G56.01 — Carpal tunnel syndrome, right upper limbnnG56.02 — Carpal tunnel syndrome, left upper limbnnZ57.8 — Occupational exposure to other risk factorsnnZ56.6 — Other physical and mental strain related to worknnY92.531 — Health care provider office as the place of occurrence of the external cause
The Centers for Medicare & Medicaid Services (CMS) has published a final rule that requires Medicare Parts A and B health care providers and suppliers to report and return overpayments by the later of the date that is 60 days after the date an overpayment was identified, or the due date of any corresponding cost report, if applicable. A separate final rule was published in the May 23, 2014 Federal Register (79 FR 29844) that addresses Medicare Parts C and D overpayments.nnSummarynThe requirements in this rule are meant to support compliance with applicable statutes, promote the furnishing of high quality care, and to protect the Medicare Trust Funds against improper payments, including fraudulent payment. This rule clarifies requirements for the reporting and returning of self identified overpayments. Health care providers and suppliers have been and will remain subject to the statutory requirements found in section 1128J(d) of the Social Security Act (the Act) and could face potential False Claims Act (FCA) liability, Civil Monetary Penalties Law (CMPL) liability, and exclusion from federal health care programs for failure to report and return an overpayment. Health care providers and suppliers will also continue to be required to comply with current CMS procedures when we, or our contractors, determine an overpayment exists and issue a demand letter.nnBackgroundnSection 6402(a) of the Affordable Care Act established a new section 1128J(d) of the Act. Section 1128J(d)(1) of the Act requires a person who has received an overpayment to report and return the overpayment to the Secretary, the state, an intermediary, a carrier, or a contractor, as appropriate, at the correct address, and to notify the Secretary, state, intermediary, carrier, or contractor to whom the overpayment was returned in writing of the reason for the overpayment. Section 1128J(d)(2) of the Act requires that an overpayment be reported and returned by the later of: (A) the date which is 60 days after the date on which the overpayment was identified; or (B) the date any corresponding cost report is due, if applicable. Section 1128J(d)(3) of the Act specifies that any overpayment retained by a person after the deadline for reporting and returning an overpayment is an obligation (as defined in 31 U.S.C. 3729(b)(3)) for purposes of 31 U.S.C. 3729. In the February 16, 2012 Federal Register (77 FR 9179),nnCMS published a proposed rule to implement the provisions of section 1128J(d) of the Act for Medicare Parts A and B providers and suppliers.nnMajor ProvisionsnThe major provisions of this final rule include clarifications around: the meaning of overpayment identification; the required lookback period for overpayment identification; and the methods available for reporting and returning identified overpayments to CMS.n
On Jan. 22, 2016, CMS issued a new application and sweeping changes to the Medicare Electronic Health Records (EHR) Incentive Program hardship exception application process. The changes are intended to temporarily ease the burden on providers seeking exemption from the 2017 Medicare meaningful use payment adjustments.nnHighlights of CMS’ guidance include:n
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nThe revised application and instructions, which are both accessible here, implement the Patient Access and Medicare Protection Act, Pub. L. No. 114-115 (Dec. 28, 2015) (PAMPA). PAMPA was passed in the last days of 2015 in the wake of provider frustration created by repeated revisions to the meaningful use criteria and CMS’ delayed release of the Stage 2 Meaningful Use Program Final Rule1 (Final Rule). CMS did not release the Final Rule until early October 2015. Consequently, eligible professionals (physicians and others subject to meaningful use as eligible professionals (EPs)) and qualifying hospitals were left with less than 90 days before year’s end to digest, implement, and attest to meeting the revised program’s criteria; yet, the Final Rule called for a 90 day data reporting period. Many EPs and hospitals also had trouble locating certified EHR technology updated for the new requirements in time to report data for the entire designated 2015 reporting period.n
nThis article originally posted on Polsinelli.com.
E66.01 — Other obesity due to excess caloriesnnZ68.38 — Body mass index (BMI) 38.0-38.9, adultnnZ72.3 — Lack of physical exercisennZ72.4 — Inappropriate diet and eating habitsnn
The Centers for Medicare and Medicaid Services (CMS) announced this week that it will be ending the “meaningful use” EHR Incentive Program in 2016.nnThe announcement—delivered by CMS Acting Administrator Andy Slavitt in a speech at a J.P. Morgan Healthcare Conference on Tuesday—follows months of requests from physician and other health stakeholder groups to slow the program down and loosen its requirements.nnCMS had announced stage 3 meaningful use guidelines in October which followed a series of proposed changes to the program, including payment adjustments and the creation of hardship exemptions.nnIn remarks at the J.P. Morgan conference and on Twitter, Slavitt said further specifics on exactly what will replace meaningful use will be forthcoming, though it will be tied to the implementation of Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) and include streamlining various quality reporting programs.nn“The meaningful use program as it has existed will now be effectively over and replaced with something better,” Slavitt said, according to a transcript of his speech. “Since late last year we have been working side by side with physician organizations across many communities—including with great advocacy from the AMA—and have listened to the needs and concerns of many. We will be putting out the details on this next stage over the next few months, but I will give you themes guiding our implementation.”nn
One of those themes focuses on shifting away from rewarding providers for the use of technology and instead centers on achieving better outcomes. He said CMS wants to offer providers the ability to customize “their goals so tech companies can build around the individual practice needs, not the needs of the government,” Slavitt said.nnAccording to Aaron Albright, director of media relations at CMS, Slavitt’s announcement is consistent with what CMS announced in the stage 3 final rule in October.nnAt that time, CMS stated that: “This rule moves us beyond the staged approach of ‘meaningful use’ by 2018 and helps us collectively move forward to a system based on the quality of care delivered, as opposed to quantity. We will use this feedback to inform future policy developments for the EHR Incentive Programs, as well as consider it during rulemaking to implement MACRA, which we expect to release in the spring of 2016 and other rulemaking as appropriate.”nnWhat remains to be seen, however, is whether CMS will still penalize eligible providers for not meeting stage 1 meaningful use requirements, or whether eligible providers should even bother continuing to track their progress on the meaningful use measures for reporting this year. Albright declined to respond to those questions at press time.nnThis article originally posted on AHIMA.org.
We have been saying it for years. Value Based Contracting is coming and in many markets it is here…and it is here to stay! nnIt is not a bad thing as long as it is transparent! Follow the money, if you cannot you should not sign the agreement! As in all economic transactions, both sides (all sides) need to be able to see and understand very clearly how it works. There are two messages here: 1) Value Based Contracting is a Market Solution – it is not and cannot be a ‘one-off’ solution where one practice or small group has a great idea and wants to keep it even semi-exclusive. Think BIG and solve BIG problems! 2) Physicians need to work together! That collaboration gene was beaten out of many docs through the battle to get into and out of medical school, getting the best residency and fellowship. We need it back! There is nothing more powerful and exciting than docs working together to solve the problems we have in health care. The smartest guys in the room have to work together and they need to take back their natural position as Leaders!nn
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About R. Todd Welter • MS, CPCnFounder and President of Welter Healthcare PartnersnMr. Welter has over 25 years of healthcare industry experience assisting physicians and other providers, hospitals and other facilities with the business side of medicine. Through strategic planning and analysis, Mr. Welter’s main focus is to strategically increase revenues and profitability in this radically changing health care environment. Mr. Welter has a Masters Degree in Organizational Leadership from Regis University in Denver where he has had an appointment as affiliate faculty in the School for Professional Studies for over ten years. In addition, Mr. Welter holds a faculty appointment at the University of Denver’s University College. In the Health Care Leadership program he teaches Macro Economics in Health Care and Innovative Strategies and Change in Health Care to graduate students.