Apr 3, 2020 | Uncategorized
Unfortunately, with the COVID-19 crisis, many providers and other healthcare organizations have had to make tough decisions regarding personnel and workflows, including staff furloughs and temporary lay-offs. While these decisions are necessary in these unprecedented times, these types of interruptions can often lead to a backlog of work creating delays in sending claims, claims payments, and overall revenue and cash flow. It can also result in non-compliance in areas such as coding, and provider credentialing and enrollment with payers and facilities. nnWe are here to help you get through these tough times! Welter Healthcare Partners is offering temporary and ongoing support services in the areas of outsourced coding, provider and facility credentialing and enrollment services, and financial strategy and compliance.nnIf you need assistance, please contact Jennifer Heuer, COO at 303.534.0388 or jh@rtwelter.com.
Apr 3, 2020 | Uncategorized
nnMedicare now recognizes the important work that primary care physicians do when it comes to preventive screenings in older patients. Is your practice currently following the annual wellness visits for Medicare beneficiaries? Read below to find out the 3 steps to add annual Medicare wellness visits in your practice!nnDoes your practice currently conduct annual wellness visits (AWV) for your Medicare beneficiaries? These AWV’s can create a great source of revenue for your practice while allowing your patient’s an outlet to make sure they are staying healthy and enhancing their quality of life. One of the benefits of an AWV is that a practice can implement a workflow that allows all members of the care team to participate, thus maximizing the patient benefit and practice revenue. To get your practice on board to start this type of encounter, it is more than just reporting a different code. The Medicare AWV consists of several elements that must be completed during the encounter in order for the codes to be supported. You must implement an appropriate workflow to ensure all required elements or the AWV are addressed and well documented. You must also make sure your patients understand the process and what their expectations for these visits will be.nnHere is the link to the CMS MLN on this topic.nn
Apr 2, 2020 | Uncategorized
The Trump administration has released information regarding financial relief for Medicare providers. Read below for more information and see what criteria the provider or supplier must meet to qualify.nnUnder the President’s leadership, the Centers for Medicare & Medicaid Services (CMS) is announcing an expansion of its accelerated and advance payment program for Medicare-participating health care providers and suppliers, to ensure they have the resources needed to combat the 2019 Novel Coronavirus (COVID-19). This program expansion, which includes changes from the recently enacted Coronavirus Aid, Relief, and Economic Security (CARES) Act, is one way that CMS is working to lessen the financial hardships of providers facing extraordinary challenges related to the COVID-19 pandemic and ensures the nation’s providers can focus on patient care. There has been significant disruption to the health care industry, with providers being asked to delay non-essential surgeries and procedures, other health care staff unable to work due to childcare demands, and disruption to billing, among the challenges related to the pandemic.n
“With our nation’s health care providers on the front lines in the fight against COVID-19, dollars, and cents shouldn’t be adding to their worries,” said CMS Administrator Seema Verma. “Unfortunately, the major disruptions to the health care system caused by COVID-19 are a significant financial burden on providers. Today’s action will ensure that they have the resources they need to maintain their all-important focus on patient care during the pandemic.”
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Medicare provides coverage for 37.4 million beneficiaries in its Fee for Service (FFS) program and made $414.7 billion in direct payments to providers during 2019. This effort is part of the Trump Administration’s White House Coronavirus Task Force effort to combat the spread of COVID-19 through a whole-of-America approach, with a focus on strengthening and leveraging public-private relationships.
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Accelerated and advance Medicare payments provide emergency funding and address cash flow issues based on historical payments when there is a disruption in claims submission and/or claims processing. These expedited payments are typically offered in natural disasters to accelerate cash flow to the impacted health care providers and suppliers. In this situation, CMS is expanding the program for all Medicare providers throughout the country during the public health emergency related to COVID-19. The payments can be requested by hospitals, doctors, durable medical equipment suppliers, and other Medicare Part A and Part B providers and suppliers.
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To qualify for accelerated or advance payments, the provider or supplier must:
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- Have billed Medicare for claims within 180 days immediately prior to the date of signature on the provider’s/ supplier’s request form,
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- Not be in bankruptcy,
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- Not be under active medical review or program integrity investigation, and
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- Not have any outstanding delinquent Medicare overpayments.
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Medicare will start accepting and processing the Accelerated/Advance Payment Requests immediately. CMS anticipates that the payments will be issued within seven days of the provider’s request.
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An informational fact sheet on the accelerated/advance payment process and how to submit a request can be found here.
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This action, and earlier CMS actions in response to COVID-19, are part of the ongoing White House Coronavirus Task Force efforts. To keep up with the important work the Task Force is doing in response to COVID-19, click here. For a complete and updated list of CMS actions, and other information specific to CMS, please visit the Current Emergencies Website.
Mar 31, 2020 | Uncategorized
Ginger Avery, CPC, CPMA, CRC, is the Coding and Compliance Manager at Welter Healthcare Partners, Inc. Below, she provides information regarding Telehealth and Telemedicine reporting. Read below for important updates and whether other important information is fact or fiction. Also, check out the new AMA scenarios for telehealth, COVID-19 coding guidance here, released 03/26/2020. Click here for the AMA quick guide to telemedicine in practice.n
Definitions:
nTelehealth refers broadly to electronic and telecommunications technologies and services used to provide care and services at-a-distance. nnTelemedicine is the practice of medicine using technology to deliver care at a distance. A physician in one location uses a telecommunications infrastructure to deliver care to a patient at a distant site. Telehealth is different from telemedicine in that it refers to a broader scope of remote health care services than telemedicine. Telemedicine refers specifically to remote clinical services, while telehealth can refer to remote non-clinical services. nnPHE = Public Health Emergency nnAsynchronous = “store-and-forward video-conferencing,” which is the “transmission of recorded health history to a health practitioner. Asynchronous telemedicine involves acquiring medical data, then transmitting this data to a doctor or medical specialist at a convenient time for assessment offline. nnSynchronous = “live video-conferencing,” which is a two-way audiovisual link between a patient and a care provider. Synchronous telemedicine requires the presence of both parties at the same time and a communication link between them that allows a real-time interaction to take place. n
Office or other outpatient visits (Telehealth)
n99201 – 99215 Office or other outpatient visits for the evaluation and management of a new (or established) patient. nnFact: These visits must have interactive 2-way video communication (synchronous). nnFact: Place of Service (POS) should be “02” telehealth. nnFact: Must be MD, DO or mid-level (aside from 99201/99211). nnFiction: If a patient calls in, you can charge an office visit code 99201-99215. Phone calls are NOT considered a 2-way video. nnFiction: You can charge New Patient visits codes for Established Patient visits. Services provided should reflect actual code descriptions. n
Emergency Department or Initial Inpatient Services (Telehealth)
nG0425 – G0427 Telehealth consultation, emergency department or initial inpatient, typically XX minutes communicating with the patient via telehealth, depending on the severity/acuity of the patient (problem-focused, detailed or comprehensive). nnThese codes are used to report an initial inpatient or emergency department consultative visit or consultations that are furnished via telehealth in response to a request by the attending physician. Place of service should indicate the location at which patient resides, eg; 21 Inpatient or 23 Emergency Department nnG0406 – G0408 Follow-up inpatient consultation, limited, physicians typically spend XX minutes communicating with the patient via telehealth These codes are used to report consultative visits or consultations that are furnished via telehealth in response to a request by the attending physician to follow up on an initial consultation or a subsequent consultative visit. Place of service should indicate the location at which the patient resides, eg; 21 Inpatient nnFact: These visits must have a saved 2-way video communication. nnFact: Must be MD, DO or mid-level. nnFact: Consultations must provide evidence that a request for service from attending was conducted as well as plan/treatment recommendation was communicated back to requesting clinician. n
Virtual Check-In (Telemedicine)
n G2010 Remote evaluation of recorded video and/or images submitted by an established patient (e.g., store and forward), including interpretation with follow-up with the patient within 24 business hours, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment Physicians or other qualified practitioners review photos or video information submitted by the patient to determine if a visit is required. For asynchronous transmissions (e.g., store and forward), Place of Service should be indicated as ’11’ office. nnG2012* Brief communication technology-based service, e.g., virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion *A brief (5-10 minutes) check-in with a clinician via telephone or other telecommunications device. A physician or other qualified health care professional conducts a virtual check-in, lasting five to 10 minutes, for an established patient using a telephone or other telecommunication device to determine whether an office visit or other service is needed. Place of service should indicate whether the visit was conducted via telephone ’02’ telehealth or other telecommunications device ’11’ office. nnFact: For established patients only. Fact: Must be MD, DO or mid-level. nnFact: Communication is not related to a medical visit within the previous 7 days and does not lead to a medical visit within the next 24 hours. nnFact: Patient consent needs to be documented to receive virtual check-in services. n
E-Visits (Telemedicine) A communication between a patient and their provider through an online patient portal.
n99421 – 99423 Online digital evaluation and management service, for an established patient, for up to 7 days, the cumulative time during the 7 days; XX minutes These codes are used to report non-face-to-face patient services initiated by an established patient via an on-line inquiry (eg. secure email, EHR portal, or other digital application). Providers must provide a timely response to the inquiry and the encounter must be stored permanently to report this service. Place of Service should be indicated as ’11’ for this asynchronous service. nnFact: Medicare Fee Schedule indicates Colorado reimbursement rates from $15.52 – $50.16 for these services. nnG2061 – G2063 Qualified non-physician health care professional online assessment, for an established patient, for up to 7 days, a cumulative time during the 7 days; XX minutes These codes represent patient-initiated, digital communications that require a clinical decision that typically otherwise would have been provided in the office. Clinicians who may not independently bill for evaluation and management visits (for example – physical therapists, occupational therapists, speech-language pathologists, clinical psychologists) should use G2061-G2063. Place of Service should be indicated as ’11’ for this asynchronous service. nnFact: Medicare Fee Schedule indicates Colorado reimbursement rates from $12.27 – $33.92 for these services. nnFact: The patient initiates communication through an EHR portal, secure email or other digital application. nnFact: Patient consent should be documented to receive virtual check-in services. Fact: For established patients only. n
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- Consents are required. Stored recordings of verbal consent are recommended, however, written documentation supporting the services reported should clearly indicate the patient’s consent to treat.
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- HHS will NOT penalize clinicians for waiving copays/out of pocket (OOP). Clinicians are encouraged by Medicare to waive patients OOP, although this is not an official requirement. OIG OFFICIAL DOCUMENT
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- Waiver can be for any emergent or acute problem, not just COVID19. Acuity/urgency must be evident in the documentation.
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- Waiver is not for routine check-ups or non-urgent encounters. Ethical standards apply.
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- The originating site requirements are waived. Clinicians and patients can communicate in their home settings.
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- Providers are expected to come into compliance with any waived requirements prior to the end of the emergency period.
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- CMS has approved specific waivers & modifications only to the extent that the provider in question has been affected by the disaster or emergency.
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- Waivers or modifications under section 1135 of the SSA may be retroactive to the beginning of the emergency period (or to any subsequent date).
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- The waiver or modification terminates either upon termination of the emergency period or 60 days after the waiver or modification is first published (subject to 60-day renewal periods until termination of the emergency).
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- Visits are considered the same as in-person visits and are paid at the same rate as regular, in-person visits.
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- To the extent the 1135 waiver requires an established relationship, HHS will not conduct audits to ensure that such a prior relationship existed for claims submitted during this public health emergency. This is not intended to allow billing for new office visits for established patients.
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Other Take Homes:
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- All services should be documented/recorded and stored in the EHR to support medical necessity.
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- Services must support actual code descriptions. Document what you do, code what you document.
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- Check with your current payers to verify specific telehealth/telemedicine requirements.
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- Consider researching various intake platforms that will help assist with service communications/ requirements.
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- Video & phone calls must be saved by recorded or written documentation in the EHR.
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- None of the listed services in this article are billable by clinical staff.
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- Time spent with the patient should be documented in all encounters.
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- HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT (HIPAA): Effective immediately, the HHS Office for Civil Rights (OCR) will exercise enforcement discretion and waive penalties for HIPAA violations against health care providers that serve patients in good faith through everyday communications technologies, such as FaceTime or Skype, during the COVID-19 nationwide public health emergency.
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Other Resources/References:
n The Medicare Newsroom Fact Sheet can be viewed in its entirety here. nnMedicare Telehealth FAQs 03/17/2020nnClick here for a complete list of Medicare-covered Telehealth Services
Mar 30, 2020 | Uncategorized
Today we celebrate and are extremely grateful for all of our healthcare providers who are on the front line treating and caring for patients. We thank you from the bottom of our hearts for your unwavering dedication to keeping all of us safe and well!
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Mar 27, 2020 | Uncategorized
Big news for PTs and their patients! For the first time, PTs will be allowed to bill for e-visits under codes associated with online assessment and management services (codes G2061, G2062, and G2063). To determine the reimbursement rates for G2061-G2063, visit the CMS Physician Fee Schedule lookup tool. Medicare coinsurance and deductible would apply to the services. A March 18 CMS MLN Matters article includes more information about the e-visits and telehealth waiver. Read below for more information!nnIn the federal government’s rapidly evolving response to the coronavirus pandemic, the U.S. Centers for Medicare and Medicaid Services has announced that it is easing Medicare telehealth restrictions in ways that could allow PTs to provide “e-visits,” a limited type of service that must be initiated by the patient. Prior to this change, CMS did not recognize PTs among the health care professionals allowed to bill codes associated with the visits.nnThe change, announced midday on March 17, is part of a set of loosened requirements that CMS has adopted to expand the provision of telehealth and patient-initiated digital communications, such as e-visits, to help blunt the spread of COVID-19. For the most part, PTs remain outside the reach of these so-called “1135 waivers” related to telehealth, with one exception: a type of remote interaction CMS calls an e-visit under Medicare Part B.nnIn its 2020 physician fee schedule final rule, CMS describes e-visits as “non face-to-face patient-initiated digital communications that require a clinical decision that otherwise typically would have been provided in the office.” The code descriptors suggest the codes are intended to cover short-term (up to seven days) assessments that are conducted online or via some other digital platform and include any associated clinical decision-making.nnUnder the waivers guidance issued by CMS, Medicare beneficiaries can qualify for e-visits no matter their geographic region or physical location, meaning that the provisions have been expanded to nonrural areas and can take place with patients in their homes. The big news for PTs and their patients is that, for the first time, PTs will be allowed to bill for e-visits under codes associated with online assessment and management services (codes G2061, G2062, and G2063). To determine the reimbursement rates for G2061-G2063, visit the CMS Physician Fee Schedule lookup tool. Medicare coinsurance and deductible would apply to the services. A March 18 CMS MLN Matters article includes more information about the e-visits and telehealth waiver.nnTo qualify as an e-visit, three basic qualifications must be met: the billing practice must have an established relationship with the patient, meaning the provider must have an existing provider-patient relationship; the patient must initiate the inquiry for an e-visit and verbally consent to check-in services, and the communications must be limited to a seven-day period through an “online patient portal.”nnAlthough the patient must initiate, CMS writes in a fact sheet that “practitioners may educate beneficiaries on the availability of the service prior to patient initiation.” For example, if a patient cancels treatment because they can’t come to the clinic or are concerned about leaving home, then the PT may advise the patient that she or her can reach out to the therapists as needed.nnAlice Bell, PT, DPT, APTA senior payment specialist, says that the waiver has some very practical implications for PTs, and offers a possible scenario in which the e-visit could be useful.nn”Let’s say that, as a PT, I’ve been seeing a patient for an orthopedic condition and I am progressing the patient’s exercises,” Bell said. “The patient is unable to come into the clinic but calls me to say she’s having difficulty with one of the exercises and that the other two seem to be too easy. I could arrange an e-visit with the patient and discuss her performance of the exercises. And I could then make a determination — maybe I find that the patient is performing one of the exercises incorrectly — and I could direct the patient on the correct performance. Perhaps I also determine that two of the exercises can be progressed because the patient is improving, so I could instruct the patient in the two new exercises. After that I could advise the patient to contact me for a follow-up e-visit as needed until the patient can return to the clinic.”nnThe HHS Office of the Inspector General has also issued a policy statement that provides guidance on how it interprets the new telehealth waivers. APTA regulatory affairs staff will continue to monitor these waivers and other developments and share news with members.nn”As we’ve seen over the past few weeks, and especially during the past few days, we’re dealing with an extremely fluid situation in terms of response to the coronavirus pandemic,” said Kara Gainer, APTA’s director of regulatory affairs. “This waiver and other changes have the potential to make a difference, and we hope that CMS continues to take steps that can help providers and their patients stay healthy.”nnAPTA has issued a statement on patient care and practice management during the COVID-19 outbreak, and offers a webpage to keep members up to date with the latest news on the pandemic.nnOriginal article published on apta.org
Mar 26, 2020 | Uncategorized
The COVID-19 pandemic is causing problems for everyone around the world. While it is important to pay attention to what is going on, there will be a point in time where everything will go back to normal. Many businesses will have buildup demand during this period and those that are ready to meet that demand will reap the rewards. Read the article below to find out what you need to do to prepare for life post COVID-19. nnPost COVID-19nCOVID-19 is all the buzz right now, but there will be a time after COVID-19 and when that time comes the winners will be those who are ready. No one, at least no one I know, wants to be sick or injured and need medical care, but it happens. Even during this pandemic, people will still need medical care, but the current slowdown, and even stoppage in some markets, of elective procedures, will create a buildup of demand for services. This pent-up demand will still be there as the impact of the virus diminishes and those practices that are ready to meet demand will reap the rewards.nnThings to consider as we weather this storm:n
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- Will you be ready to go back to “life as usual?” Will your facility be ready? Will you have all of the other providers and services needed to treat patients? Be sure to consider other services that may come from outside your practice. Services like: Anesthesiology, Radiology, Blood, and an actual facility to perform the procedure, etc.
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- It’s very likely that at least some hospitals and hospital systems will be swamped with COVID-19 patients, hopefully, many of them recovering. Consider, for example, most employed specialists have employment agreements based on Work RVUs, and they will be hungry to make up for lost RVU’s as the impact of COVID-19 abates; however, because they are tied to a specific hospital or system, there may not be capacity available to support their specialty. This means that the hospitals’ usual case volume may become available! Hospital-based providers may even become available themselves. Do you know which providers are the best candidates to join your practice?
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- As we have learned over the years, the art of commercial payer contracting has much to do about supply and demand! As we see a slowdown in the market to perform elective cases as COVID-19 cases increase, we should understand that this is affecting supply, but not demand. When we begin to see COVID-19 cases going down, access will increase to provide services for the built-up demand. Be ready!
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nWe want to encourage you to weather the storm and prepare for the opportunity on the other side. If you want to discuss appropriate strategies for your practice, please reach out to us. We are here to help!nnTodd Welter, CEO
Mar 24, 2020 | Uncategorized
Below are some updates regarding telehealth providers in Colorado. These are new updates and resources regarding COVID-19 (Coronavirus). Each of these payers has links to its website, for you to learn more about the services they are offering. Keep reading below to see if your provider has made any change to their telehealth program. If you have any questions for us at Welter Healthcare Partners feel free to contact us at 303-534-0388 or by email at info@WHPelter.com. nn
Mar 24, 2020 | Uncategorized
So many of us are now faced with not only the challenges associated with working from home but having the whole family home as well. There are daily news stories about how to cope with kids who want to go see their friends, work-out routines without gym equipment, and virtual dance parties streamed live via social media. But as members of the health care industry, we must always keep the patient’s information as a top concern. Read below for more information!nnWhether you are working off your work computer hauled into your dining room or a laptop on the kitchen table there are steps you can take to make sure personal health information (PHI) stays secure. Just like being at the office make sure you are locking your computer every time you walk away. If you are talking on the phone make sure you are in a closed room where PHI cannot be heard by other members of your household. Keep your internet tabs to a minimum and close out all unnecessary programs while PHI is open.nnClick on the links below for information on working from home during COVID-19:nnCoping With Children During QuarantinenWork Productively from Home in a Time of Social DistancingnnFrom everyone at Welter Healthcare Partners, we wish all of you health and safety during this time.
Mar 19, 2020 | Uncategorized
Welter Healthcare Partners is committed to keeping you up to date with the latest news regarding COVID-19. Beginning April 1st providers can start to use U07.1 for the diagnosis code of COVID-19. Read below to find out more about this coding update. n
Written by: Laura Evans, CPC Mar 18, 2020
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Providers in the U.S. will have a specific ICD-10-CM diagnosis code for the COVID-19 virus beginning April 1.
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During a meeting today, the ICD-10 Coordination and Maintenance Committee announced that it would adopt the World Health Organization (WHO) code, U07.1 (COVID-19), effective April 1.
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Previously, the panel had planned to implement the code beginning October 1 in the U.S. But the committee moved up the adoption date after the WHO declared COVID-19 a pandemic and President Trump declared the spread of the virus a national emergency, explained Donna Pickett, head of the diagnosis coding side of the ICD-10 Coordination and Maintenance Committee. She announced the April 1 implementation date during the March 18 committee meeting.
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Prior to April 1, providers can continue to report based on previously published interim guidelines, which outlines, among other things, how to report illnesses caused by COVID-19.
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Note that code U07.1 should be reported only for confirmed cases. Providers should continue to follow the interim guidelines for unconfirmed cases of suspected exposure or symptoms.
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Code U07.1 is designed to be a primary code, and you are to code also pneumonia and all other manifestations, Pickett advised during the meeting.
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Providers on the call noted that they are seeing testing only for severe cases and asked whether there are specific codes for exposure to COVID-19 or suspected cases of the virus that are symptomatic. Currently, there are not, Pickett responded.
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The ICD-10 Coordination and Maintenance Committee plans to update coding information about the code change on its website by March 20, 2020.
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Editor’s note: This is an unfolding story. Stay tuned for additional coverage.
Mar 18, 2020 | Uncategorized
Dear Valued Welter Healthcare Partners Customer,nnYour team at Welter Healthcare Partners is closely monitoring the developments regarding Coronavirus (COVID-19). We are following the guidance from multiple healthcare authorities, including our own medical director, and implementing policies and procedures to keep our employees healthy so we can uphold our commitment of providing quality services to you. nnWe are currently open and maintaining our operations and delivering services. In the unlikely event we are required to temporarily close our office, we have a business continuity plan in place and are ready to execute it. This includes the ability of our employees to work from home. Our work from home policy includes compliance and security standards to protect your information, including encrypted VPN access to various platforms and data. We are limiting business travel for employees but can ensure continuity of service to our clients in a virtual environment. nnThank you for being a valued client. We are here for you and committed to helping our clients through this very difficult and challenging time. Please contact us if you have any concerns or need any assistance. Your continued success is of the utmost importance to us. Our team will work closely with you and provide necessary updates and information.nnPlease stay safe!nnTodd WelternnCEO
Mar 17, 2020 | Uncategorized
Welter Healthcare Partners is committed to providing you with the most up to date information regarding billing and coding issues regarding COVID-19. For more information regarding this billing update on Medicare read the article below!
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The Trump Administration today announced expanded Medicare telehealth coverage that will enable beneficiaries to receive a wider range of healthcare services from their doctors without having to travel to a healthcare facility. Beginning on March 6, 2020, Medicare—administered by the Centers for Medicare & Medicaid Services (CMS)—will temporarily pay clinicians to provide telehealth services for beneficiaries residing across the entire country.
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“The Trump Administration is taking swift and bold action to give patients greater access to care through telehealth during the COVID-19 outbreak,” said Administrator Seema Verma. “These changes allow seniors to communicate with their doctors without having to travel to a healthcare facility so that they can limit risk of exposure and spread of this virus. Clinicians on the frontlines will now have greater flexibility to safely treat our beneficiaries.”
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On March 13, 2020, President Trump announced an emergency declaration under the Stafford Act and the National Emergencies Act. Consistent with President Trump’s emergency declaration, CMS is expanding Medicare’s telehealth benefits under the 1135 waiver authority and the Coronavirus Preparedness and Response Supplemental Appropriations Act. This guidance and other recent actions by CMS provide regulatory flexibility to ensure that all Americans—particularly high-risk individuals—are aware of easy-to-use, accessible benefits that can help keep them healthy while helping to contain the spread of coronavirus disease 2019 (COVID-19).
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Prior to this announcement, Medicare was only allowed to pay clinicians for telehealth services such as routine visits in certain circumstances. For example, the beneficiary receiving the services must live in a rural area and travel to a local medical facility to get telehealth services from a doctor in a remote location. In addition, the beneficiary would generally not be allowed to receive telehealth services in their home.
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The Trump Administration previously expanded telehealth benefits. Over the last two years, Medicare expanded the ability for clinicians to have brief check-ins with their patients through phone, video chat and online patient portals, referred to as “virtual check-ins”. These services are already available to beneficiaries and their physicians, providing a great deal of flexibility, and an easy way for patients who are concerned about illness to remain in their home avoiding exposure to others.
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A range of healthcare providers, such as doctors, nurse practitioners, clinical psychologists, and licensed clinical social workers, will be able to offer telehealth to Medicare beneficiaries. Beneficiaries will be able to receive telehealth services in any healthcare facility including a physician’s office, hospital, nursing home or rural health clinic, as well as from their homes.
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Medicare beneficiaries will be able to receive various services through telehealth including common office visits, mental health counseling, and preventive health screenings. This will help ensure Medicare beneficiaries, who are at a higher risk for COVID-19, are able to visit with their doctor from their home, without having to go to a doctor’s office or hospital which puts themselves or others at risk. This change broadens telehealth flexibility without regard to the diagnosis of the beneficiary, because at this critical point it is important to ensure beneficiaries are following guidance from the CDC including practicing social distancing to reduce the risk of COVID-19 transmission. This change will help prevent vulnerable beneficiaries from unnecessarily entering a healthcare facility when their needs can be met remotely.
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President Trump’s announcement comes at a critical time as these flexibilities will help healthcare institutions across the nation offer some medical services to patients remotely, so that healthcare facilities like emergency departments and doctor’s offices are available to deal with the most urgent cases and reduce the risk of additional infections. For example, a Medicare beneficiary can visit with a doctor about their diabetes management or refilling a prescription using telehealth without having to travel to the doctor’s office. As a result, the doctor’s office is available to treat more people who need to be seen in-person and it mitigates the spread of the virus.
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As part of this announcement, patients will now be able to access their doctors using a wider range of communication tools including telephones that have audio and video capabilities, making it easier for beneficiaries and doctors to connect.
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Clinicians can bill immediately for dates of service starting March 6, 2020. Telehealth services are paid under the Physician Fee Schedule at the same amount as in-person services. Medicare coinsurance and deductible still apply for these services. Additionally, the HHS Office of Inspector General (OIG) is providing flexibility for healthcare providers to reduce or waive cost-sharing for telehealth visits paid by federal healthcare programs.
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Medicaid already provides a great deal of flexibility to states that wish to use telehealth services in their programs. States can cover telehealth using various methods of communication such as telephonic, video technology commonly available on smart phones and other devices. No federal approval is needed for state Medicaid programs to reimburse providers for telehealth services in the same manner or at the same rate that states pay for face-to-face services.
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This guidance follows on President Trump’s call for all insurance companies to expand and clarify their policies around telehealth.
nFor more information regarding this update click here.nnComplete and original article published on cms.gov.
Mar 16, 2020 | Uncategorized
Due to the recent outbreak in COVID-19 paired with increased concern for patients to be seen under quarantine conditions, Welter Healthcare Partners is striving to collect all relevant documentation, coding and billing details to help clinicians assure they receive appropriate reimbursement for unique services they are providing. Welter Healthcare Partners recommends checking with your top payors for coverage benefits, limitations and originating site waivers. Your feedback is greatly appreciated. Welter Healthcare Partners will continue to provide updates as we receive them. If you have any questions, please contact us at info@rtwelter.com. nnThe CPT Editorial Panel approved a new CPT® code at a special, expedited meeting held, via telephone, on Friday, March 13, 2020. A new CPT® code has been created that streamlines novel coronavirus testing offered by hospitals, health systems, and laboratories in the United States. nnNEW CPT CODE: 87635 Infectious agent detection by nucleic acid (DNA or RNA); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), amplified probe technique. nnCPT Assistant has provided a fact sheet for coding guidance for the SARS-CoV-2 (COVID-19) test in relation to the use of the new CPT code. Click here for the fact sheet.nnThere are two new HCPCS codes for healthcare providers who need to test patients for Coronavirus. Providers using the Centers for Disease Control and Prevention (CDC) 2019 Novel Coronavirus Real-Time RT-PCR Diagnostic Test Panel may bill for that test using the newly created HCPCS code (U0001). A second new HCPCS code (U0002) can be used by laboratories and healthcare facilities to bill Medicare as well as by other health insurers that choose to adopt this new code for such tests. HCPCS code (U0002) generally describes 2019-nCoV Coronavirus, SARS-CoV-2/2019-nCoV (COVID-19) using any technique, multiple types or subtypes (includes all targets). The Medicare claims processing system will be able to accept these codes on April 1, 2020 for dates of service on or after February 4, 2020. Click here for more information.nnTelehealth Evaluation considerations: nnEffective immediately 03/14/2020, United Health Care (UHC) will wave CMS originating site restrictions for Medicare Advantage, Medicaid and commercial members so services can be performed while the patient is in their home, effective until April 30, 2020. United Health care has waived all member cost-sharing, including copays, coinsurance, and deductibles, for COVID-19 diagnostic testing provided at approved locations, in accordance with the Centers for Disease Control and Prevention (CDC) guidelines for all commercial insured, Medicaid and Medicare members. UHC will also reimburse providers for telephone calls to existing patients. nnWe’ve found that most payors advise providers billing telemedicine to use the appropriate evaluative and management CPT code (99201 – 05, 99211-15) along with a GT modifier. nAlthough, MM10152 from January 1, 2018 eliminates the requirement of the use of GT modifier on professional claims. Click here for more information.nnPrivate payors may prefer that you use the telemedicine specific code 99444. It varies based on the payer and the state guidelines.nnMany of the MACs have yet to loosen the reigns on the originating site requirement with the use of “02” Place of Service with an office visit code. There are many other payors, including Medicare Advantage plans that have waived the originating site requirement. nnCMS is recommending the use of G2012 for telehealth services in a recent press release: nnCode G2012 has specific guidelines and documentation requirements to keep in mind when considering the appropriate use of this code: nnG2012 (Brief communication technology-based service, e.g. virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion).nnReimbursement according to the recent MFS is $14.89.n
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- The service is communication technology-based
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- The provider can be a physician or other qualified health care professional who reports E/M services
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- Interaction must be between the patient and billing practitioner, not clinical staff.
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- The communication can’t be related to an E/M service from within the previous seven days.
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- The communication can’t lead to an E/M service within 24 hours (or soonest available): The language in the code descriptor states, “nor leading to an E/M service or procedure within the next 24 hours.” Consequently, Medicare will be watching for an uptick in appointments occurring 25 hours or so after the call. Do not game the system to get around the 24-hour limitation.
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- The code represents five to 10 minutes of medical discussion.
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- The medical record must document verbal consent from the patient for each billed service. Cost-sharing applies, and the beneficiary co-payment isn’t waived.
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- The service is available only to established patients, defined as patients who have “received professional services from the physician or qualified health care professional or another physician or qualified health care professional of the exact same specialty and subspecialty who belongs to the same group practice, within the past 3 years.”
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nHealth First of Colorado states, “Place of Service 02 should be used to report services delivered via telecommunication, where the member may be in their home and the provider may be at their office.” nnNon-F2F evaluation & management telephone services 99441-99443 may also be a consideration. This category of codes have yet to be recognized as CMS for reimbursement. Many other payors also do not cover these services. Welter Healthcare Partners recommends verifying coverage, limitations and reimbursement with your top payers for these services. nnModifier Considerations: nnUse of GT modifier on Medicare claims was eliminated in 2018. According to CMS, the place of service code 02 is sufficient. See the instructions below for appropriate consideration of CR modifier. nnChange Request (MLN) MM10152 from January 1, 2018 eliminates the requirement to use the GT modifier (via interactive audio and video telecommunications systems) on professional claims for telehealth services. Use of the telehealth Place of Service (POS) Code 02 certifies that the service meets the telehealth requirements. Click here to read the request.nnEffective August 31, 2009, the use of the CR modifier will be mandatory for applicable HCPCS codes on any claim for which Medicare Part B payment is conditioned directly or indirectly on the presence of a “formal waiver.”nnThe CR Modifier: Both the short and long descriptors of the CR modifier are “catastrophe/disaster-related.” The CR modifier is used in relation to Part B items and services for both institutional and non-institutional billing. Non-institutional billing, i.e., claims submitted by “physicians and other suppliers”, are submitted either on a professional paper claim form CMS-1500 or in the electronic format ANSI ASC X12 837P or – for pharmacies – in the NCPDP format. In previous emergencies, use of the CR modifier was entirely discretionary with the billing provider or supplier. It no longer may be used at the provider or supplier’s discretion. Effective August 31, 2009, the use of the CR modifier will be mandatory for applicable HCPCS codes on any claim for which Medicare Part B payment is conditioned directly or indirectly on the presence of a “formal waiver.”nnSee the MLN in its entirety for appropriate consideration of the CR Modifier here.nnDiagnosis (ICD10COM) Coding for COVID-19: Interim coding advice for COVID-19 has been provided by the CDC here. Clinicians are reminded to follow HIPAA mandated diagnosis coding guidance by reporting signs or symptoms until a definitive diagnosis has been made. nn nn
Mar 11, 2020 | Uncategorized
In March 2020, The U.S. Department of Health and Human Services finalized two HHS interoperability rules that give patients access to their healthcare data. With this new system, patients and providers will be able to access their medical records through applications on smartphones. While these new rules sound like a big step forward for the healthcare industry, there have been mixed reviews as some people are worried about patient privacy and provider API cost. Read the article below to find out more about this interesting development. nnThe U.S. Department of Health and Human Services (HHS) has finalized two interoperability rules to give patients direct access to their healthcare data. The first provisions of the rule will impact healthcare systems in as soon as six months.nnThe two rules, issued by the HHS Office of the National Coordinator for Health Information Technology (ONC) and Centers for Medicare & Medicaid Services (CMS), were announced last year, and the final rules were issued today. They are expected to “empower patients around a common aim—giving every American access to their medical information so they can make better healthcare decisions,” according to a release issued by CMS.nn”Americans will now have electronic access to their health information on their smartphone if they choose,” said ONC National Coordinator Don Rucker, MD, during a White House media briefing this morning with multiple government officials. “Our rule requires hospitals and doctors to provide software access points—endpoints if you will—to their electronic medical record databases so that patients can download these records to their smartphones.”nnOne key deadline for health systems occurs six months from today, said CMS Administrator Seema Verma. “We are changing the conditions of participation for hospitals to ensure Medicare- and Medicaid-participating hospitals are supporting care coordination for patients by sending admission, discharge, and transfer notifications so patients receive a timelier follow up, supporting better care and better health outcomes,” she said.nnThe CMS rule also impacts payers. Starting in 2021, Verma said, “all health plans doing business in Medicare, Medicaid, CHIP, and the federal exchanges [must] share their health data with their patients through a secure standards-based API (application programming interface), which represents the link between the data on various systems and [the] consumer’s phone.”nnThe rule also requires payers to make their provider directories publicly accessible through a provider directory API starting in 2021, said Verma. “This will allow innovative third parties to design apps that will help patients evaluate which plan networks are right for them and potentially avoid surprise billing by having a clearer picture of which clinicians are in-network,” she said.nnHHS Secretary Alex Azar said he expects the rules to spawn a new era of innovation in healthcare. “We hope to see a whole ecosystem of condition- or disease-specific apps to help patients monitor and improve their health in real-time, in part, by using data made available from their electronic health record via an API,” said Azar.nnRucker further commented: “We’re going to see a growth in patient-facing healthcare IT markets from an entirely new app ecosystem that’s going to be fueled by transparency about both product and price. We think this health app economy is going to have new services and we see the smartphone—not just as a smartphone—but as a tool to connect other devices to it.”nnAs expected, the ONC rule specifies the API certification criterion requires the use of the Health Level 7 (HL7) Fast Healthcare Interoperability Resources (FHIR) standard Release 4 and references other standards and implementation specifications to support standardization and interoperability.nnPatient Privacy ConcernsnThe ONC rule received more than 2,000 comments from the public, said Rucker. While most pertained to price transparency, concerns about protecting patient privacy rose to the forefront when Verona, Wisconsin, EHR vendor Epic Systems launched an initiative to delay the ONC ruling until certain patient privacy issues were addressed. The company marshaled its health system clients to write a letter to Azar to request the delay.nnDuring the White House media briefing with reporters, Azar said, “I want to emphasize that we’re taking these actions while maintaining and strengthening patient privacy protections. Patient privacy should never stand in the way of patient control.”nnIn a later media briefing on Monday exclusively with ONC representatives, Rucker said the final rule does not offer explicit mandates for third-party app privacy requirements, in part, for legal reasons.nn”Under the HIPAA right of access, [access to your] data is your right,” said Rucker. “We cannot, as a general matter, of course, presume to tell you how you are going to exercise your rights to your data.”nnIn addition, he said that while the U.S. Food & Drug Administration has some regulatory control over consumer apps, the ONC does not want to institute measures that will stifle innovation so early in the app development process. “The future is really unbounded, and we do not want to prospectively clamp off business models … We should really be open to the opportunities, um, that modernity affords us.”nnIn a statement issued Monday to HealthLeaders, Epic said, “The rule is very important to health systems and their patients, so we will read it carefully to understand its impact before making judgments.” In Epic’s statement today, among the issues it said it would closely scrutinize was “transparency for patients into companies’ data use and data handling practices.”nnYet the American Hospital Association still has concerns. In a statement issued after the final rule was released, the organization said, “America’s hospitals and health systems support giving patients greater access and control over their health data … However, today’s final rule fails to protect consumers’ most sensitive information about their personal health. The rule lacks the necessary guardrails to protect consumers from actors such as third-party apps that are not required to meet the same stringent privacy and security requirements as hospitals. This could lead to third-party apps using personal health information in ways in which patients are unaware.”nnIndustry ReactionnThe news received mixed reviews by healthcare systems, healthcare organizations, and observers, but most had not yet had the opportunity to completely review the 1,244-page ONC final rule or the 474-page CMS rule.nnAmong the misgivings expressed:n
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- Disappointment that an interim ONC final rule wasn’t issued: The American Health Information Management Association (AHIMA) issued a statement expressing support for the effort to “eradicate practices that unreasonably limit the access, exchange, and use of electronic health information for authorized and permitted purposes including patient access to their health information. However, given that the rule introduces a number of new definitions and terminologies and the significant economic impact of this rule, we are disappointed the [ONC} did not heed stakeholders’ calls to issue an interim final rule.”
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- Provider API costs: The Medical Group Management Association (MGMA) expressed support for the new opportunities for medical practices to share health information with their patients via user-friendly apps and CMS’s new hospital admission, discharge, and/or transfer notification requirements, but pointed out a significant issue. “MGMA is concerned that the ONC rule permits EHR vendors to push API costs onto providers,” the association said in a statement. “We will lead industry efforts to protect medical groups from potentially excessive EHR upgrade fees to ensure limited practice resources are not diverted from patient care.”
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nOthers embraced the changes.n
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- Cerner: Brent Shafer, CEO of EHR company Cerner, based in North Kansas City, Missouri, also issued a statement to HealthLeaders, saying in part, “Today marks an important milestone in a decades-long pursuit of improving consumers access to their own personal health data and clearing unnecessary hurdles that have stood in the way. The rules announced today will support a seamless and connected health care world where patients are more empowered than ever before.”
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- Intermountain: Stanley Huff, chief medical informatics officer for Intermountain Healthcare, said, “We are excited to see a major step forward in healthcare interoperability that is enabled by releasing the final rules. We anticipate that adoption of the HL7 FHIR Application Programming Interface (API) and encouraging patient-controlled access to their data will lead to healthcare applications that will improve the quality of care we provide while improving access to care and decreasing costs.”
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- Accenture: In a statement to HealthLeaders, Andy Truscott, managing director and technology consulting lead in Accenture’s health practice, said: “With today’s ruling, health systems have a clear compliance timeline to work toward. It does require a gap assessment of existing people, processes, and technologies against the obligations of the new rules and to deliver change. The rules are a boost for health systems in that custodianship of information about patients cannot be used as a way of binding the patient to that provider. Health systems will now look at how to improve the quality of the services they provide patients by leveraging the richer stream of information that can be obtained from other providers under the new rules. The opportunity to provide patients and providers with heightened experiences supported by a rich information fabric is there for the taking of the innovator. A clear statement on FHIR R4 as the backbone now provides certainty to information systems developers. Accenture believes that innovation is even more important now than ever.”
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nOriginal article published on healthleadersmedia.com
Mar 11, 2020 | Uncategorized
CMS has released a second emergency code for the testing of CORVID-19. To find out more about this update, read the article below and click on the links to see how you are covered. nnAs of Friday, March 6th, CMS released a second emergency code for CORVID-19 testing. Unlike HCPCS code U0001, which was released last month, U0002 will be used by laboratories to bill for non-CDC SARS-CoV-2/2019-nCoV (CORVID-19).nnHCPCS code U0001 was enacted to bill for tests and to track new cases of the virus. CMS and Medicare claim processing systems will begin accepting these codes as of April 1st for dates of service on or after February 4th of this year.nCheck with individual payers for guidance based on your contracts with them.nnCMS has also released three different fact sheets related to the virus. Click on the links below for more information regarding these updates from CMS:nnCMS Individual Insurance CoveragennCMS Medicare Coverage & PaymentnnCMS Medicaid Coverage
Mar 4, 2020 | Uncategorized
Anthem has recently finalized its acquisition of Beacon Health. This deal will allow for the expansion of critical behavioral health services, which will provide more care across the country. Read the article below for more information regarding the new changes that will come to Beacon and Anthem.nnAnthem, Inc. on Monday said it has finalized its previously announced acquisition of Beacon Health Options, the nation’s largest independently held behavioral health organization.nnFinancial terms were not disclosed for the sale of Boston-based Beacon, which had been held by Bain Capital Private Equity and Diamond Castle Holdings. The newly acquired BHO will move into Anthem’s Diversified Business Group.nnBeacon serves 36 million people and almost 3 million individuals in comprehensive risk-based behavioral programs. Indianapolis-based Anthem said the acquisition creates an opportunity to combine existing behavioral health capabilities “with Beacon’s successful model and support services in order to enhance whole-person care.”nn”We are pleased to complete the acquisition of Beacon Health Options and are excited to expand our critical behavioral health services to more people across the country as part of our focus on true whole-person care,” Anthem CEO Gail K. Boudreaux said in a media release.nn”Consumers and health plan customers alike will benefit from our ability to scale and integrate physical and behavioral capabilities in new and meaningful ways to improve lives,” she said.nnWhen the deal was first announced last June, Beacon CEO Russell C. Petrella said the acquisition would provide Beacon will scale to expand service options.nn”Together, we will expand access and enhance the quality of care for our mutual members,” Petrella said in a statement. “I am proud of the talented and committed team at Beacon, and we look forward to our future with Anthem.”nnOriginal article published on healthleadersmedia.comnn
Mar 4, 2020 | Uncategorized
When we go to the doctor, someone puts notes into our file. If you see these notes, some entires might be strikingly similar. This is called cloned notes. Below in this week’s Industry Hot Buttons, we go over cloned notes and how they can be an issue. Read the article below to find out more!nnCloned notes, as defined by CMS, are entries in a patient’s health record that are identical or strikingly similar to other entries in the same or another patient’s health record.nnEMR’s have made the lives of health industry professionals easier in so many ways. Unfortunately, they have also created a few headaches.nnMany people may not have known him until his recent passing, but Lawrence “Larry” Tesler was one of the computer scientists who created the “copy/paste” function.nnThis function has completely changed the way that each of us uses technology every day and is a function some of us would be lost without, myself included.nnThe problem is when this is over-utilized in the medical record. It leads to contradictions in our notes, unnecessary information, and often times the needed and pertinent information is left out.nnAs far back as 2013 the OIG has had Cloned Notes on their radar. It can lead to loss of integrity of the documentation and even damage the trustworthiness of the clinicians.nnIn a recent issue of Healthcare Business Monthly from the AAPC, an article entitled “Skirting the Dangers of Cloned Notes in Healthcare Practices”, writer Terry A. Fletcher explores the issues surrounding this and the risks it puts your practices at.
Feb 27, 2020 | Uncategorized
You may have heard that Cofinity.net is being sunset and we’ll no longer be using directprovider.com. These sites have been replaced with a new secured provider portal at firsthealth.com, a self-serve center that’ll support your network needs by offering claim search functionality, a complete client list, access to news and updates, and much more. Read the article below to find out more about this important change.nnIn just a few short weeks you’ll no longer be able to access Cofinity.net at all. Already, you might’ve noticed that the site is no longer interactive, and we aren’t processing password resets or new registration requests. We’re very proud to offer you this streamlined, self-serve, single-portal that connects you to both First Health and Cofinity network resources.nnHere’s a brief description features available on the First Health-Cofinity website:nnSecure LoginnnThe new secure login feature allows providers to access the First Health-Cofinity network portal on FirstHealth.com using their user ID and password. All providers will need to register as first-time users to access this feature.nnDemographic and TIN Updates Registered providers can submit demographic and TIN updates right on the website.nnClaim Activity ReportnnThis feature will allow providers to run ad-hoc reports for claim(s) within a specified time frame.nnClaim SearchnnThe new provider claim search functionality allows registered providers to search for claims by TIN and DOS. Providers will also be able to submit claim appeals if they are questioning the pricing. Appeals will be sent to our customer service team for review.nnClient ListnnProviders will be able to view an online list of all the clients (payers) contracted. Registered providers can even view details, like affiliations, address, and phone number for each client in the list.nnInformation provided by cofinity.net
Feb 27, 2020 | Uncategorized
February is Heart Health Awareness Month, so we all wear red and talk about our hearts, but what are we doing every day to make sure we are keeping it healthy? How many hours each day, week, month do we each spend at our desks without so much as a break to get water? If you’re like us, we can sit at our desks for hours on end. So next time you open a different patient chart, or are waiting for a webinar to start or a webpage to load, here are a few exercises you can do right at your desk to promote heart health.nnJust because you’re at the office, that doesn’t mean you can’t incorporate some desk exercises to keep your cardiovascular health on track. Short bouts of exercise between conference calls and checking emails will help improve fitness levels and heart health while burning a few extra calories. In addition, a minimal amount of extra activity can help limit additional weight gain.n
nnHere are five exercises that you can easily incorporate for a healthier and happier workday:n
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- Stretch – Interlace your fingers and reach up toward the sky, as high as you can – keep your palms facing up towards the ceiling.
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- Triceps dip – Find a solid, stable surface such as your desk. Turn away from the surface, put your feet together and place your palms on either side of you on the surface. Bend your arms to dip and raise yourself.
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- Under desk leg raise – Place your hands on either side of your chair for stability. Begin to slowly lift and lower your legs to engage your abdomen muscles.
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- Squat – Stand in front of your chair with your hands facing out, horizontal from the ground. Slowly and gently move up and down in the sitting position.
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- Calf raises – While standing, make sure you have a stable surface if needed for balance, and lift and lower onto your toes.
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nEach exercise can be performed 10 times for three rounds. That will total about 20 minutes to kick-start your cardio and build strength while at work.nnOriginal article published on blog.mission-health.orgnn
Feb 19, 2020 | Uncategorized
The Trump Administration has released their healthcare spending proposal for FY21. These plans are said to foster cost transparency, break down barriers impeding choice and competition, and reduce regulatory burdens. Read the article below to learn more about the Trump Administrations hospital spending plans for FY21.n
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- Hospitals cuts proposed in the FY21 budget include $117 billion in site-neutral payment cuts for on-campus hospital outpatient departments (HOPDs).
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- Hospitals would lose $87.9 billion over 10 years from limits on bad debt payment increases.
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- Hospitals would lose $47.2 billion from site-neutral payment policies for off-campus HOPDs.
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nIn what could be a 2021 preview if Republicans take control of Congress and retain the White House, the Trump administration included a range of sweeping healthcare policy proposals targeting hospitals in this week’s release of its proposed budget.nnThe Trump administration’s FY21 budget proposal emphasizes healthcare policies that would foster cost transparency, break down barriers impeding choice and competition, and reduce regulatory burdens.nnAlthough the current Congress may ignore the budget, the proposals could come back as last-minute funding sources for big budget packages or as part of major healthcare policy changes in the next Congress.nnThe budget projected savings of $844 billion over 10 years through implementation of a “Health Reform Vision Allowance,” which entailed:n
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- Reforming Medicare’s primary care service payments
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- Implementing a value-based purchasing program for hospital outpatient departments (HOPDs), ambulatory surgical centers and post-acute care facilities
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- Offering incentives to improve quality and health outcomes
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nProposed healthcare funding levelsnnThe Centers for Medicare & Medicaid Services (CMS) is projected to spend $1.2 trillion in FY21, or $47.6 billion more than in FY20. The budget proposes $1.6 trillion in CMS spending cuts over the next decade. Those cuts include $756 billion to Medicare over 10 years, which is projected to extend the Hospital Insurance Trust Fund by 25 years.nnThe budget also includes $920 billion in Medicaid cuts over 10 years, in part through increased eligibility enforcement and anti-fraud measures.nnThe budget would provide $5.7 billion for the 1,400 community health centers, which operate more than 12,000 care delivery locations and serve more than 28 million patients.nnHospital revenue would be significantly affectednnThe budget includes policies that would directly affect hospital revenue in widely varying ways, including:n
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- Limiting uncompensated-care bad debt payment increases to the consumer price index for all urban consumers (87.9 billion in savings over 10 years)
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- Requiring site-neutral payments between on-campus HOPDs and physician offices for services, such as clinic visits, commonly provided in nonhospital settings ($117 billion in savings)
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- Eliminating Medicare bad debt payments for disproportionate share eligible hospitals, exempting rural hospitals ($33.6 billion in savings)
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- Requiring all off-campus HOPDs to be paid under the Physician Fee Schedule ($47.2 billion in savings)
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- Allowing increased Medicaid copayments for nonemergency use of emergency departments ($1.8 billion in savings)
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nThe bad debt payment cuts would principally hit urban safety-net hospitals, said Chad Mulvany, a director of healthcare financial practices with HFMA.nnMeanwhile the site-neutral payment cuts would “blow teaching hospitals out of the water,” Mulvany said.nnAmong savings to Medicare more broadly, the budget projects that already-implemented changes to payment arrangements for Medicare accountable care organizations will save $2.9 billion over 10 years.nnPotential good news for hospitalsnnAmong the administration’s priorities is reducing the regulatory burden for providers. The Department of Health and Human Services (HHS) touted a reduction of $25.7 billion in regulatory burdens between FY17 and FY19.nnThe administration aims to add to that amount by requiring regulators to:n
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- By August 2020, issue finalized regulations on processes and procedures for issuing guidance documents
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- By the end of February 2021, establish a single, searchable database on the HHS website that contains, or links to, all of the agency’s guidance documents currently in effect
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nThe budget proposes medical liability reforms that would save HHS $27.2 billion and the federal government $40.3 billion over 10 years. Those reforms include capping awards for noneconomic damages at $250,000, indexed to inflation.nnAnother proposal would consolidate the four hospital quality payment programs in the form of a 5% payment cut that hospitals could earn back.nnThe budget would risk-adjust payments to HOPDs and ambulatory surgical centers based on the severity of patients’ diagnoses, in a budget-neutral manner.nnA value-based purchasing program for HOPDs and ambulatory surgical centers would be implemented, with 2% of payments tied in a budget-neutral manner to performance on quality and outcome measures.nnFor primary care physicians, the budget would create a risk-adjusted monthly Medicare Priority Care payment for providers who are eligible to bill for evaluation and management services and who provide ongoing primary care to Medicare beneficiaries. That payment would be funded by a 5% cut to all nonprimary care services and procedures.nnThe budget would eliminate the requirement that physicians certify all patients at critical access hospitals (CAHs) who are reasonably expected to be discharged or transferred within 96 hours of admission.nnCAHs could voluntarily convert to an emergency hospital that does not maintain inpatient beds, while receiving the same Medicare payment rates as other emergency departments, plus an additional payment to assist with capital costs.nnImpacts on bundled payments and other value-based payment policiesnnA major cut in the budget that was not targeted at hospitals but could directly affect their performance in value-based payment models was the $101 billion in 10-years savings from the establishment of a unified post-acute care payment system across all four post-acute care settings, including long-term care hospitals.nnSuch cuts could eliminate the source of nearly all of the savings obtained by hospital-led bundled payment participants, Mulvany noted.nn”If you suddenly go site-neutral on post-acute care, I don’t know why I join joint bundles, or really any bundle; there’s no savings there at that point,” Mulvany said about how hospital finance leaders might perceive such a change.nnThe budget would incentivize participation in advanced alternative payment models (APMs) by eliminating the participation thresholds needed for physicians to qualify for the 5% APMs bonus.nnIn another proposed tweak to the physician payment system, the budget would alter the Merit-based Incentive Payment System (MIPS) to assess performance at the group practice level instead of the individual-clinician level during the performance period, to reduce physician reporting burdensnnStriving to shore up rural hospitalsnnRural providers were a big focus of the administration’s budget.nnThe administration aims to build on its 2019 temporary increase in the wage index for hospitals in low-wage areas, which are primarily rural hospitals, with a proposed pilot to implement further changes to the Medicare inpatient hospital wage index.nnThe budget also would build on the expanded use of telehealth for Medicare Advantage plans with a comprehensive package to promote rural access to care and telehealth in Medicare fee-for-service.nnRural hospitals would be exempted from the proposed site-neutral payment cut to on-campus HOPDs.nnA new Medicare prospective payment system would be established for rural health clinics, with annual updates based on a market basket derived from cost report data and rebased periodically. Those changes would save an estimated $1.8 billion over 10 years.nnRural health clinics and federally qualified health centers could become distant-site providers for Medicare telehealth and be paid at a composite rate similar to that for comparable telehealth services under the Medicare Physician Fee Schedule.nn340B targeted with oversightnnThe budget would increase scrutiny of the 340B discount drug program, which is used by about 12,000 safety-net hospitals and clinics. A new $34 million oversight initiative for 340B would be established, funded in part by a new user fee based on 340B sales.nnAnti-fraud initiatives includednnThe administration said it cut the Medicare fee-for-service improper payment rate to 7.25%, the lowest since 2010, and projected that continued savings from anti-fraud program changes will provide another $31.4 billion over 10 years.nnThe budget would garner $20 million over the decade through new administrative fees for filing Medicare appeals, which the administration said is needed due to the filing of “non-meritorious appeals.”nnThe package of program-integrity legislative proposals is projected to improve payment accuracy, enhance provider and program oversight, reduce improper payments and support law enforcement.nnOriginal article published on hfma.org
