May 23, 2013 | Uncategorized
Bringing down health care costs is a top priority. That’s why the Affordable Care Act contained an historic set of reforms designed to reward higher quality and lower the cost of care. And we know that the best way to do that is the same way leading health care organizations do it: by making care better and more efficient.nnWe also know there are great ideas out there that can help push this work forward and that the kinds of innovative practices that make our health care system work better for everybody can come from any corner of the country. That’s why today we’re launching a $1 billion initiative through a second round of Health Care Innovation Awards.nnThese Innovation Awards will be given to organizations whose creative solutions to our most pressing health care challenges have the potential to serve as models for improving care and lowering costs across the country.nnIn November of 2011, we launched our first round of Health Care Innovation Awards by issuing a challenge to America’s health care providers, businesses, universities, and community groups. We asked them to submit their proposals for how to get the most out of our health care dollars by delivering better care. That challenge resulted in more than 3,000 applications, from which a team of independent experts and HHS officials selected 107 promising innovations with the strongest likelihood of creating larger-scale, sustainable results.nnAnd as we kick off round two of the Innovation Awards today, we’re already seeing encouraging results from a number of our round one recipients. The University of Miami, for example, is transforming school-based health clinics into medical homes to serve vulnerable children. These medical homes are connected to community health care providers and these children are already receiving tele-health consults for dermatology, psychiatry, and nutrition along with dental care.nnAnother recipient, Christiana Care Health Services, has used advanced data analytics to improve preventive care for patients with heart disease. Their comprehensive electronic registry allows providers to more quickly and accurately assess patients’ symptoms and needs based on similar occurrences in the past. This smarter preventive care doesn’t just prevent tragedies before they happen—it also saves money on hospital visits.nnAs with last year’s awards, we’re seeking out innovative practices that have a high likelihood of delivering better care and lower costs on a national scale. The last few years have seen us make tremendous strides towards keeping health care spending in check, and a lot of that is thanks to innovations that have helped improve the quality and efficiency of care delivery and payment systems.nnAcross the country, private and public sector innovators are developing even more great ideas to improve our health care system. And today’s announcement will allow us to take some of the most promising innovations and put them into action for the benefit of all Americans. That’s good news for patients, for providers, for our economy, and for the future of American health care.nnMore information is available here.nnSource: www.cms.gov; Rick Gilifillan; May 15, 2013.
May 13, 2013 | Uncategorized
Allergic Rhinitis due to Pollen — J30.1nnPoison Ivy: Allergic Dermatitis due to plants — L23.7nnBee Sting, accidental, initial encounter — T63.441AnnPoisoning, Larkspur, accidental, initial encounter — T62.2X1AnnAccident caused by contact with garden tool, initial encounter — W27.1xxAnn nnIn preparation for the upcoming deadline for ICD-10 implementation, Welter Healthcare Partners presents weekly ICD-10 Codes of the Week! Our goal is to familiarize you with the new and expanded code set and the additional clinical documentation needed from your providers to comply with ICD-10 coding, and more importantly, for accurate and clean claims submission to keep your revenue stream flowing! We are to help YOU prepare for the October 1, 2014 implementation date. Please don’t hesitate to contact us for all of your training and education needs!
May 13, 2013 | Uncategorized
nnA recent incomplete CMS listing is raising concerns, as the state of Colorado is missing from the listing annltogether, and this leaves no way for providers to check to see if they are due for revalidation. Welter Healthcare Partners works with over 150 providers and has had providers whose PTANs have been deactivated due to non-response to the revalidation request. Representatives at Novitas have stated that they are receiving many phone calls on this concern, and that they have escalated it from the inside. They have further stated that this issue is being addressed at each staff meeting, there has not been a definitive resolution presented. If you have any questions, or need any assistance with this process, contact us today.n
Medicare is continuing their efforts to revalidate ALL Medicare providers! There are 2 years left in their intended timeframe.
nYou will be receiving a notification letter (letters being mailed between late 2011 & March 2015). You (the provider) only have 60 days to complete and submit the proper forms that must be completed. The process is/was to be suspended until after completion of the new MAC transition. However, if you do/did receive a revalidation notice, don’t ignore it! PTANs will be deactivated if forms are not received and processed, which means your payments will stop!nnIf you need assistance, please don’t hesitate to contact Welter Healthcare Partners’s dedicated credentialing department at 303.534.0388.nnSection 6401 (a) of the Affordable Care Act established a requirement for all enrolled providers and suppliers to revalidate their enrollment information under new enrollment screening criteria. This revalidation effort applies to those providers and suppliers that were enrolled prior to March 25, 2011. Newly enrolled providers and suppliers that submitted their enrollment applications to CMS on or after March 25, 2011, are not impacted. Between now and March 23, 2015, MACs will send out notices on a regular basis to begin the revalidation process for each provider and supplier. Providers and suppliers must wait to submit the revalidation only after being asked by their MAC to do so. Please note that 42 CFR 424.515(d) provides CMS the authority to conduct these off-cycle revalidationsnnWere you sent a Medicare revalidation request?nnIn the “Downloads” section (found here) is a listing of all providers and suppliers who have been mailed a revalidation notice. The files are broken down by the month in which the revalidation request was mailed. CMS will add lists on a bimonthly basis. If you are listed, and have not received the request, please contact your Medicare contractor. Their contact information can be found in the Downloads section, herennWould you like to learn more?nnIn the “Related Links Inside CMS” section, here, you will find the transcript of the October 27, 2011 National Provider Call about the Revalidation of Medicare Enrollment. You will also find helpful articles about the revalidation process, enrollment provisions of the Affordable Care Act and how to pay your enrollment application fee.nnStill have questions?nnQuestions concerning provider enrollment policy or your provider’s situation should be referred to your MAC. Their contact information can be found in the “Downloads” section below. Questions concerning a system issue regarding PECOS should be referred to the CMS EUS Help Desk at 1-866-484-8049, or send an e-mail to EUSSupport@cgi.com.nnSource: www.cms.gov; April 15, 2013.
May 3, 2013 | Uncategorized
While most hospital leaders see the advantages of moving to bundled payments for an episode of care, many are unprepared either for the mindset or the mechanics required to implement the emerging reimbursement model. Here are the concerns and possible strategies you should consider. n
FRAMING THE ISSUE
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- Momentum is building to replace the fee-for-service payment system with one that emphasizes value over volume. Bundled payment is one strategy being tested by hospitals around the nation.
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- Bundled payments require hospitals to align incentives by contracting with physicians and to share risk. But many providers are not yet ready to determine a fixed cost for an episode of care.
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- Hospitals will need historical data on care for patients with similar medical situations as well as analytical data on what to pay individual clinicians.
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- Early adoption of bundled payment may be an advantage for hospitals by solidifying their place in the market and attracting docs and insurers.
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nAt Geisinger Heart Institute in Bloomsburg, Pa., unraveling the mysteries of bundled payment was a breeze compared with what other health care organizations will face. The institute has offered bundled payments for cardiac surgery since 2005, and Alfred Casale, M.D., who is chairman of surgery and co-director of the cardiovascular service line, says establishing the process was relatively painless because the organization employed the cardiologists and other clinicians involved, and because Geisinger Health Plan owned the hospital and had a robust electronic health record system.nnFor most hospital leaders, setting a bundled price on an episode of patient care will be much more complex. Administrators and their physician partners must collect reams of patient data, spend hours identifying best practices and develop teams of clinicians to run these programs. Unlike Geisinger Heart Institute, they are likely to contract with physicians they may or may not employ and work with health plans with which they are otherwise unaffiliated. For everyone, including Casale’s organization, bundled payment represents a different way of thinking and poses significant challenges.nn[vc_toggle title=”Aligning Financial Incentives” size=”sm” el_id=””]Hospitals and health systems have several reasons to pursue bundled payment. For one, the Centers for Medicare & Medicaid Services support the approach, approving more than 500 organizations for its Bundled Payments for Care Improvement initiative in January. Other hospitals want to replace fee-for-service payment and move toward full-risk contracting. Still others see an opportunity to align incentives by contracting with physicians and health plans so that all parties are working to improve care quality, eliminate unwarranted variation and lower costs.nn”Bundles facilitate the alignment of incentives for providers to work together across the continuum of care, resulting in the collaboration of partners across all specialties and settings to maximize quality and efficient care,” says Mike O’Boyle, president and CEO, Parallon Business Solutions, a consulting firm. “For those hospitals and physicians that have not had experience with population health, bundled payments are mechanisms to allow for their evolution into shared-risk arrangements.”nnUnder bundled payment, a hospital and physicians assume the financial risk for delivering all care for one price for one patient episode over a set period — usually 30, 60, 90 or 120 days. Most bundled payment programs today are for acute care episodes, such as hip or knee replacement or spine or cardiac surgery. Some health plans are making bundled payments to providers for patients with asthma, diabetes, cancer and other chronic conditions. In these cases, the episode of care is usually for one year.nn”Bundled payments are incredibly effective in transforming care because they focus providers on areas where there are unwarranted variations and realizable savings,” says Jay Sultan, associate vice president and general manager of payment reform at the TriZetto Group, a consulting firm. “Bundled payment brings alignment with physicians that allows hospitals to cut their variable costs and reduce postsurgical complications, pharmacy costs and length of stay.”nnManaging the financial risk is the key challenge of bundled payment because hospitals and physicians guarantee to deliver all services for each patient’s full episode of care, including any complications. In this way, bundled payment comes with a guarantee: The physicians and hospitals cover the costs of postsurgical infections or the need for rework or a readmission.nn”If a hospital and the physicians are unable to successfully work together to reduce the average cost of the episode, they would be at risk for those costs above the negotiated budget,” O’Boyle explains.[/vc_toggle]nn[vc_toggle title=”Working Through Uncertainty” size=”sm” el_id=””]n
The at-risk nature of bundled payment may leave hospital administrators feeling somewhat unsure about how to proceed, as Casale did in 2005. “We were preparing a presentation for the board of directors about bundled payment, which Geisinger calls ProvenCare,” he says. “We decided to offer one price for a package of services to include everything from the first office visit through the surgery and for 90 days postsurgery.”nnInstitute leaders had two and a half years of data that showed what GHP paid for coronary artery bypass grafts. They also knew that related complications tended to occur within four weeks of the operation and that by 90 days, 99 percent of all complications had occurred. That’s why they set the episode duration at 90 days.nn”Then we had to set a price,” Casale says. “We had never done this and our presentation was the next day. There was no calculus or even any science involved. We just took the average cost and decided to charge half. At the board meeting the next morning, we said, ‘Give us half of the average charges in a package price and we’ll immunize you for the cost of care for any related complications at a Geisinger facility for 90 days.’ “nnSince then, the program has worked so well that it was cited as an example of the effective use of evidence-based protocols in the Institute of Medicine’s report, Best Care at Lower Cost: The Path to Continuously Learning Health Care in America, published last September. The report shows that Geisinger cut operative mortality by 67 percent and length of stay by 1.3 days. Revenue minus expenses improved by more than $1,900 per case and the cost per case dropped by 4.8 percent. Also, GHP had a 23 percent increase in profit for each episode of cardiac care, the IOM reports.nnAlthough the results are dramatic and demonstrate how physicians armed with data and a willingness to assume risk can effect change, Geisinger is not representative of the kinds of bundled payment arrangements hospitals typically make with physicians and health plans. Health plans are unlikely to send unaffiliated hospitals the data they need on costs and complications. Without that data, hospitals may find it difficult to analyze past expenses because most hospitals do not have a true understanding of the cost of episodes of care, O’Boyle says.[/toggle]nn[vc_toggle title=”Spreadsheets Required” size=”sm” el_id=””]n
“Many hospitals have yet to determine the best process to allocate fixed costs to an episode to determine a fully loaded cost per episode,” O’Boyle says. “Most hospitals will need to undertake a process like activity-based costing to understand their costs per episode. That costing process will need to include all care providers and settings, which can be cumbersome and time-consuming.”nnMost hospitals have not changed their revenue-cycle management process for many years and have systems that are not designed for bundled payment, says Shannon Dauchot, Parallon’s senior vice president of corporate operations and client relations. Most payers don’t have the systems they need to make bundled payment work either. “That means hospitals might have to use spreadsheets to collect all the numbers they’ll need,” she says. “By starting small, they can sort through each bundle until they figure out what can be automated. But we’re not aware of a one-size-fits-all system that does all that because every bundle and every group of providers will be different.”nnIndeed, when collecting the data it needed for bundled payments for hip and knee replacements, Crozer-Keystone Health System used spreadsheets.nn”We spent an incredible amount of time and resources looking at financial modeling and getting people to help us do the modeling for bundled payment,” says Susan L. Williams, M.D., Crozer-Keystone’s senior physician for clinical integration. “Starting in 2008, our strategy was to build primary care around patient-centered medical homes, and so we had a fair amount of experience with collecting the data and building the data systems required to pull out quality metrics on individual physicians or physician groups for bundled payment. And, our finance people are great at calculating costs. But marrying all the data on costs and quality has been a journey.”nnElizabeth Jaekle, Crozer-Keystone’s vice president for business development, agreed. “There is a level of nuance that we had not counted on with bundled payment,” she says. “Our cost accounting system was not set up to facilitate bundled payment or any kind of gainsharing because it collected data in aggregate and averages, which is fine for most of the work we do. But when you’re compensating for quality improvement, you need to measure the rate of change and differentials at an actual point in time.”nnMost cost accounting and information systems are not oriented to measure and report such data. “So, first we had to use spreadsheets to collect what we needed and then we put the data into various working documents that we could evaluate,” Jaekle adds. “From there, you can start to put together the infrastructure to automate these systems.”nnOvercoming these hurdles helped Crozer-Keystone learn enough that CMS approved its application in January to implement bundles for hip and knee replacements under the BPCI.nnHospitals also face challenges in collecting data on each provider who will deliver care in a bundle, says Joseph J. Fifer. Before he became president and CEO of the Healthcare Financial Management Association last June, Fifer was vice president of hospital finance at Spectrum Health in Grand Rapids, Mich., where he implemented four bundled payment programs.nn”Collecting all the data elements that span across multiple providers might be a bigger hurdle to clear than the accounting issues,” he says. “There aren’t any systems today that can easily gather data on a patient-specific basis and that span the entire episode of care from the first primary care visit to the last exam. By its nature, bundled payment covers everything, meaning you have to include costs for post-acute care, rehabilitation and physical therapy.”nnHaving the data on costs and quality is critical to the success of a bundled payment initiative, agrees James T. Caillouette, M.D., surgeon-in-chief at Hoag Orthopedic Institute in Irvine, Calif. Hoag has a bundled payment program for hip and knee replacement surgery. “The key to success or failure hinges on alignment with the participating physicians,” he says. “Everyone needs full cost transparency because you are going to be accountable for the cost of care in a way that you have never before been accountable. Typically, this kind of accountability is difficult because hospitals and health plans are not readily going to share their costs with physicians and other providers.”nnBefore allowing its doctors to participate in the bundled payment program, Hoag examines physicians’ past results. “We’re looking for costs, infection rates, outcomes and the reasons behind any readmissions. You have to set the bar high because those who can achieve that bar will participate in the bundle and those who haven’t achieved that bar need to work toward it so they can participate,” Caillouette says.nnFor Hoag, gathering information on its physicians is relatively easy because the institute is a collaboration between the orthopedic physicians and Hoag Memorial Hospital Presbyterian.nnWhen separate entities develop bundled payment initiatives, collecting information from outside providers can be difficult, says Caroline Steinberg, vice president of trends analysis for the American Hospital Association. “Hospitals have never had any information on what happens to patients outside their doors,” she explains. “There are a lot of tricky issues with bundled payment because hospitals have never taken on responsibility for care across the continuum.”nnNot only does the hospital need historical data on care for similar patients so that it can decide what to charge, it also needs to know how much to pay each individual physician and other clinicians delivering care in the bundle.nnCollecting that data for each episode of care is just part of the solution. “The real trick to make bundled payment work is that information must be readily available to the various providers on a need-to-know basis virtually in real time as opposed to what we have now,” Fifer says. “You’re pricing based on last year’s numbers but you’re doing the surgery this year and paying out on this year’s numbers. Making all the data available in real time today is a huge challenge.”[/vc_toggle]nn[vc_toggle title=”Fewer Heads In Beds” size=”sm” el_id=””]nOnce a hospital standardizes care and cuts lengths of stay, it could create a new problem: reduced revenue. That’s leading some observers to question whether bundled payment works against a hospital’s best interests. “If we go down this path in any material way, what does that mean about how many beds we need?” Fifer asks. “What does it mean for the pure existence of many hospitals, especially those in small, rural communities?”nnBecoming an early adopter may be one answer. “The hospitals that are the first movers get an advantage by seizing the opportunity to acquire volume,” TriZetto’s Sultan says. “Bundles for cardiac or orthopedic surgery can be the most profitable cases in hospitals, making them crucial for hospital success. Plus, getting a higher fee in a bundled payment is a profound financial incentive for surgeons to refer patients.”nnEarly adoption has another advantage. “Bundled payment not only allows hospitals to transform the delivery of care, but also to solidify their place in the market,” Sultan says. “Once the program is running smoothly, other physicians, such as oncologists, will want to develop bundles. And health plans may start coming to you as well.”nnJoseph Burns is a freelancer writer in Falmouth, Mass., specializing in health care strategies.[/vc_toggle]nn
nn[vc_toggle title=”How Bundled Payment Differs From Global Payment” size=”sm” el_id=””]nnBoth bundled and global payment systems provide financial incentives for hospitals and physicians to deliver better care and control costs. Though similar, the two forms of reimbursement differ in significant ways.nnBundled payment is for a specific set of services, such as an episode of care for hip or knee replacement or all services for one year of care for a patient with asthma or diabetes. A hospital and physicians would work together to care for a health plan’s patients and may share in any savings if costs are lower than a specified target. The providers also are required to care for patients who have complications during the episode of care, usually 30 to 120 days for acute conditions or a full year for chronic care.nnGlobal payment, also called capitation, is for all care for a patient for a month or a year. Physicians are responsible for all primary care to these patients and may share in any savings at year end. Hospital and specialist care may or may not be included in the global budget.nnFor Blue Cross Blue Shield of Massachusetts, choosing bundled or global payment hinged on the willingness of physicians to accept financial risk, says Deborah Devaux, senior vice president of network & service integration. “We’ve seen how the various bundled payment approaches are being implemented. But for acute conditions, we already pay a fee based on diagnosis-related groups, which is a form of bundled payment,” Devaux explains. “For surgery, we also pay a DRG.”nnUnder its global payment initiative, called the Alternative Quality Contract, BCBSMA pays provder organizations for all care delivered to a patient for a year. Physicians can share any bonuses with the affiliated hospitals, Devaux says. She believes the AQC allows the Blues plan to control costs more closely than it could under bundled payment while also providing an incentive for quality improvement.nn”The AQC creates an environment where hospital administrators have to consider how to support physicians in avoiding unnecessary admissions, readmissions and emergency room visits,” she says.nnPlus, for patients with multiple chronic conditions, bundled payments may require multiple bundles, which can be confusing and may lead to global payment anyway, she adds.[/vc_toggle]nn
nn[vc_toggle title=”Physician–Hospital Integration Is Key” size=”sm” el_id=””]nn[toggle title_open=”” title_closed=”Physician–Hospital Integration Is Key” hide=”yes” border=”yes” style=”default” excerpt_length=”0″ read_more_text=”Read More” read_less_text=”Read Less” include_excerpt_html=”no”]When contracting for bundled payment, Blue Cross and Blue Shield of Florida closely examines the legal entities in its bundled payment contracts, says Andy Marino, the health plan’s vice president of network development.nnSince March 2011, Florida Blue has had a bundled payment program for laparoscopic radical prostatectomy surgery with Mobile Surgery International and two bundled payment programs for knee replacements. One is with the Mayo Clinic and one is with the Florida Orthopaedic Institute.nn”It’s easy for us to contract with the Mayo Clinic because Mayo’s physicians and the hospital facility are fully integrated,” he explains. Florida Orthopaedic Institute is similar in that it employs anesthesiologists and has an outpatient surgery center. “Therefore, it can bring the facility component all under one tax identification number,” Marino says.nnAlthough hospitals have asked Florida Blue about bundled payment, not all are ready to do so. “A hospital needs to be able to take a lump sum payment and then pay some of those dollars to the surgeon and everyone else involved in the care,” he explains. “But if they don’t have the legal structure to do that, then it creates problems for us.”[/vc_toggle]nn
nn[vc_toggle title=”Report Outlines Steps For Facilities Adopting Bundled Payment” size=”sm” el_id=””]nn[toggle title_open=”” title_closed=”Report Outlines Steps For Facilities Adopting Bundled Payment” hide=”yes” border=”yes” style=”default” excerpt_length=”0″ read_more_text=”Read More” read_less_text=”Read Less” include_excerpt_html=”no”]
A January issue brief from the American Hospital Association, Moving Towards Bundled Payment, explains the steps hospitals and health systems would take to develop such programs. By examining how to define an episode of care and how to evaluate the distribution of costs across service lines, the brief offers a starting point and guide for hospital administrators in how to manage costs, risk and unwarranted variation.nn”Understanding where the costs are concentrated helps identify where cost-reduction opportunities are likely to be found and where partnerships with other providers or specific types of interventions may be most important,” the brief states.nn”Bundled payment comes down to the opportunity to improve quality and efficiency,” says the report’s author, Maulik S. Joshi, Dr.P.H. President of the Health Research & Educational Trust and senior vice president of research at the American Hospital Association, Joshi calls bundled payment a vehicle to manage financial risk and care across various care delivery settings. “The triggers that allow bundled payment to succeed are improved quality and improved efficiency. As a natural artifact of those two aims, you have to address unwarranted variation and you have to address care coordination,” he says. Bundled payment also gives hospital administrators a new and perhaps more complete view of the full continuum of care than they normally have. “The fact that hospitals have not looked at the continuum of care is not a knock on hospitals. It’s just a reality,” Joshi comments.nnAnother issue that may be new to hospital administrators is the link between risk and high levels of unwarranted variation. “The ability to identify, understand and eliminate variation in care practices will be critical to success under bundled payment,” the report adds. Hospitals that measure variations in cost may be better able to manage risk. For example, the report shows how the difference in costs between the 25th and 75th percentile (the interquartile range) for a percutaneous cardiovascular procedure with drug-eluting stent is approximately $3,251, or about 28 percent of the median episode cost. But the same difference in costs for chronic obstructive pulmonary disease is about $3,884, or 80 percent of the median episode cost. Administrators may want to select episode types that have enough variation to provide opportunities for cost-reduction, but not so much variation that they pose excessive risk to the organization. “We are still early in our ability to measure risk,” Joshi explains. “Therefore, maybe it’s better to figure out why the variation is so high rather than put it into a bundled payment program.”[/vc_toggle]nnSource: www.hhnmag.com; Joseph Burns; April 4, 2013.
Apr 22, 2013 | Uncategorized
With the news that CMS has started conducting pre-payment audits to monitor meaningful use payments, some providers have been worried about what it means if they get a letter in the mail. Below, Rob Anthony, Deputy Director of the HIT Initiatives Group, Office of E-Health Standards and Services at CMS, discusses how CMS is handling its EHR audits of potential meaningful users, and to give some tips to providers about what to have on hand if an auditor comes knocking on the door.nn[vc_toggle title=”What’s the purpose of meaningful use audits, and how do they help CMS and providers?” size=”sm” el_id=””]As a government agency, we do an audit for anything where we’re disbursing funds. We obviously want to be sure that the right people are getting paid who should get paid, and that people have done what they said they did. So we take the oversight of the payment pretty seriously, and a robust audit program is really an essential component of that oversight. And really, the purpose of the audits is partially to detect inaccuracies in things like eligibility or reporting and payment information, ensuring that the providers who are participating in the Medicare EHR Incentive Program are only receiving payment if they successfully demonstrated meaningful use and met the other program requirements.nnBut also, as we’re moving into years where the payment adjustments take effect, we’re moving into a time where providers, if they’re not meaningful users, will receive payment adjustments. So we want to ensure that, as we move forward, everybody who is actually attesting to meaningful use is really a meaningful user so that they can avoid those adjustments moving forward. Incentives are great, but we want to make sure that people aren’t subject to those payment adjustments when they don’t have to be.[/vc_toggle]nn[vc_toggle title=”The OIG made some strong recommendations last year about how CMS should improve their oversight of EHR Incentive Payments. How are you addressing these concerns?” size=”sm” el_id=””]We’ve instituted the pre-payment audit program, after initially only doing post-payment audits. It should be noted that at the time the OIG report was initially compiled, we really were at the very beginning of our audit program. We were really just establishing the audit protocols that we use to determine what documentation to ask for, what to look for, and how we go out and talk to providers, so we really didn’t have a developed audit program at the time those recommendations were released. As we have moved forward, I think that we have been able to really figure it out.nnWe do both random and targeted audits, and we’ve figured out the type of things that are anomalous and raise a red flag for us to start taking a look at, so that allows us to be much more robust in our oversight. And now, with the introduction in January of the pre-payment audits, we’re doing that random and targeted check of providers to look at their attestation before they actually receive payments. We think that appropriately addresses the OIG recommendations.[/vc_toggle]nn[vc_toggle title=”What are some of the things you look for, and how can providers satisfy the audit requirements?” size=”sm” el_id=””]nnWe can’t really tell you exactly what we’re looking at, because it’s an audit program. But I can tell you one of the primary areas to look at is documentation. This is an attestation program, and when we come to look at someone, we want to see that they have documentation that supports the attestation information that they entered. And that’s why we’ve released the documentation guide on our website that goes through each of the objectives and gives a suggested documentation example, whether that’s a screenshot from a certified EHR system that’s dated, or whether it’s a report for your clinical quality measurements.nnMake sure you have that type of documentation on hand. I always tell people that when you go through and attest, not everybody’s system is able to provide a snapshot in time. Not everybody’s system is able to go back to the date you attested and show what the data looks like. They may have a system that has rolling data, which means that information that you’ve entered long after the close of the reporting period could actually affect the measurement that your system does when you make a subsequent report. So I always suggest that providers make a print or electronic copy of the actual report that they used for attestation so they can show those numbers when an auditor requests supporting documentation.nnThe other area that I can say where there’s great confusion is the security risk analysis. We always suggest they make sure they know what they have to do as part of a security risk analysis with their EHR system. A lot of people don’t realize that analysis is the same type of thing that they should be doing under HIPAA for all privacy and security. This one is just specific to their EHR system. So familiarize yourself with those HIPAA requirements, make sure you have some type of security risk analysis specific to your EHR, and be sure it’s dated. And be sure that if you have not been able to address all of the concerns raised in the risk analysis, that you at least have a plan to address those concerns.[/vc_toggle]nn[vc_toggle title=”What advice do you have for providers who might be nervous about the audit process?” size=”sm” el_id=””]nnI’ve talked to several vendors and consultants, and they tell their clients this same thing: make sure that you enter the accurate information. Make sure that you have the documentation to support it. If you have those things, then you’re a meaningful user, and you don’t have anything to worry about. This is one of those areas where prevention is truly the best way to address this. So just make sure that you have the documentation ahead of time. The information we’ve put out on supporting documentation is a great place to find out what you need and what has to be there. Make sure everything is dated and that it specifically shows that it’s for you. You should have your NPI or provider name to show that this is evidence that supports your EHR system.[/vc_toggle]nnSource: www.ehrintelligence.com; Jennifer Bresnick; April 15, 2013.
Cerveza intoxication, uncomplicated — F10.120nnMontezuma’s revenge, bad tacos: T62.8X1A – Toxic effect of other specified noxious substances eaten as food, accidental, initial encounternnInjury due to falling piñata: W20.8xxA — Struck by falling object, initial encounternn nn[hr]nnIn preparation for the upcoming deadline for ICD-10 implementation, Welter Healthcare Partners presents weekly ICD-10 Codes of the Week! Our goal is to familiarize you with the new and expanded code set and the additional clinical documentation needed from your providers to comply with ICD-10 coding, and more importantly, for accurate and clean claims submission to keep your revenue stream flowing! We are to help YOU prepare for the October 1, 2014 implementation date. Please don’t hesitate to