonomic assessments, and finding the best ways for workers’ compensation patients to get back to work and continue contributing safely and appropriately within their restrictions.

At the clinic level (can be delegated), your requirements to meet OSHA requirements include:

  • Displaying the required workplace safety and employee rights posters for all employees to review
  • Establishing annual training for yourself and your employees. Local fire departments usually are able to conduct these trainings and are willing to include other participants.
  • Developing a written emergency plan in case of fire, severe weather, etc.
  • Drawing up an exit plan and post for employees and patients to see. See example below:

evacuation map

  • Developing written procedures (universal precautions) to minimize risk exposure to bodily fluids such as blood, vomit, saliva.
  • Obtaining Safety Data Sheets for disinfectants used at the clinic, as well as if you process X-rays.
  • Have handy your Quality Assurance X-ray manual, follow it, and ensure it is accessible to those who take/process X-rays.
  • Ensuring ergonomic workplace assessments are conducted at the clinic and documented. This could include posture screenings for your employees and requiring stretch breaks – for you, too!

Information Technology (IT) Security/HITECH

The Health Information Technology for Economic and Clinical Health (HITECH) Act, enacted as part of HIPAA and the American Recovery and Reinvestment Act of 2009, was signed into law on February 17, 2009, to promote the adoption and meaningful use of health information technology. Section 1176(a) of the Social Security Act was revised during this timeframe to allow for significant monetary penalties up to $1.5 million for breaches/violations of protected health information. However, an interim revision (later known as The Omnibus Rule) set prohibitions on enforcing such significant monetary penalties if it was found in investigation that the covered entity did not know and with the exercise of reasonable diligence would not have known of the violation. In these cases, the breaches were punishable under the lowest tier of penalties, and further, prohibited the imposition of penalties for any violation corrected within a 30-day time period, as long as the violation was not due to willful neglect. A final ruling in January 2013 reiterates all of the above standards.

Your responsibilities to get IT Securities compliant include:

  • Assigning a securities officer
  • Conducting a risk assessment
  • Ensuring your EHR vendor and billing clearinghouse are HITECH/HIPAA compliant
  • Ensuring every vendor you work with has signed a Business Association Agreement with your office and you have those Agreements on file. These need to be updated at least annually.
  • Ensuring the clinic’s computer systems are backed up regularly, have virus-checking software, firewalls, and encrypted operating systems
  • Establishing securities policies and procedures, including on your social media networks.
  • Creating a disaster recovery plan
  • Creating a policy and procedure of notification, in the event of a data leak or leak of PHI/ePHI

Impact of non-compliance? Another covered entity was fined $25,000 for posting patient information online.

Feeling overwhelmed? We can help. Contact me on how you can get an initial Compliance Assessment and a Medicare Documentation Assessment with a Report of Findings sent to you, for a ridiculous low price of $299!*

References:

  • nueMD Cloud-based health information technology, http://www.nuemd.com/webinars
  • HIPAA Journal, http://www.hipaajournal.com/
  • United States Health and Human Services, http://www.hhs.gov/hipaa/
  • United States Occupational Safety and Health Administration, www.osha.gov/
  • Federal Register/Rules and Regulations Publication Vol. 74 No. 209
  • Federal Register/Rules and Regulations Publication Vol. 78 No. 17
  • Emergency Exit Diagram: www.steamwire.com business continuity templates

*Mileage cost may apply.

Medicare in Your Chiropractic Office: Is Your Documentation In Order?

Lisa J. Barnett

Lisa J. Barnett

Have you ever thought you could be both a great documenter and repeatedly educate your patients on their innate intelligence . . . if you only had the time? Keep reading on how to both bulletproof your documentation for a potential audit and maintain the energy of our profession’s principles.

Let’s help build your ammunition.

First . . . did you know that the US Health and Human Services advised Medicare to target chiropractors to curb questionable and inappropriate payments, projected at $280,000,000? Seriously! And clinics are, as I write this, being audited. How do I know? Because we’re receiving phone calls and emails asking, “What do I do? I received a letter from Medicare.” As a result, I’m traveling around to help chiropractic offices prepare.

To insure yourself and what you’ve worked hard for, make sure your documentation (that is, every single note in the patient’s file/your EHR software) is citing the following information:

  • History Obtained at Initial Visit:
    • Symptom(s) causing patient to seek care
    • Family history if relevant
    • Past health history (general health, prior illness, injuries, hospitalizations, surgeries, current medications)
    • Mechanism of trauma
    • Quality and character of symptoms/problem
    • Onset, duration, intensity, frequency, location, radiation of symptoms
    • Aggravating or relieving factors
    • Prior interventions, treatments, medications, secondary complaints
  • Initial Visit or New Onset
    • History (as stated above)
    • Description of the present illness:
      • Mechanism of trauma (how did it happen?) For example, getting out of bed, twisting, gardening.
      • Quality and character of symptoms/problem
      • Onset, duration, intensity, frequency, location, radiation of symptoms
      • Aggravating or relieving factors,
      • Prior interventions, treatments, medications, secondary complaints
      • Symptoms causing patient to seek care. Symptom(s) must be related to the level of the subluxation documented.
    • Evaluation of spine/nervous system through physical examination.
      • PART: pain and tenderness, asymmetry/misalignment, range of motion abnormality, tissue, tone changes
    • Diagnosis: Primary diagnosis must be a subluxation, including the level or identified descriptive term of location, i.e., condition of the spinal joint involved, direction of position assumed by the named bone.
    • Treatment plan, to include the following:
      • Recommended level of care (duration and frequency of visits), specific goals, objective measures to evaluate treatment effectiveness, date of the initial treatment.
      • Though not a documentation requirement, this is where you will educate the patient face to face, as to their subluxation and what will happen if they don’t get it corrected, as well as educate them on their innate intelligence.
  • Subsequent Visits:
    • Review of chief complaint, changes since last visit, systems review if relevant
    • Physical Exam
      • Exam – area of spine involved in diagnosis
      • Assessment of change in patient condition since last visit
      • Evaluation of treatment effectiveness.
      • Though not a documentation requirement, this is a perfect time to re-educate the patient on chiropractic principles.
      • Documentation of the presence or absence of a subluxation
      • PART: pain and tenderness, asymmetry/misalignment, range of motion abnormality, tissue, tone changes
    • Documentation of treatment given on day of visit (technique(s) used and areas adjusted)
    • Progress or lack thereof, related to goals and treatment plan (is the patient meeting goals?)

Let me be clear: The above documentation requirements are not PM&A’s. They are Medicare’s.

Other Tips:

  • Your subjective findings in initial visits/new onsets should tell a story about what happened, how it happened, and when it happened.
  • The Visual Analog Scale (VAS) is not sufficient documentation as your sole objective tool. Use additional tools to measure objectives findings.
  • See below for a typical VAS:

VAS-Lisa

  • You should self-audit your documentation on a regular basis.

In closing, get out there, do what you do best to attract and help anyone with a spine, and follow the above documentation requirements to armor yourself in the event of an audit by Medicare and other payers. Need help staying relaxed and focused, and getting paid? Give us a call. That’s why we’re here.

Sincerely in Chiropractic,
Lisa

Lisa is now providing a no charge initial consultation regarding your Medicare documentation. You can contact at (920) 334-4561 or by email at Lisa (at) @ pmaworks.com

More information on Lisa[LINK]

Download a printable copy of this newsletter [June newsletter]

Download a customizable copy of the Checklist: [Medicare Documentation ChecklistDOC]

Print Checklist (PDF)[Medicare Documentation Checklist-PDF]

 

Medicare Changes: National Government Services LCDs: Effective 12/1/2015

*This notice specifically pertains to those offices where the Provider of Medicare is NGS:  CT, IL, ME, MA, MN, NH, NY, RI, VT, and WI.

 

For those of you who have NGS as their Medicare provider (states listed above), we wanted to make sure you were aware of a new policy which has some big changes, mostly positive and where you could get more information about it.

The NGS(National Government Services) recently published the new Chiropractic Medicare Policy which will go into effect on 12/1/2015

For more information on the chiropractic medicare policy visit:

L66315 Chiropractic Services Policy

Sincerely,
Dave

Anthem Chiropractic Network Reductions

(Wisconsin, April 4) Chiropractors in WI received certified letters from Anthem BCBS announcing that they are initiating a sweeping reduction of their chiropractic provider network to supposedly “right size their provider network as a result of the ACA”.

According to Mr. Dave Michel of Petty, Michel & Associates, if you have one of these letters, you’ll be removed from the BX network on Sept 30 “without cause”, as allowed under your provider agreement.

He says that it looks like they may be targeting larger clinics in each city with higher utilization and also possibly those with a focus towards wellness,and that this doesn’t bode well for their customer base.

Dave mentioned that a similar tactic was used by insurance companies in Massachusetts with the introduction of “Romney-Care” in 2006 and after the hue and cry, chiropractic offices continued to grow. This has also been the case with offices that we have worked with when the doctor was booted from a network – stats go up!

In many cases, the out of network benefits are close to those in network.

Dave has written a letter that you can customize and send to your patients should you get hit by an insurance company claiming they need to “right size.” You can download a copy of this letter as a Word file with the link provided below.

A key to survival is patient education, not only on chiropractic, but also on chiropractic benefits. This is why we stress the Patient Financial Consultation, or the Post Report of Findings.

Lastly,  Dave recommended working together as a group with your state associations and respectfully confronting any insurance company that discriminates against chiropractic services with the facts.  And the facts are that chiropractic care doesn’t cost… it pays.

While you may not practice in Wisconsin, there may be a time when you receive such a letter and if you  do,  these suggestions  can help.

For PM&A clients, if you have received a letter like this, let us know and we’ll work with you on your options.

Sincerely,

Ed

Dave Michel’s Letter to patients: Anthem Termination Letter

ICD-10 Implementation Delayed until 2015 – Chiropractors Breathe a Sigh of Relief

Good Grief!

After all the pressure to get compliant and ready for the new ICD-10, it looks like it will be delayed for another  year.  Again.

According to a report issued by the AHIMA (American Health Information Management Association):

“On behalf of our more than 72,000 members who have prepared for ICD-10 in good faith, AHIMA will seek immediate clarification on a number of technical issues such as the exact length of the delay,” said AHIMA CEO Lynne Thomas Gordon, MBA, RHIA, CAE, FACHE, FAHIMA

Please note the number of capital letters behind Thomas Gordon’s name. This should give us all an idea of how convoluted this process is and will continue to be.

The same article, issued on March  31, 2014 states:

CMS (Centers for Medicare and Medicaid)  has estimated that another one-year delay of ICD-10 would likely cost the industry an additional $1 billion to $6.6 billion on top of the costs already incurred from the previous one-year delay.  This does not include the lost opportunity costs of failing to move to a more effective code set, AHIMA said.

Many coding education programs had switched to teaching only ICD-10 codes to students, hospitals and physician offices had begun moving into the final stages of costly and comprehensive transitions to the new code set—even the CMS and NCHS committee responsible for officially updating the current code set changed the group’s name to the ICD-10-CM/PCS Coordination and Maintenance Committee.

The delay directly impacts at least 25,000 students who have learned to code exclusively in ICD-10 in health information management (HIM) associate and baccalaureate educational programs, AHIMA said in a statement.

The United States remains one of the only developed countries that has not made the transition to ICD-10 or a clinical modification. ICD-10 proponents have called the new code set a more modern, robust, and precise coding system that is essential to fully realizing the benefits of recent investments in electronic health records and maximizing health information exchange. (AHIMA article)

 ICD-10 is not going away. But for those of you who felt that you weren’t going to be ready by the deadline… looks like you have more time to get everyone trained and the systems worked out.

Which is nice!

Stay tuned for more info from your state associations, carriers, and CMS. We will do our best as well to keep you up to date.

Preparation for the September 7 switch to NGS Medicare

This shouldn’t be too big a deal, but there are a couple steps I want to make sure you are on top of. Obviously it would be best if you can attend one of the Wisconsin CSW Medicare seminars (here), but these are the basics:

  1. Make sure you have talked to your billing software company and your clearing house and that you have made any changes needed so that your Medicare claims goes to the correct place as of Monday, September 9.
  2. Do your final billing to WPS Medicare on Friday, September 6. That is the last day you can bill to them. Starting with dates of service September 7 or later, send those to NGS Medicare.
  3. You and the doctors should review the diagnosis that NGS Medicare allows for chiropractic claims. I have heard that there are slight differences, so this all has to be reviewed prior to submitting claims after the switch. Medicare Allowed Diagnosis Codes
  4. The new chiropractic policy for Wisconsin, Minnesota and Illinois is L27350 (here:LCD for Chiropractic Services) and has all the diagnosis allowed. Double check these on your Medicare patients. Any Dx not on this list will be denied.
  5. Doctors need to review all onset dates for all current Medicare patients to make sure that they are under active care, that they have an updated onset, and that documentation is in order (see #4 above).
  6. In order to document your objective goals and functional impairment, I strongly suggest you start using an outcome assessment tool every 30 days with all Medicare patients. In speaking to several clients, they like the Functional Rating Index. It is quick, easy for a Medicare patient, and very fast for the staff to score.
  7. You can find the FRI form for free at http://www.chiroevidence.com/FRI.html. There is a two page version or a one page version.

As always, call me if you have any questions, but these are the minimum basics that we have to be ready to move on.

Best, Dave

Dave Michel Presents “What Chiropractors Can Expect with Obamacare and Other Upcoming Changes”

Mr. Dave Michel is making presentations throughout the state of Wisconsin covering some of the key elements of the Affordable Care Act. He is also discussing other changes that will be affecting reimbursement in the upcoming months.

Dave is a 30 year veteran of practice management and a partner in Petty, Michel & Associates, a practice management company headquartered in WI. He is especially expert in the area of insurance and chiropractic reimbursement.

“I have been doing this a long time and I have never seen the quantity of changes, or the degree to which the changes will be affecting reimbursement as I am seeing now.”

Some of the topics Dave covered included a time line of new forms and policies over the next 14 months. He also gave advice on what offices should do to make the most from the changes. If done right, he said, all these changes can be of help to the office, to the patients, and to the health of the community.

#   #   #

For more information visit/view:

2013-04-18 12.30 Surviving, Striving and Thriving Through the Affordable Care Act(mp3)

Dave’s outline with references for further study and a list of upcoming insurance events and deadlines

Upcoming Medicare and Reimbursement Changes: To Survive and Thrive – You Need to Study and Train

“The illiterate of the 21st century will not be those who cannot read and write, but those who cannot learn, unlearn, and relearn.”  Alvin Toffler

 

I don’t see this discussed much – at least not enough.

It’s called: STUDY.  Study is similar to training, which includes practice, and both require real personal effort and engagement to be effective.

You may want to study more but just don’t feel like you have the time to do so.  It does take time away from other activities. It can be confusing, tedious, and even seem belittling – sitting down and grinding over information, trying to figure out how something works. Practicing and roll playing can seem even worse.

But the return on your investment is worth it.   And nowadays, you have to constantly study just to stay up to date, let alone get ahead.    For example, for those of you in the insurance departments – patient accounts – you have probably had to learn many new things lately. You may have had to upgrade your computer programs for electronic health records. You have had to learn about “meaningful use” and other new terms.

But wait, there’s more!
INSURANCE
I checked in with our resident billing expert, Mr. Dave Michel, and he informs me you have the following headed your way:
  • June: new CMS 1500 claim form
  • July: PQRS implementation
  • Sept 7: WPS to NGS (Medicare administrator change in several Midwest states.)
  • Oct: new ICD 10
  • January major provisions of the PPACA and required EFT and ERA

For those of you in charge of patient reimbursement, you will have to learn about these new programs, train and then get them correctly implemented.  You have many resources from which to learn, including: association seminars and webinars, the CMS website, Chirocode.com, NGS web site for those of you in the Midwest, the PM&A Members website and Facebook page.  There are other resources as well, but the point is that you will have to study, learn, and work it out and get it implemented.

FRONT DESK AND OTHER CLINIC DEPARTMENTS
This also applies to every other job in your office. Each team member should be able to write a book about their department and job within five years and be capable of presenting a full day seminar on what they do to other chiropractic staff.

The front desk should be experts in customer service, sales for scheduling, and excellent in many other skills.  Therapy and rehab staff should know the physiological affect their machines and protocols produce for their patients. They too need to be exceptional at patient education, customer service, and as compassionate as the patient’s mother.

YOU ARE PROFESSIONALS
These are high standards, but you are professionals. You don’t work on an assembly line at the Ford plant. We now live in a networked economy. We have long since passed the Industrial Age, even though most of our management techniques still seem tied back to when “Father Knows Best.”

There is no getting around it, this is a new age. Alvin Toffler, quoted above, wrote about post the Industrial age for business in his book, The Third Wave. The second wave was the Industrial Age – and the third was and is the Information Age.

It is 2013 and your patients are smarter than patients have ever been and expect more.  They know about you before they call you and report on you after they see you so the whole world knows how you treated them.

You have to be better.  You have to study, learn, train.  In a tough economy, patients will go to the best and  bypass the rest. You have to be the best.

A NOTE TO DOCTORS
This apples to you doubly. Beyond the continuing education credits, I suggest you consider challenging yourself to constantly work on improving any and every aspect of your clinical craft like a true artisan. Like a scientist. And like a philosopher.

But you are also a CEO, which includes an entirely different set of skills. As the owner and manager of your business, you need to perfect your skills as a leader, manager, and marketer.  This is so horribly omitted (or perverted) in many programs as to be either laughable or criminal.   Once you do learn these subjects, you can delegate most of them and we can show you how, but you need to learn them nevertheless.

ONE HOUR PER WEEK
Stephen Covey talks about how you have to “sharpen the saw.”  You can cut a tree much faster if the saw is sharp and that sharpening is called training and study.  According to the American Society for Training and Development, since 1991, annual training budgets in the U.S. have grown from $43.2 billion in 1991 to $156 billion in 2011. Obviously, business sees an ever increasing need for training.

Encourage your team to take at least one hour each week to study some aspect relating to their job.   Encourage them to attend seminars and webinars and tele-classes, and have them give a presentation for the entire team at the next team meeting about what they learned.  You can give them a bonus if they give a book report about a book they read in the Lending Library.

YOUR PATIENTS
Lastly, this also applies to your patients. One of the primary functions of your office should be the training and education of your patients.  They need to take responsibility for their own health and in order to do this – they need to know what you know.  Regular care classes, a “lending library” and of course, warm “table talk” by doctor and staff help.

***SPECIAL TEAM TRAINING TELECLASS WITH PHYLLIS FRASE AND DANA PITTNER TUESDAY, MAY 21, 

12:30pm – 1:30pm CDT – “Dialogues and Dilemmas

Take time this Tuesday to listen to these dynamic ladies discuss solutions to the 10 most common conversations staff often gets stuck on with patients.

Learn how your staff can share and educate your patients on the chiropractic lifestyle.  What you can say at the front desk, in therapy, financials, etc.

There is no charge for this teleclass. For active PM&A members, you will find it on you Members site in a few days just in case you missed it.

Affordable Care Act and Chiropractic: A Teleclass with Dave Michel

What is the Affordable Care Act and how will it affect you, your chiropractic business, and your patients?

In this timely teleclass, Mr. Dave Michel outlines the basics of the ACA and demystifies it’s myths and complexities.

Learn how it can affect you and your patients.

Ordinarily reserved for our Members Only confidential site,  we are making this teleclass broadly available for listening and download since this is such an important and timely topic,

 You can listen or down in two formats for your convenience: MP3 or WAV.

2013-04-18 12.30 Surviving, Striving and Thriving Through the Affordable Care Act – 50 minutes (mp3)

2013-04-18 12.30 Surviving, Striving and Thriving Through the Affordable Care Act – 50 minutes. (wav)

 

Chiropractic Maintenance Care: Medicare Settlement Means No More “Improve or You’re Out”

In what could be a landmark decision for chiropractors that have long asserted that regular chiropractic care for seniors with chronic conditions actually saves Medicare money and keeps seniors active and independent, an agreement has been reached.

A Federal Judge has approved the proposed Settlement Agreement in the Medicare Improvement Standard case, Jimmo vs. Sebelius, [Link] clearing the way for thousands of Medicare beneficiaries to receive needed health services to maintain their current level of functioning. While not specifically aimed at chiropractic, the exciting implications remain.

The settlement, which represents a significant change in Medicare coverage rules, ends Medicare’s longstanding practice of requiring people to show a likelihood of improvement in order to receive coverage of skilled care and therapy services. It specifically pertains to “…those with disabilities or suffering from chronic illnesses such as Alzheimer’s disease, Parkinson’s disease, ALS, lung disease.” (ital added)

The Agreement, which is retroactive to the date of the suit was filed, January 18, 2011, includes skilled services covered by Medicare Part A and Part B, such as speech, occupational and physical therapy, nursing and home health services, even when the goal is maintaining the patient’s current condition rather than requiring that the patient improving.

The Medicare law has never supported the “”improvement standard.” Nevertheless, for decades beneficiaries have been denied needed services because they are not improving or have “reach a plateau”, sometimes with devastating results. The Center for Medicare Advocacy says providing maintenance services will save money in the long run, preventing decline, hospitalizations and need for more expensive services.

The official approval of the settlement means the Center for Medicare and Medicaid Services (CMS) must develop and implement an education campaign to ensure that Medicare providers are not denying coverage for vital maintenance services to those with any chronic illness who meet other qualifying Medicare requirements.

The “maintenance standard” is effective immediately. Importantly, this does NOT change anything at this time for you, your documentation, or your patients. Even though we have not seen the official documentation that Chiropractic Maintenance Care is included in this settlement, we are hopeful and following this closely.

More Info:
http://blog.aarp.org/2013/02/06/amy-goyer-medicare-pays-for-skilled-therapy-for-maintenance-with-chronic-illness/

New Medicare ABN Form for Chiropractic Offices

Below you can find a link to a  sample version (in pdf)  of the new Medicare ABN Form that all offices must use starting January 1, 2012. Please download, review, edit name & address, and have your Medicare patients complete this form starting Monday.

If you have questions, see below. I tried to answer them the best I could, but contact me if you are unsure.
Thanks, and Happy New Year!
Dave

NEW MEDICARE ABN FORM – PDF

What is an ABN Form?

“The ABN is a notice given to Medicare beneficiaries to let them know that Medicare is not likely to provide coverage in a specific case. The patient must complete the ABN as described below before providing the items or services that are the subject of the notice.”

What do we need to do with this form?

First, you must put in your clinic name, address and phone number on the form. This is Medicare’s requirement. Have each Medicare patient review the form, check one of the three options, and sign the form. Keep a copy in the patient’s chart for the most current course of treatment.

Why are exams, xrays and therapies noted on the form?

The ABN can be used for both covered, but not medically necessary services (such as a wellness adjustment billed without the –AT modifier) or for non-covered services. Adding non-covered services, such as therapies or exams, helps Medicare patients better understand what will and won’t be paid.

Why is the “Estimated Cost” line left blank?

Because this will vary depending on what you are doing with the patient, whether the patient has a secondary, supplement, or alternative financial agreement with your office. This will be different for different patients. You can either estimate a “per visit” cost or the total cost for care. (per page 4, Form Instructions, ABN).

Please get rid of your older, blank ABN forms. More Questions? Ask Dave!