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Will ACA Change Physicians' Diagnosis or Treatment Regimens?

  
  
  

Preventative vs DiagnosticThe Affordable Care Act (ACA) is here, with all its advantages and drawbacks for Americans. While dissenters still abound, a sense of resignation is descending upon the nation.

Those hoping for a repeal of the ACA continue to be steadfast, although most seem to realize this may be more dream than a real possibility. Critics continue to maintain that the goal of healthcare reform is worthy, but the ACA attacks the wrong problem component. All that may be “accomplished” is transferring the cost of a broken system to Americans, without addressing the core problem.

Preventative Versus Diagnostic Services

One of the patient positives with the ACA is the renewed emphasis on preventative servers, eliminating patient cost sharing. Even the AARP has weighed in on this issue, noting in a recent issue of their magazine some 10 diagnostic tests to avoid, as their cost pales in comparison to their effective results.

Yet, patients and physicians still face a quandary. For example, a preventative service, such as an annual mammography seems to fall within the purview of a test dedicated to prevention. However, should the test result in an abnormal result, physicians often prescribe another such test. This then becomes a diagnostic service, subject to deductibles and patient cost sharing in most ACA insurance plans.

Both patients and physicians would welcome a better defined distinction to eliminate confusion. For example, a physician filing a claim should be confident that the claim is either preventative or diagnostic—it can affect reimbursement levels and/or cause delays.

Diagnostic and Treatment Options

Preventative versus diagnostic services is but one of several ACA-qualified insurance plans inconsistencies. Some are concerned that this and other ACA provisions may change the diagnostic and treatment regimens providers have used in the past.

For example, the ACA seems to include pay-for-performance provisions similar to CMS’ PQRS standards. Physician dissatisfaction with this issue is widespread.

However, the issue of preventative versus diagnostic services may become an equal source of concern. There are numerous real-world potential problems that could affect physicians’ diagnostic or treatment options because of this one distinction. Here are a few examples noted by Physicians Practice.

  • Your billing staff or third-party firm bills for preventative and diagnostic services accurately. But, then your patient complains that, thinking these were preventative services, the patient is very unhappy that some were diagnostic and subject to large deductibles and cost sharing.
  • You spend extra time addressing patient concerns during a preventative visit, but only bill for the preventative services, costing you time and money, as you’ll not be reimbursed for your extra evaluation, analysis and professional advice.
  • You bill for both the preventative and diagnostic portions of patients’ visits, but waive deductibles. You may open your practice to more billing audits for perceived irregularities.
  • Even the time spent deciding which were preventative and which were diagnostic services will challenge the goal of reducing or controlling costs.

Physicians may modify their diagnostic and/or treatment procedures to accelerate or smooth the process for the benefit of the practice. Should this affect patient well-being, when combined with pay-for-performance initiatives, this could negatively affect your revenue stream over time.

Regardless of ACA provisions or restrictions, physicians are cautioned to continue to use good patient welfare judgment with diagnostic and treatment regimens. Delivering quality patient care, while keeping your practice viable, is a required goal, however you get to the end result.

Congressional action, like the ACA, should not dictate diagnosis and treatment selections that “fit” a bureaucratic “box” that must be “checked” to fulfill government or payer regulations. Focus on delivering quality care at the expense of governmental considerations. Your patients’ welfare should always take center stage. You can fine tune your claims reimbursement procedures to better conform to ACA mandates with some practice and repetition.

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For more information about M-Scribe Billing Services please contact 888-727-4234.

Will PQRS Affect Quality Care?

  
  
  

PQRS incentiveThe Physician Quality Reporting System (PQRS) is changing the face of providing patient care and revenue levels. Although this pay-for-performance initiative was introduced by the Centers for Medicare and Medicaid Services (CMS), there are indications that private healthcare payers may also adopt PQRS in the future. Physicians and other critics believe the industry is morphing from a fee-for-service system into a pay-for-performance platform. While this may be the obvious intent of the CMS regulations, private payers apparently are looking favorably on PQRS features.

PQRS submissions have resulted in around $26 million quality reporting incentives since inception. CMS reports that participation in PQRS is increasing with an estimated 280,000 eligible professionals (EPs) enrolled through April 2013.

Participation Growth Slow

The growth of participants, however, remains “slower” than CMS hoped. Observers, healthcare consultants and many physicians seem to agree there is one overriding reason for this modest growth: The documentation burden on medical practices. Yet, there may be some other contributing factors, when combined with the reporting burdens.

  • The general dissatisfaction with a pay-for-performance model,
  • The bonus incentives, two percent, may be insufficient to stimulate providers to adopt PQRS,
  • Although many providers agree that the healthcare system needs revamping, some veteran physicians may feel the way they’ve delivered patient services ensures quality care, regardless of providing additional evidence to CMS.

When combined with documentation mandates and the push by the Affordable Care Act (ACA) to implement pay-for-performance, many EPs consider the risk, cost and extra work as not matching the reward. The ACA 1.5 percent reimbursement penalty for insufficient reporting only adds to the dissatisfaction and also may be slowing PQRS participant growth.

Affect on Quality Patient Care

The intent of PQRS is noble: Improve patient care, while lowering or better controlling costs. There is little disagreement with the goal.

However, this also begs the question, “How can I deliver higher quality care at lower cost?” The dissatisfaction comes with the lack of workable answers by the medical community, to date.

Many providers believe the documentation needed to provide evidence to CMS of quality diagnosis and treatment activities to be a disincentive to even seeing as many patients as in the past. The requirement of recording actions that CMS considers incontrovertible proof of quality care delivery takes physicians extra time to note, resulting in more staff time to prepare accurate claims submissions.

Experts recommend the physician or practice manager install an “accuracy review” procedure to catch errors before submitting claims. Providers maintain this adds even more non-care delivery time to their day and/or more, not less, cost to practice operations.

While most EPs would love to improve or maintain the quality care they deliver, many simply find the challenge of documenting every nuance of diagnosis and treatment methodology as a detractor from controlling costs. It is difficult to forcefully argue with their position so far.

Those who are optimistic that, over time, EPs will develop reporting systems that satisfy PQRS requirements tend to remain unsure of how to do so. However, providers often believe the melding of bureaucracy (CMS) with quality patient care may be an unworkable marriage.

The Future

Should private payers install PQRS or similar pay-for-performance requirements, might physicians face even greater challenges? Many providers believe the answer to be “Yes.” Is this just negativity, resistance to change or veteran providers being “set in their ways?”

Or, is it the thoughtful analysis of documentation requirements that detract from quality patient care delivery for less than desired reward? The medical community and CMS are unsure of the true answer. As long as the passionate debate continues, there will be divergent supporters and critics of PQRS—and its requirements.

Patients, providers and observers should stay tuned for future developments.

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Understanding Building Blocks of Delivering Quality Care-PQRS

  
  
  
PQRSEligible Professional's (EPs) who bill Medicare (using the new 1500 claim form) and satisfactorily report quality-measures data for services furnished in year 2014 are eligible to earn a extra incentive equal to 0.5% of the estimated total allowed charges for covered Medicare Part B Physician Fee Schedule (PFS) services.

These new quality care incentives, although many medical providers question the use of the word “incentives,” mandate that physicians continue delivering quality patient care to satisfy the stated guidelines. Ensuring high quality care is a challenge, compounded by numerous new regulations, which can best be faced with provider understanding of the components of high care performance.

According to Medical News Today, there are identifiable features, or building blocks, that researchers have identified as key elements in delivering consistent quality patient care. Physicians and practices committed to a continuing delivery of quality care in the face of changing and expanding government regulations should consider these essential building blocks.

Doctors and practice managers should take the time to introspectively analyze whether they employ these foundations. If some of these key elements are being overlooked, providers should strongly consider introducing missing elements to their procedures. Research indicates they will be pleased they took the time to integrate these elements into their policies and procedures.

Key Elements of Delivering Consistent Quality Care

Consider these important “foundational elements.”

  • Ensure engaged practice leadership,
  • Improve data collection and recording,
  • Practice empanelment as routine procedure, and
  • Implement team-based care.

These foundation elements, help providers successfully install the remaining components.

  • Create a patient/team partnership environment,
  • Consider population management as a practice priority,
  • Commit to continuity of care,
  • Always provide prompt access to care,
  • Coordinate and explain care procedures, and
  • Create a “template” of the future.

Research identified these essential features after study of high-performing primary care practices. The common shared vision of these practices: Creating a patient-centered environment.

Physician Quality Reporting System (PQRS) Role

PQRS is intrinsic to creating a quality care practice. Although potentially burdensome, PQRS gives providers 2014 to install the system before downward “payment adjustments” take effect in 2015 for unsatisfactory reporting.

EPs should understand the system to create documentation evidencing quality care for reimbursement purposes. Dissenters believe PQRS is a another example of the government requiring the medical community to do some of its work—at provider cost—to administer its bureaucracy. Whether a desired or unintended consequence, non-compliance can result in penalties for inadequate reporting.

EPs who deliver Medicare and Medicaid services should use 2014 as a training and implementation time period to integrate PQRS into their practices. This action plan should minimize or eliminate costly claim denials in 2015 and beyond.

Developing a Model That Works for You

We cannot overstress the importance of integrating these elements into your own practice. If, after introspective evaluation, your practice lacks one or more of these vital components, strongly consider installing them as soon as possible. Be specific, not general. Devise attitudes and techniques that will integrate these elements into your daily practice routine.

Commit to creating the mindset in yourself and your staff that alternative options run the risk of falling short of achieving efficient and effective quality patient care—and having the evidence (data) to validate your commitment. The extensive recording and documentation regulations will provide the evidence you need to prove your practice is more than just in compliance. Your records will display you have gone beyond planning to build a working quality care model—you have done it.

While all of these key elements are important and necessary, it all starts with engaged leadership. If you tend to focus on delivering quality care only, be sure the other leaders in your practice are thoroughly engaged. How will you know?

Your leaders truly care about making the practice all that it can be. Engaged leaders do not view their position as a “job.” They do make the practice part of their fabric and personality. Engaged leaders are totally committed to high performance by everyone involved, regardless of titles or duties. Identical to every other organization, medical practice excellence starts at the top and works its way through everyone involved.

Build or maintain your practice excellence by heeding these foundations. Employ all, making them part of every day operations. You will deliver consistent, optimal patient care and enjoy more efficient, profitable practice performance.

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Has the Federal Government Declared War on Physicians?

  
  
  

Medical Management ServiceStarting with one family physician from Alabama contacting his congressman to request help fending off "Washington's war against doctors," he expressed the feelings of many of his medical peers. This one doctor also noted that "doctors are smothered by destructive regulations that add costs, raise our overhead and 'gum up the works,' . . ."

He is not alone. Many physicians believe these burgeoning regulations are dictating they target other things at the expense of quality patient care. Some doctors also feel these documentation regulations are reducing the number of patients they can help each day.

Combined with electronic health records (EHRs), the once again delayed ICD-10 code implementation until 2015 (or beyond?) and the ongoing Obamacare issues, other issues are only compounding physician dissatisfaction. Some providers feel that Washington is attempting to mimic an equally unsatisfactory government bureaucracy.

While the government bureaucracy claim may be stretching reality, it is easy to understand the other issues are that cause provider dissatisfaction. However, those physicians hoping for a return to the former status quo, will be disappointed, as it simply will not happen. Too many things have changed in the healthcare landscape, including the controversial Obamacare.

Obamacare Effects

According to PhysiciansPractice.com, for all its many faults, Obamacare did our country a valuable service. The Affordable Care Act (ACA) has exposed the real healthcare problem. Unfortunately, Obama care focuses on the wrong problem, as it is not the fault of Americans that healthcare costs have escalated to unacceptable levels.

Obamacare only transferred these unacceptable costs to American individuals and small businesses. The White House focus is skewed and ineffective. Yet, physicians and practices reap no benefits from healthcare reforms, only more regulation and paperwork. For some reason, Washington believes physicians can deliver quality care to the same number of patients (or more), while lowering costs, in the face of increasing documentation requirements.

Regulatory Requirements

Reducing costs while delivering quality care is a noble goal. This objective, however, is more attainable without increasing regulatory requirements. Cutting wasteful spending is always a practice goal, but it is being made more difficult by the government's consistent need for more detailed documentation to allegedly verify the quality of patient diagnosis and treatment procedures.

The methods used to reduce the runaway cost of healthcare need some physician creativity. It appears that the only way to win the "war" is through the effective action of medical providers to focus on quality care and expense reduction at the same time.

Remember, the Congress and the White House do not view their regulatory actions as declaring war on the medical community, only exercising their duty to protect Americans. While it is difficult to believe Washington is unaware of the unreasonable burdens they are placing on providers, physicians must analyze their own operations, finding ways to cut waste and make their practices more efficient.

How to Win the “War”

There are suggestions that can help physicians fine tune practice operations to achieve success in this confusing, burdensome new environment. Consider these suggestions when designing your policies.

  • Learn to use state-of-the-art technology to streamline HIPAA and governmental reporting requirements.
  • Encourage practice staff to "think" like entrepreneurs, seeking better ways to do things.
  • Implement creative new policies and procedures a step at a time, instead of overwhelming staff.
  • Consider a proven medical management service organization, such as M-Scribe Technologies, to control practice costs, ensure efficient claims processing to maintain revenue streams, and allow physicians to concentrate on delivering quality care, without concern for regulatory compliance requirements.

Use some or all of these general tips to craft an action plan, with specific operating procedures, to satisfy the need to deliver quality patient care, control expenses, maintain revenue levels, while staying in regulatory compliance. Your contribution to healthcare reform can win the "war" with Washington, while also reaping benefits for you, your practice and your patients.

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Three Steps to Selecting the Right ICD-10 Codes

  
  
  

ICD-10 code selectionThe October 1, 2014 deadline for implementing ICD-10 codes is sneaking up behind you. Is your practice ready to make the transition from ICD-9 to ICD-10?

If not, your practice faces some rough times ahead. The 2014 ICD-10 contains nearly 70,000 codes, providing ample room for error when selecting codes. Almost none of the code numbers remained the same from ICD-9 to ICD-10, and it is not as easy as translating the old ICD-9 codes into new codes.

A poor transition from ICD-9 to ICD-10 has real consequences for any practice, whether it is a large hospital or single practitioner practice. Selecting the wrong ICD-10 codes will result in disruption of reimbursements, low reimbursements, and claim denials. Ill-prepared coders will likely grow frustrated with returned claims, denied claims, and requests for more information.

Fortunately, you can select the right ICD-10 codes in just three easy steps.

Step 1: Use the ICD-10 alphabetical index

Locate the main term in the alphabetical index. Review the list of sub-terms and select the most appropriate sub-term specific to the case. Read the instructional notes about how to add terms like “see,” “see also,” “with,” "without,” “due to,” and “code also.”

The “see” and “see also” instructions in the alphabetical index mean you should reference another term to find the correct code. The “code also” note describes a case where you will need to enter two codes to describe the situation fully.

Step 2: Verify the code with the tabular list

Use the tabular list to verify the code. The tabular list groups the ICD-10 codes according to chapter, categories, and subcategories. Be sure to review the notes appearing at the top of the tabular list, as that information can help you select the correct code.

The tabular list allows you to provide more information about the visit. Use the tabular index to describe the severity of the patient’s condition and any complications associated with the case.

The tabular list helps you reduce your selections to only the appropriate codes. Use the tabular list to describe “Excludes 1” and “Excludes 2” rules that identify codes you should never use together and at the same time, respectively. Excludes 1 would prohibit you from entering J05.0 with J04.0, for example, because both describe acute laryngitis.

Furthermore, the tabular index contains information that determines the length of the code, which can be anywhere from three to seven characters long.

Step 3: Review coding guidelines

Read over those coding guidelines at the top of the alphabetical listing. It includes specific information for some of the more complex codes, such as sepsis and HIV. Miss this section and you might miss vital sequencing guidelines. The sequencing order for a patient with anemia resulting from malignancy, for example, is completely different from a case where chemotherapy, radiation or immunotherapy caused anemia.

You can reduce confusion, frustration and loss of reimbursements by preparing your practice for the ICD-10 transition now. Encourage all staff members to learn how to implement the new ICD-10 codes into your practice. Teach these three easy steps to every worker who records information about patient care and ease the tension in your office when October rolls around.

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For more information about M-Scribe Billing Services please contact 888-727-4234.

Clinical Documentation Improvement is critical for Private Practices too!

  
  
  

Clinical Documentation ImprovementClinical documentation improvement, or CDI, is a hot topic in hospital and clinic roundtable discussions but it is also important in the outpatient setting.

An increasing number of insurance companies are submitting queries for more information and denying claims when the institution cannot provide the clinical documentation to support a claim for payment. The government is working harder to catch fraud and abuse then recoup improper payments. Medicare and Medicaid are also requesting more information on claims to reduce abuse.

These changes force healthcare providers to streamline their practices towards providing meaningful healthcare at a low cost. CDI gives outpatient clinics the platform they need to streamline these practices by reducing queries, claim rejection rates and government inquiries.

Then there is the ICD-10 implementation deadline of October 14, 2014. Hospitals and clinics beefed up CDI to meet this deadline but many institutions are still not ready – especially smaller institutions like outpatient clinics. The American Academy of Professional Coders, or AAPC, says “After thousands of ICD-10 assessments, we’ve noticed that only 37 percent of today’s documentation is ready for the transition.”

CDI in the Outpatient Setting

CDI is as relevant in outpatient settings as it is in hospitals and offices. Like other institutions, outpatient practices rely on accurate diagnosis codes for DRG reimbursements and other reimbursement-based programs; CDI provides the information necessary to ensure accuracy in submissions in the outpatient setting. Furthermore, these codes affect physician scoring, healthcare policies and insurance coverage.

Benefits of CDI in outpatient setting include:

  • Fewer claim denials and rejections
  • Increased reimbursement, especially in HCC/risk adjustment coding and quality improvement programs
  • Fewer physician queries
  • Optimized coder productivity
  • Improved documentation
  • Enhanced patient quality measures and continuity of care
  • Improved communication with providers

Enhancing CDI Relevance in Outpatient Settings

Remember that CDI’s relevance goes deeper than simply using the correct ICD-10 code. The Centers for Medicare and Medicaid, or CMS, says that when trying to implement CDI strategies, you should “Identify documentation improvement opportunities that could impact multiple initiatives – don’t focus solely on ICD-10-CM”

The transition process entails more than just translating your handful of ICD-9 codes into the new ICD-10 codes. While creating “cheat sheets” is important, it is more important to learn how to provide proper documentation to back up the codes you use.

Start by creating a CDI position in your outpatient clinic. Hospitals often hire registered nurses to do in-house coding and CDI. Outpatient practices can use this same strategy by training one or two RNs interested in taking an online medical coding program that leads to certification in coding in auditing.

Initiate CDI implementation in your outpatient practice by first performing a few retrospective audits. Grab a handful of random samples from your most common and problematic claims. Determine whether each has the documentation necessary for billing and coordination of care. Create a panel of physicians, billers and coders to discuss how they would have applied the new documentation rules to these older cases.

Establish a means of communicating deficiencies found in reviewed documentation. Be sure your outpatient office electronic health record, or EHR, system can send and receive electronic queries or an HIPAA-compliant email system.

CDI helps you keep track of improvements and spot patterns. Monitor query traffic for the number of queries and the type of information the payer requests. Look for positive and negative patterns, and use what you see there to develop training strategies.

CDI is more relevant in the outpatient setting than ever before. Implement CDI practices as soon as possible to work out the kinks before the October 14, 2014 deadline.

ICD-10 and Documentation
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Most Common Reasons for Medical Claims Denials and their Remedies

  
  
  

DenialsToday’s physician and doctor office faces shrinking reimbursements and increased claim scrutiny from third parties. If your practice is like most, it gets most of its revenue from submitting CPT and ICD-10 codes. Third party denial of your claims costs your practice – and all the physicians practicing there – big bucks.

Remit Data, an independent source of healthcare data analytics, regularly compiles a list of the most common denials for medical claims filed in February of 2014.

Top Five Most Common Unexpected Denied Procedures

  1. 99213: Outpatient doctor visit, level 3
  2. 99214: Outpatient doctor visit, level 4
  3. 36415: Routine blood test
  4. 97110: Therapeutic procedures
  5. 99232: Subsequent hospital care visit, level 2

Practitioners are often surprised when a payer denies payment for a 99213 procedure, as many physicians and coders look upon 99213 as the default code for almost every E/M service. It is possible many filers think any higher code would require too much information or that 99214 are beyond the level of service they really rendered.

On the other hand, payers are increasingly rejecting 99214 submissions because practitioners seem to be filing more 99214s than ever before.

Speaking of unexpected denied procedures, who could have predicted denial on payment for 36415? They are, after all, just routine blood tests.

The Top Five Reasons for the Top Five Unexpected Denials

The Claim Adjustment Reason Codes, or CARC, sheds light on why payers denied those claims so frequently. Remit Data also lists the top five CARC codes and reasons for those top five common denied procedures:

  1. 18: Duplicate claim/ service
  2. 97: The benefit for this service is included in the payment/allowance for another service/procedure that has already been adjudicated
  3. 16: Claim/service lacks information or has submission/billing error(s) which is needed for adjudication. Do not use this code for claims attachment(s)/other documentation. At least one Remark Code must be provided
  4. 96: Non-covered charge(s). At least one Remark Code must be provided
  5. 109: Claim/service not covered by this payer/contractor

Most CARC 18 violations are the result of simple mistakes but this error can cause loss of revenue and major headaches. Medicare reminds providers and suppliers to stop filing duplicate claims, as doing so may delay payments. Medicare also warns that they identify providers and suppliers who file duplicate claims regularly as an abusive biller. Medicare officials may launch an official investigation potentially resulting in fraud charges if they see a pattern of abuse develop.

CARC 19 is the newest addition to the top five lists. In January of 2014, reason codes 29 and 22 took the numbers 4 and 5 spots, respectively.

CARC violations are usually process-related issues that you can solve with relative ease through additional training for everyone who uses codes. Assess your current compliance management systems, and look for ways to improve compliance. Consider implementing pre-submission payer and contractor confirmation. While these resolutions might be time consuming at first, they greatly reduce claim denials and potential trouble with Medicare.

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For more information about M-Scribe Billing Services please contact 888-727-4234.

ICD-10 Planning and Assessment

  
  
  

ICD-10 implementationIf your practice or organization hasn’t already begun the processes of assessing, planning and implementing training and other matters related to transitioning to the ICD-10 coding October 1, 2014 deadline, there is still time to become trained, systems-ready and become compliant before then. If you’re not sure where to begin or what considerations and tasks should be on your readiness checklist, M-Scribe and its team of experienced professionals can help make the transition process easier and faster for you and your staff.

Perhaps the most critical part of a practice’s successful transition to the new ICD-10 coding system is the Planning and Assessment stage. Proper planning lays the groundwork for your health care billing team to obtain the necessary upgraded software, equipment, and training as well as to develop staff proficiency with the new coding system well ahead of the October deadline. Waiting until the last minute can result in overlooking necessary tasks and processes, leading to frustration, deficiencies in staff ICD-10 readiness training, unexpected software and other systems upgrades causing billing, posting and other delays, as well as other coding and billing headaches.

M-Scribe’s team can assist you and your staff with the following tasks to ease the transition to ICD-10:

  • Develop a list of tasks that need to be completed prior to implementing the ICD-10 coding in your practice or organization, as well as develop a realistic timetable for completion. These will include identifying tasks, those responsible for executing each task, resources and other dependencies specific to your practice or organization, its existing policies, processes and systems, as well as where the current ICD-9 fits in with the organization, and the expected effects of ICD-10 changes to the practice, including electronic health records.
  • Identify and plan a realistic and comprehensive budget that includes upgrades to software as well as training expenses, coding guides and Superbills.
  • Work with you to designate transition responsibility to either one person among your staff or to a committee, depending upon your organization’s size and budget.
  • Review the facts and background information about ICD-10 and its benefits with both management and billing staff. The new coding’s benefits include expanding the flexibility of coding by increasing the length to seven characters, thus permitting coding specific complications, severity, conditions and other factors affecting accuracy and detail. More detailed reporting as well as analytics outcomes and utilization should result in improved claims reporting and processing on both the practice’s end as well as with the carriers. When your staff understands the reasons behind the new coding, learning the new ICD-10 system will seem less burdensome.
  • Identify necessary changes to systems, as well as costs and testing to successfully transition. You will also need to ask your software and/or systems vendors about the time frame required for testing, including starting and ending dates.
  • Review transition plans and contracts with affiliated physicians and hospitals, trading partners and other vendor agreements, including billing services, clearinghouses, and software or systems vendors for their ICD-10 readiness.

Once the initial planning and needs assessment is in place, M-Scribe’s team can assist you with the implementation and adoption of ICD-10. Your practice should find that with the adoption of ICD-10, with its more sophisticated and detailed coding, it will be easier to establish more efficient payment services as well as weed out fraud and abuse, improve medical decisions on a clinical level, measure the quality of patient care and keep track of issues in public health.

M-Scribe Technologies, LLC has been a leader in the health care billing and documentation services industry since its founding in 1999, serving practices of all sizes and specialties. Contact us today at 888-727-234 or visit us online for an in-depth consultation and evaluation of your practice’s unique needs to ensure that your organization is ICD-ready and compliant before the October 2014 deadline.

FREE ICD-10 WebinarClick For Dates & Time!

For more information about M-Scribe Billing Services please contact 888-727-4234.

Mitigate HIPAA Risks With a 'Best Practices' Checklist

  
  
  

HIPAA checklistMedical providers are aware of the risks and penalties associated with HIPAA regulations. Yet, healthcare professionals sometimes become so busy with providing diagnosis and treatment, they overlook some important best practices to remain in compliance.

Creating a HIPAA checklist for staff--and themselves--helps providers and practices mitigate these risks to avoid costly penalties. Expanded requirements involving EHRs (electronic health records) have compounded the potential issues leading to non-compliance. Consider these suggestions to bring into or keep your practice in HIPAA compliance.

Suggested Best Practices Checklist

  • Fulfill all patient record storage rules. Be sure you have locked areas, with visual monitoring, for patient records, whether electronic or paper files. Employ intrusion detection systems, with clear alarms, and maintain safe environmental conditions to avoid fire or other file destruction. Instruct all employees how to use, monitor and take action if storage security is breached.
  • Screening, hiring, and training employees should include HIPAA risk minimization information. Using thorough background checks for staff candidates and training new staff on the specifics of HIPAA protected health information rules will lower or eliminate HIPAA patient privacy violations. Avoiding practice violations caused by honest errors by employees is vital to continued compliance and penalty elimination.
  • Install sufficient staff controls on access to patient information. Develop procedures for staff access to patient records that are appropriate for each employee's responsibility level to eliminate unauthorized access to protected patient information. Regardless of practice or staff size, design written plans that you follow religiously. Larger practices demand more detailed plans, but still involve designating a specific person or department to authorize access, passwords and prompt deactivation of credentials for separated employees, regardless of authority level.
  • Plan for security measures and contingencies. A written risk analysis of potential unauthorized access to protected information should alleviate many costly HIPAA violations. Also, plan and execute secure backup procedures that include written disaster recovery policies. Along with physical access limitations to paper files, create procedures for electronic access restrictions. After identifying possible risks, develop policies to immediately address breaches of security. Include all possible contingencies in your procedures to minimize unwelcome surprises for which you have no remedial policy in place.
  • EHR and paper patient records need secure, written transmission or transportation policies and procedures. When digital EHR or paper files must be transmitted or transported to others, secure all information to be moved. Remember to also employ documented chain of custody procedures to ensure protection against claims of a broken chain. For physical transportation issues, address both information security and vehicle security to minimize protected information violations.
  • Be sure all vendors the practice uses are HIPAA compliant. Always ask vendors for evidence that they are HIPAA compliant before doing business with them. Your responsibility and potential liability dramatically increases if you associate with vendors that cannot prove they are HIPAA compliant.

If your practice faces additional HIPAA risks, add these items to your checklist. For example, if you must physically transport health record documents often, you might want to include more detailed best practice operating procedures to ensure security and chain of custody tracking systems. The probability of violations increases with the number of transport and transmission repetitions necessary.

Preparing a best practices checklist and policies addresses at least three potential problems.

  • Checklist keeps employee accidental HIPAA violations to a minimum.
  • Checklist provides a "road map" of remedial actions to solve recording, privacy and security problems.
  • Checklist and contingency plans display practice and provider concern for staying compliant with HIPAA rules and regulations.

Be sure to write down all plans, policies and procedures. Oral claims of having remedial and preventative procedures typically will "fall on deaf ears." Keep a secure backup of all checklists and compliance policies, in the event your original copies are accidentally destroyed.

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How to Manage Stage 2 Meaningful Use Requirements

  
  
  

EHR Incentive Stage 2Many medical providers still remain unsure of how to attain and manage meaningful use final rules to fulfill criteria and requirements. As the incentive program--which some claim is more of a disincentive measure--moves to Stage 2 in 2014, prior criteria expands with increased requirements.

Understanding these targets and requirements are imperative for compliance, which should protect practice revenues. Stage 2 objectives involve expanded detailed clinical processes that place more responsibility on the medical community to create additional documentation, possibly added cost and more opportunity for errors. First, eligible professionals (EPs) must realize what is required to address and manage these issues efficiently.

Stage 2 Criteria and Focus

  • More detailed health information exchange (HIE) necessities,
  • Additional e-prescribing and lab result requirements,
  • Ability to transmit patient care summaries via multiple platforms, and
  • Create more detailed data under patient control.

These are the primary targets of Stage 2 meaningful use final rules. These are the general focus of Stage 2, and assume medical providers have fulfilled Stage 1 requirements, applicable during 2011 and 2012. The overriding target of Stage 1 was the electronic capture of patient care and treatment information, ensuring quality control of care and delivering data for public health information purposes.

Satisfying and Managing Stage 2 Objectives

Core Objectives include the following final rules. The primary targets are to improve care quality, patient safety and reporting efficiency. Here is a partial list of primary goals for 2014.

  • Electronic order entry for medications, lab tests and radiology actions,
  • Use of e-prescribing (eRx) systems,
  • Create the ability for patients to view, download and or transmit their health information,
  • Record more detailed clinical summaries,
  • To ensure privacy and security, install improved security protection of health data.
  • Make lab test results available and thorough,
  • Offer patient education resources,
  • Maintain electronic patient lists,
  • Use of secure electronic messaging to peers and patients,
  • Record all medications and reconcile their use,
  • Clearly document all preventative care provided, and
  • Note all immunization treatments.

Stage 2 targets include the following objectives. The primary goals remain to improve care, safety and efficiency for patient diagnosis and treatment, along with improving public health results. The following issues are specific to eligible medical providers.

  • Provide "syndromic surveillance" data,
  • Make "notes" on electronic health records (EHRs),
  • Offer clear imaging results, with appropriate explanations,
  • Digitize family health histories,
  • Report all cases involving cancer, and
  • Electronically report significant specific cases.

Managing these requirements begins with ensuring you follow the meaningful use rules and maintaining documentation that evidences your compliance. The inability to comply and/or prove your adherence to Stage 2 rules will negatively impact your revenue and claims submissions.

As should be obvious, managing Stage 2 requirements involves no "magic bullet." Successfully achieving Stage 2 meaningful use goals do involve achieving the stated objectives, along with the ability to prove you did so.

If you consider these Stage 2 requirements a daunting challenge, as many EPs do, consider outsourcing these requirements to a top third-party, proven medical documentation firm. You will enjoy these advantages, at a minimum.

  • Better protect your current revenue levels or create additional income,
  • Security of knowing that the firm's staff is thoroughly trained in Stage 2 requirements,
  • Receive assurance that meaningful use rules are consistently followed, and
  • Control your costs, while minimizing errors.

Lowering the probabilities of mistakes by overworked and overtaxed busy staff is critical to managing Stage 2 meaningful use requirements. Since most EPs and practice managers are equally busy, it is often unreasonable to expect they can devote the time to guarantee that all rules are followed.

If you choose to comply internally, be sure to create written policies, procedures and checklists for you and your staff to follow to better ensure compliance. Remember, it is ultimately the EP's responsibility to comply with Stage 2 meaningful use rules and objectives.

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