There are a number of current and future guidelines and regulations coming that will impact your office.
The number of RAC audits have increased significantly over the past quarter. It is imperative to be proactive. Most physicians that fail these audits are ill-prepared, and do not have a team assembled to gather and submit information in a timely manner to the different appeal levels. Of the audits I have participated in, most can be won or significantly reduced by being proactive.
The overwhelming majority of RAC appeals that have been favorably overturned have been to hospital providers. Hospitals take these audits more seriously and have a proactive team in place before the first letter hits their desk. Physician groups wait and start the process late in the game, increasing their legal expenses and, in many cases, have missed the audit time line.
Here is one of the more ‘positives’ we have all been waiting on. Starting in May, you and your office staff can register providers for the Electronic Health Record (EHR) Incentive Program and also attest that that they met meaningful use criteria and are eligible for federal bonus money.
Here are the four steps to get through the process:
- Get login information for providers. https://ehrincentives.cms.gov/hitech/login.action
- Click the registration tab
- Enter all personal information. Aside from the full name of the provider and the business address, you also must enter the provider’s Social Security Number, national provider identifier (NPI) and a valid email address.
- Submit registration and complete the process. Once the information is complete, hit the “submit” button and wait for CMS to approve the registration.
CMS’s 20 page registration guide for providers: http://bit.ly/EHR_registration_user_guide
CMS recently released an informational MLN Matters article to provide practices with some guidelines on retaining medical records. While the article notes that a State law usually regulates how long medical records should be retained, the strictest regulation would prevail. Access this article at: http://www.coms.gov/MLNMattersArticles /downloads/SE1022.pdf
Chiropractic claims have been identified by CMS because the Medicare program only pays for medically necessary acute chiropractic services and does not cover “maintenance” therapy. Proper documentation is vital because audits are based on being “medically necessary.” Many providers with proper documentation can get many challenges overturned with proper documentation.
Physical Therapists are to be the first targets of Comparative Billing Reports. This is another tool in the arsenal of CMS to identify improper payments and to ‘educate’ (yeah right). The Comparative Billing Report (CBR) is designed to compare individual providers to their peer groups, looking at specific procedures and services and they were billed.
As the title indicates, this is only the first and new CBR that will be produced and sent out monthly. For more information go to http://www.safeguard-servicesllc.com/cbr/default.asp
At Watkins Uiberall HealthCare Consulting Group LLC we work closely with our nationally BKR affiliates, the Medical Group Management Association , the American College of Healthcare Executives and other organizations stay current on regulations and trends impacting healthcare.
Bill Appling, MBA, FACMPE, is president of Watkins Uiberall Health Care Consulting. He has faculty appointments at the University of Memphis in the Fogelman College of Economics and Business, where he teaches in the Masters of Health Care Administration program.