Happy Holidays!

Warm Holiday Wishes to You

Happy Holidays!  May you be blessed with the riches of life.  As we wind down the year, the holidays are a time to spend with friends and family sharing joy, laughter, and love.  The holidays are also a time of reflection and gratitude.  I want to thank each of you for making this a successful happy year, it has been a true gift in my life.  So many of you are friends, business advisers, business partners, clients, and maybe all of these, but you are truly appreciated.  Some of you make me reflect more often than I might like but I’ll keep you anyway..LOL.  I wish each of you a happy and safe holiday that is a road to a successful new year for you, your family and business.   I look forward to you being a part of my life in 2011 too.

Remember to pray for our soldiers and their families during the holidays, and if you see them during travels thank them.

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How to Connect with Medical Auditing Solutions LLC?

You can find a complete scope of services under my blog.  In short, I work with most types of health care providers to setup compliance programs and training and anything that impacts cash flow.

You can follow us through our blog by scrolling to bottom of this blog, click follow then enter your email address.

You may follow Angela Miller and Medical Auditing Solutions if you a a profile on any of the following:

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Those who have recently attended a speaking engagement, I am connecting you through my blog. If you want to connect on the other sites feel free. I do not send out many email blast and utilize my blog the most.

Physician Fee Cut on Hold & 2.2% Increase for now

Docs Get Six-Month Reprieve; Industry Looking for Longer Fix
WASHINGTON—President Obama signed legislation Friday canceling a scheduled 21.2 percent pay cut for Medicare physicians and instead giving them a 2.2 percent increase. While it offers the docs some current relief, the new measure is effective only through the end of November.

That means months, a decade even, of congressional wrangling over the issue could start up again before the year’s end, offering HME advocates another shot at a possible legislative vehicle that could carry language to stop competitive bidding.

The American Medical Association and other physician groups have been urging Congress to revise Medicare’s current “sustainable growth rate,” or SGR, payment formula—which has resulted in annual pay decreases for physicians over the past decade—in favor of a permanent fix. But the cost of such a change has quashed any long-term action.

“Delaying the problem is not a solution,” the AMA said in a statement issued last week. “It doesn’t solve the Medicare mess Congress has created with a long series of short-term Medicare patches over the last decade—including four to avert the 2010 cut alone.”

In December, the physician pay cut “will be a whopping 23 percent, increasing to nearly 30 percent in January,” the statement read.

“The baby boomers begin entering Medicare in six months, and if the physician payment problem isn’t fixed, these new Medicare patients won’t be able to find a doctor to treat them,” the AMA said.

In a Friday afternoon legislative update, Waterloo, Iowa-based VGM Group said because the cuts to physician reimbursement have only been postponed through November, “the temporary ‘doc fix’ will need to be addressed once again towards the end of the year. This will offer another vehicle to eliminate competitive bidding.”

In the meantime, the group urged continued support for H.R. 3790 to repeal the bidding program.

LATE-BREAKING: CMS’ proposed physician fee schedule for 2011, released late Friday, calls for a 6.1 percent cut for Medicare physician services that would take effect Jan. 1, 2011.

As outlined under health reform, the proposed regulation would also expand Round 2 of the DMEPOS competitive bidding program from 70 MSAs to 91, for a total of 100 in the national bidding program.

Taken from http://www.homecaremonday.com weekly email blast received today.

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Angela Miller of Medical Auditing Solutions LLC has been in health care compliance, auditing, billing, collections and HIPAA for over 18 years.  Ms. Miller has made it the  focus of the business to help providers run their businesses efficiently, collect money, and maintain compliance with federal and state regulations and coverage criteria through compliance program development, management and training.  Ms. Miller is very experienced with Medicare & Payer audits.  Ms. Miller ran a very successful compliance program for over 5 years for the largest private held HME/Pharmacy provider in the US at the time.  Ms. Miller  also works as a contract compliance officer to provide an avenue to compliance training to staff, implementation of policies, as well as handling anything that affects cash flow from the initial intake to back-end collections. You can visit our website at Medical Auditing Solutions LLC.

Medicare Timely Filing Reduced to 12 Months

As you may recall in my earlier health reform blog,  I noted that one of the several changes to be implemented was the reduction of the initial claims filing period reduced from 18 months to 12 months.  I would encourage you to read the other operational changes impacting collections noted in the blog.

Region A MAC and HCCA Compliance Weekly published the system change on May 14.  Each contractor may have a different published date but it appears that the announcements will be coming very shortly.

Note the change is RETROACTIVE to all claims on or after January 1, 2010! This would indicate that CMS has most likely directed all contractors to this announcement.  Notify your billing staff ASAP, they only have 1 year to file an initial claim.  For providers who must receive documentation from physician’s prior to billing, you must be more diligent than ever before.  If the physician’s are not providing the necessary information to bill for the services ordered, get the patient involved.  The patient can request a copy of their record at any time and can carry the order to the physician for signature.

Angela Miller of Medical Auditing Solutions LLC has been in health care compliance, auditing, billing, collections and HIPAA for over 18 years.  Ms. Miller has made it the  focus of the business to help providers run their businesses efficiently, collect money, and maintain compliance with federal and state regulations and coverage criteria.  Ms. Miller is very experienced with Medicare & Payer audits.  Ms. Miller ran a very successful compliance program for over 5 years for the largest private held HME/Pharmacy provider in the US at the time.  Ms. Miller  also works as a contract compliance officer to provide an avenue to compliance training to staff, implementation of policies, as well as handling anything that affects cash flow from the initial intake to back-end collections. You can visit our website at Medical Auditing Solutions LLC.

Security Tips to help with HITECH Compliance

Here are some tips for added security, but this is not a substitute for using an IT person, who is familiar with HITECH/Red Flag Regulations.  Remember, encryption prevents the need to report disclosures to HHS and avoids penalties.  These are not the only solutions, so no matter what it is crucial to find encryption solutions.  These are the ones I have implemented although I rarely have more than a patient name in reports and do not have more than a patient name or account number in audit reports. 

Prior to starting any process and for your business sanity, ensure you have a current backup of your system.  Remember, onsite backup should have enough “disks” to rotate for several weeks.  Also they do need to be replaced periodically because they can fail after they have been used repeatedly.  There are many free or inexpensive options for offsite and automatic backups including Carbonite, Mozy, Amazon S3, Rackspace and others.  The Jungledisk interface which backs up to Amazon’s S3 or Rackspace is an automatic backup that is thoughtless and has saved my butt many times. These also permit you a second “drive” that can function as a network drive if you need to work on a document while you are away from your office; although you do need internet access.

Security software can be vastly expensive and still not catch viruses.  I use AVG for small business which is about $50/year.  AVG has a firewall plus I have a network firewall.  If you use a wireless network, make sure your settings are the highest or newest released, as of the moment that will be WPA2. I changed my own settings so it is relatively easy.  I have had great luck with AVG from a protection standpoint.  This does not bog down my system so I have to push molasses up hill.  The processing speed is barely impacted.

Truecrypt is a hard drive encryption program that is free for home and small businesses.  The company price is very inexpensive!  It has 256-bit encryption and most banks use 128-bit so should be good protection.  This is pretty simple although, I would recommend using the IT specialist I mentioned.  Now, you will have to consider whether to encrypt the entire drive or part of the drive, it will impact processing speed.  If you have an extensive number of employees I would recommend the entire drive because you cannot ensure they will save documents with PHI in the encrypted drive.  You will also need a 20+ digit password for each computer that can be remembered.

The browser FireFox has 256-bit encryption while Internet Explorer has 128-bit encryption.  Firefox is a little different but not terribly noticeable and now it is all I use.  Firefox is also a free browser.

Myfax is an “internet” fax that will send you notifications via email.  There faxes are PGP encrypted; however, what I learned was you need to receive a email notification, login to your account, and download the file direct to your computer.  If it comes as an attachment to your email then the PGP encryption is void.  The cost is about $10/month for home or small business, but the corporate account is not expensive.

Cutepdf Professional costs about $50.00 you can print documents to pdf (this is in the free version) but if you need to send that document to your consultant or CPA the professional version allows for password protection as well.  You would not put the password in the same package as the CD or in the same email.  It will allow you to open a PDF and make a text box for notes that will print out.  So you do not have to recreate the information then add notes in another tool.  This may be more depending on the number of licenses you need.

When printing and saving reports from your billing system, you can export to excel or similar file, leave the patient account number or patient name only but take out address, and other identifying information that will identify 1 specific person.  These will be HIPAA compliant if all Patient specific information is removed.

Ensure staff understands they cannot place PHI or patient financial information in an email.  Having an email encryption program may not be the solution right now because if you use for example PGP email encryption the receiver of the email must have the same email encryption program and the key code (password if you will).  This may be problematic for awhile.  So this is why I want to give you some other options.  One such one is Hushmail which is a 1028bit online e-mail service, where your e-mail never leaves their servers, and so remains encrypted end to end.  But both sender and receiver have to have accounts (though they do have a free option, you must use it regularly though).

I understand processes, but the inner working of IT I utilize experts.  I am not affiliated with nor promote any specific product, these are only suggestions.  I hope you will subscribe to my blog as well as provide comments.  I use this to broadcase updates and tips to help you run your business.  If you need help with your IT network solutions, here is a  contact that works on my office equipment and they can work with clients nationally.  A big thank you to Glenn for helping me with the correct lingo!

Glenn Kimball         GWK Technologies           

Angela Miller of Medical Auditing Solutions LLC has been in health care compliance, auditing, billing, collections and HIPAA for over 18 years.  Ms. Miller has made it the  focus of the business to help providers run their businesses efficiently, collect money, and maintain compliance with federal and state regulations and coverage criteria.  Ms. Miller is very experienced with Medicare & Payer audits.  Ms. Miller ran a very successful compliance program for over 5 years for the largest private held HME/Pharmacy provider in the US at the time.  Ms. Miller  also works as a contract compliance officer to provide an avenue to compliance training to staff, implementation of policies, as well as handling anything that affects cash flow from the initial intake to back-end collections. You can visit our website at Medical Auditing Solutions LLC.

Tidbit of the Day: The Unknown Benefit of Hair

This is totally unrelated to health care but an interesting story.  As many of you have heard for a couple of weeks of the oil rig explosion in the gulf and the difficulty they are having containing the oil spill and the dramatic effects to the environment as well as the gas pump.  Last night on the local news in Dallas, a story aired on Matter of Trust, a San Francisco nonprofit, recycles the hair scraps and turns it into small mats that help absorb oil. The mats look like large an S.O.S. pads. Other hair is made into booms after being packed into used nylon.  This is low cost and minimal effort.  Send this to your hair dresser, barber, pet grooming, and wool farmers to increase participation.

SPECIAL PROGRAM FOR HAIR & FUR CLIPPINGS
To know what this fun program is about, see our YouTube
Welcome Hair Salons, Pet Groomers, Wool Farmers…

PRESS
Please contact:
Lisa@MatterOfTrust.org
415 235 2403

GULF HAIR BOOM ALERTS
5/5/10 We have more new warehouses and are sending out more addresses for hair donations! Sign up here to get an email with the site to send yours in!

Our thanks to Hanes for the nylons!

We are asking all new sign ups (of which we are getting hundreds an hour now) to sign up and be patient for the next addresses for WAVE 2 as we watch the progress of the oil slick.

Today, so many communities are contacting us since they are collecting hair / fur / nylons on large scales around the country. We have all decided to orchestrate a NATIONAL FIBER RECYCLING & OIL BOOM MAKING SYSTEM. With 2600 small oil spills a year all over, each community will be more prepared!

We hope this will also create green jobs (pick ups, boom making). We dream that this will bring the textile industry back to the US so we can make our mats here!

China has been recycling hair and all fibers for over 3,000 years. Their textile industry is BOOMING. Hair mats are basically like flat square dread locks, we really are industrious enough to make these in the US again, too! Sign up here and join us, Please!

Angela Miller of Medical Auditing Solutions LLC has been in health care compliance, auditing, billing, collections and HIPAA for over 18 years.  Ms. Miller has made it the  focus of the business to help providers run their businesses efficiently, collect money, and maintain compliance with federal and state regulations and coverage criteria.  Ms. Miller is very experienced with Medicare & Payer audits.  Ms. Miller ran a very successful compliance program for over 5 years for the largest private held HME/Pharmacy provider in the US at the time.  Ms. Miller  also works as a contract compliance officer to provide an avenue to compliance training to staff, implementation of policies, as well as handling anything that affects cash flow from the initial intake to back-end collections. You can visit our website at Medical Auditing Solutions LLC.

Social Media Security and Privacy

Social Media sites are becoming a way of communicating with the world.  Remember, no matter what social media site you are using whether it is an instant message, website profile, social network or skype or similar sites, your communication can be viewed or intercepted.  If you have any of these social media profiles, do not publish your address, DOB, or any other information that could be used to steal your identity, break into your home, stalk you or your children.  Use the incorporation date of your business or a combination of information and chose not to publish your address and DOB.  Ensure you obtain your free annual credit report to review for accuracy.  There are also programs that will monitor your credit activity for potential theft.

Publishing any personal information can lead to not only credit or financial fraud but health care fraud also.  Protect your information.

Remember, this method to communicate with patients is not with HIPAA, HITECH and Red Flag rules if you are exchanging any credit, financial or other personally identifiable information whether health or otherwise.

As a note, you can find us on all Social Media sites: Facebook, Myspace, Linkedin, Plaxo, Twitter.  We do submit blogs through these sites and occasional other notes so you can stay updated through status notifications.

Angela Miller of Medical Auditing Solutions LLC has been in health care compliance, auditing, billing, collections and HIPAA for over 18 years.  Ms. Miller has made it the  focus of the business to help providers run their businesses efficiently, collect money, and maintain compliance with federal and state regulations and coverage criteria.  Ms. Miller is very experienced with Medicare & Payer audits.  Ms. Miller ran a very successful compliance program for over 5 years for the largest private held HME/Pharmacy provider in the US at the time.  Ms. Miller  also works as a contract compliance officer to provide an avenue to compliance training to staff, implementation of policies, as well as handling anything that affects cash flow from the initial intake to back-end collections. You can visit our website at Medical Auditing Solutions LLC.

Medtrade Spring 2010 – Vegas

The HME & Pharmacy industry has been hit hard the last couple of years with reimbursement cuts, competitive bidding and much more.  The big focus on Medtrade Vegas 2010 is to help the suppliers be proactive and more efficient with their business.  Medical Auditing Solutions will be there to meet with clients and vendors as well to be an active participant in these solutions.

Angela Miller will be speaking Wednesday, May 12,  at 9:15am on “Developing a Risk Protocol for Auditing.”  This program will discuss how to identify the risk model(s) for your business.  Every business will have a different risk model.  The program will review areas for auditing the risk model.   This program will be a tool to help you develop your audit plan.

We look forward to speaking with you.  If you miss the session and would like to schedule a meeting with Ms. Miller, you may contact her by email (angela@medicalauditingsolutions.com) or by mobile (409.673.7103).  No sales calls will be accepted.  This is a time for our clients.

Angela Miller of Medical Auditing Solutions LLC has been in health care compliance, auditing, billing, collections and HIPAA for over 18 years.  Ms. Miller has made it the  focus of the business to help providers run their businesses efficiently, collect money, and maintain compliance with federal and state regulations and coverage criteria.  Ms. Miller is very experienced with Medicare & Payer audits.  Ms. Miller ran a very successful compliance program for over 5 years for the largest private held HME/Pharmacy provider in the US at the time.  Ms. Miller  also works as a contract compliance officer to provide an avenue to compliance training to staff, implementation of policies, as well as handling anything that affects cash flow from the initial intake to back-end collections. You can visit our website at Medical Auditing Solutions LLC.

Health Care Reform: Compliance Programs, Reduce Filing Limits, Limited Ownership

The Health Care and Education Reconciliation Act of 2010 signed March 23, 2010, has made significant changes to health care providers and claims filing requirements.  Remember, CMS will have to publish written notification and post implementation deadlines; however, it will make your life easier to start educating staff and changing practice now.

*  Mandatory Effective Compliance Program for ALL health care providers that bill Medicare, Medicaid, and other federally funded program from hospital to mental health and everyone in between.

A compliance program has been required for providers collecting $5 million or more per year in Medicaid funds collectively since 2006.

http://www.cms.gov/smdl/downloads/SMD121306.pdf

New York Office of Inspector General implemented state requirement for effective compliance program 10/1/2009. http://www.omig.state.ny.us/data/content/view/79/1/

An effective compliance program contains 7 elements which includes Compliance Officer, Compliance Committee, Code of Conduct (approx 70 pages), Policies & Procedures (50+ depending on practice), Minimum of 5 hours of training per year on specific relationship and billing topics, Auditing and Monitoring Function, Reporting Options without fear of retaliation, and a few others that are embedded in these items.  It takes at least 12 months to roll out a compliance program and about 18 months to see effectiveness.  As a note, accreditation policies typically do not include most of the elements likewise the audits typically are not coverage criteria based or risk based.

*  Physicians must have a Face to Face with patients prior to ordering DME (durable medical equipment) and HHA (Home Health) Services effective 2/23/10.  This should be taking place now; however, if not, do not wait until CMS publishes an effective date.  This is good business practice and should be implemented immediately.

*  Physicians must be a Medicare provider as of July 1 2010, if they order DME and HHA that will be billed for Medicare reimbursement.

*  Physicians must provider medical record documentation to support referral orders or be subject to a revoked Medicare supplier number for a period not greater than one year **ADDED**

*  Claim submission filing limit has been reduce from 18 months to 12 months.  Until CMS publishes an effective date, you will have 18 months.  Be on the look out.  Announced 5/14/2010

*  Expanded Stark Law regulations will limit physician ownership in hospitals as of 12/31/2010.

*  Must provide patient choice when you have diagnostic equipment in your office such as MRI, PET, CAT.

*  Stark & Anti-kickback violations will also receive penalties until Federal False Claims Act.

*  Overpayments must be refunded to Medicare/Medicaid within 60 days whether you identify the overpayments or the refund is requested.  Failure to do so is likely to result in a revoked provider number and sanction from participating with the Medicare and Medicaid programs.  This was actually part of the Patient Affordable Care Act.  CMS announced 10/15/2010 see also Cynthia Stamer’s Blog.  This announcement also has language on Self Disclosure of Self Referral practices that have taken place.

*  Have heard from several people, that Oxygen will be reduced from 36 months to 13 months.  However, I have searched the full text and amendment and cannot find it. **ADDED**

*  It will require insurance payers to reimburse preventative services at 100% with no co-pay.  Please note, this has not been published with an implementation date so continue to file claims as normal.  Patients cannot expect to receive free preventative services until their payer publishes this change!

*  It appears to me that only companies with 50 or more employees will be required to provide health insurance for all W-2 employees.  I will be interested in seeing how this turns out.   It also appears that in 2018, you will have to use the government health care program or loose tax credits of 25-35% of the premiums.  I wish I had one of this money trees in my back yard!

This covers many of the highlights that impact provider billing, but there are so many more points.  Read over the information so your are prepared.  If you find you need your compliance program reviewed and developed remember to find a consultant that focuses on ALL aspects of compliance not just a compliance program.  They need to understand billing and operations and we are one of the companies that offers an all encompassing solution to health care providers.

You can reference the full text http://www.cbsnews.com/htdocs/pdf/Senate_health_care_bill.pdf and amendments http://www.cbsnews.com/htdocs/pdf/House_reconciliation_package_031810.pdf as well as a blog from Looper, Reed, & McGraw http://www.lrmlaw.com/pdf/ALERT-Healthcare-Reform-Alert.pdf.  Search the document for key words used in bullet points.  I have also included a Timeline link that has many items bullet pointed except the ones that apply to providers and reimbursement for Medicare services http://docs.house.gov/energycommerce/TIMELINE.pdf

Angela Miller of Medical Auditing Solutions LLC has been in health care compliance, auditing, billing, collections and HIPAA for over 18 years.  Ms. Miller has made it the  focus of the business to help providers run their businesses efficiently, collect money, and maintain compliance with federal and state regulations and coverage criteria.  Ms. Miller is very experienced with Medicare & Payer audits.  Ms. Miller ran a very successful compliance program for over 5 years for the largest HME/Pharmacy provider in the US at the time.  Ms. Miller  also works as a contract compliance officer to provide an avenue to compliance training to staff, implementation of policies, as well as handling anything that affects cash flow from the initial intake to back-end collections. You can visit our website at Medical Auditing Solutions LLC.

RAC and ZPIC Audits: How to have a Successful Payer Audit?

In the last twelve months, there has been more money than ever before put into fighting fraud and abuse.  Contractors are requesting more charts than ever before to review for fraud and abuse.  How do you have a successful payer audit?  The simple answer is provide the documents requested, but there is more to it.

First, Make a checklist for each chart.  Pull each chart and copy all records requested.  The request period may not include the delivery or start date and copies of initial qualifying test results and/or chart notes, include them if it is pertinent to the determination of ongoing medical necessity for example rentals of equipment.  If you did not obtain the test results or physician chart notes at the time of the start of care, request them now because the physician is not penalized if he does not respond.  Physician failure to respond to a request is an error and results in “overpayment/error” paid by the provider.  It is in your best interest to gather and submit each patient record in an organized manner.  This needs to be top priority because you have limited time frame to produce and failure to respond timely results in overpayment calculations!

Have you seen or heard the “error rates” being published?  The way it sounds, ever provider will have an audit with an error rate, it is just a matter of time.  A error rate published March 1, 2010, by Noridian was over 102 files with 86% error rate.  This is a small sample to create a crisis over.

I would recommend you have an independent third party, whether consultant or your health care attorney,  review the records before you send them off.  You can typically be granted one extension.  Do not wait until the last minute to start this process.  If you have a large number, have someone review a sample then expand based on the determined error rate.

If more than 20-30 charts are requested, I would notify outside counsel.  I am receiving new clients weekly with 200, 300, 400 or more charts being requested.  To produce duplicate copies of these records and obtain physician records in 14-21 days may be difficult and still run your business.

If you haven’t received an audit to this point, be prepared for when it happens.  Any overpayment determination in a payer audit requires payment arrangements prior to the appeal process being completed.  Be proactive, have an audit of your business to be prepared for when that day comes.

Angela Miller of Medical Auditing Solutions LLC has been in health care compliance, billing, collections and HIPAA for over 18 years.  Ms. Miller has made it the  focus of the business to help providers run their businesses efficiently, collect money, and maintain compliance with federal and state regulations and coverage criteria.  Ms. Miller has extensive experience with Medicare and Payer audits.  Ms. Miller  also works as a contract compliance officer to provide an avenue to compliance training to staff, implementation of policies, as well as handling anything that affects cash flow from the initial intake to back end collections. You can visit our website at Medical Auditing Solutions LLC.