Is Your Credit Card Terminal PCI HIPAA Compliant?


World Pay is a company that I have come across that has some really good educational information for clients and perspective clients on Payment Care Industry or PCI Compliance.  HIPAA extends to protect the financial information of clients.  It is important that you have policies regarding your PCI practices or accepting and processing credit card payments.  If your credit card processing company helping you?  Is your credit card terminal PCI Compliant, feel free to check the lists for WPVeriFone EOL Products and WPHypercom T7Plus End of Life that have reached”End of Life” or are no longer compliant.

A company can be out of PCI compliance in two ways 1) the terminal they use does not meet criteria and 2) through processes of gathering, transmitting and storing data.

Let me tell you what impressed me about World Pay.  They have a terminal that is end to end encrypted to protect financial data.  This company has a tremendous about of education materials on this topic. There fee of $14.99/month of PCI compliance includes 24/7 customer service, guidance to get your policies and procedures in place, a third party vendor to provide PCI Accreditation and Certification for that process only, and $30K of indemnity coverage when using their standard terminal or $100K indemnity coverage if your are using their end to end encrypted terminal, they help with negotiations with visa, master card, etc., if their is a breach.  Additional medical audit and HIPAA breach defense coverage may be obtained through Jim Patterson at Agape Insurance

It is important that you ensure your credit card processing machine and process is HIPAA compliant.  Educate yourself and make an informed decision.  I have included links to PCI websites for further explanation of PCI Compliance.

What will you need to have a free PCI Compliance review provided?

1.  Your Credit Card Statement; Does your statement say “non-validation of PCI” with a fee?

2.  Name/Model# of the Terminal(s) being used

3.  Do you have policies and procedures for use, storage and transmission?

4.  Mention this blog from Medical Auditing Solutions

How do you get this complimentary PCI Compliance Review?

Have the information above available and Contact Martin Anderson with World Pay at *martin.anderson@worldpay.us*

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.

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Medicare PrePay Audit for Oxygen and CPAPs for all MACs


As I understand it, all Oxygen and CPAPs in all Medicare MAC regions are on prepayment status.  This means you will be getting additional documentation or development request letters to provide documentation to support medical need prior to the claims being paid.  This evidently is being discussed in Mac Council Meetings this month.

How to do improve turnaround time?

You need to obtain all documentation, physician chart notes, date last seen initial and renewal (if applicable), and copies of test results at the time of the order intake and certainly PRIOR TO BILLING.  Waiting until the request is received puts your business in danger of missing the deadline due to the physician failing to see the importance of a timely response to the request for records.

What is your plan?

Have you diversified your business model with higher ratio of commercial payers?  If not and you want to increase to likelihood of sustaining prepayment audit while Medicare penalizes everyone in the industry with this prepayment plan you need to look at diversification.

If you have better ideas for fighting fraud and abuse beside penalizing everyone in the industry with prepayment audits, the Senate Finance Committee is seeking input from the healthcare community.  Speak up!

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.

Senate Finance Committee Seeks Feedback on Fighting Fraud & Abuse as They Look at ZPICs


Reposted from email blast received May 2, 2012.
FOR IMMEDIATE RELEASE
May 2, 2012
CONTACT:  Julia Lawless/Antonia Ferrier (Hatch)              (202) 224-4515
                            Communications Office (Baucus)                          (202) 224-4515 

HATCH, BAUCUS LEAD FINANCE COMMITTEE MEMBERS IN BIPARTISAN EFFORT TO COMBAT WASTE, FRAUD, & ABUSE IN
MEDICARE & MEDICAID PROGRAMS
In an open letter to members of the health care community Senators write, “Drawing on the collective wisdom and accumulated insights of thousands of professionals and individual experiences could offer a fresh perspective and potentially identify solutions that may have been overlooked or underutilized.”


WASHINGTON – Today, six members of the Senate Finance Committee, led by Ranking Member Orrin Hatch (R-Utah) and Chairman Max Baucus (D-Mont.), announced a bipartisan effort to begin soliciting ideas from interested stakeholders in the health care community regarding effective solutions to improve federal efforts to combat waste, fraud, and abuse in the Medicare and Medicaid programs. Joining Hatch and Baucus in the effort are:  Senators Tom Coburn (R-Okla.), Ron Wyden (D-Ore.), Chuck Grassley (R-Iowa), and Tom Carper (D-Del.).

In an open letter to members of the health care community, the Senators wrote, “We believe federal efforts would be strengthened by input from members across the health care community – providers, payers, health plans, contractors, non-profit entities, consumers, data analytics entities, governmental partners, and patients. Drawing on the collective wisdom and accumulated insights of thousands of professionals and individual experiences could offer a fresh perspective and potentially identify solutions that may have been overlooked or underutilized.”

This week, the lawmakers invited interested stakeholders to submit white papers offering recommendations and innovative solutions to improve program integrity efforts, strengthen payment reforms, and enhance fraud and abuse enforcement efforts. Submissions are due by June 29, 2012. A summary document highlighting key proposals will be compiled and released later this year.

The Senate Finance Committee has jurisdiction over the Medicare and Medicaid programs.

To view a signed copy of the letter click HERE.

Below is the full text of the letter:

May 2, 2012

To Members of the Health Care Community:

According to the Government Accountability Office (GAO), few programs are as much at risk for fraud, waste and abuse as the Medicare and Medicaid programs.  Estimates of the amount of fraud and misspending in these programs vary widely, from $20 billion to as much as $100 billion. Just this week, testimony before the Senate Finance Committee underscored the seriousness of this problem, as witnesses testified that while much has been accomplished in the fight against fraud and abuse, much more needs to be done.  As Senators and members of the Finance Committee, we have a duty to ensure that taxpayer funds are being spent wisely.

Combating fraud in Medicare and Medicaid has long been a challenge for the Centers for Medicare & Medicaid Services (CMS), the Department of Health and Human Services Inspector General (HHS OIG) and the Department of Justice (DOJ).  To date, numerous efforts have been made to reduce fraud, yielding a mixed record of successes and failures.  We believe federal efforts would be strengthened by input from members across the health care community – providers, payers, health plans, contractors, non-profit entities, consumers, data analytics entities, governmental partners, and patients. Drawing on the collective wisdom and accumulated insights of thousands of professionals and individual experiences could offer a fresh perspective and potentially identify solutions that may have been overlooked or underutilized.

Today we are announcing an effort to solicit ideas from all interested stakeholders in the health care community, regarding solutions and suggestions for how to better prevent and combat the multi-billion dollar problem of waste, fraud and abuse in the Medicare and Medicaid programs.  We invite you to submit white papers offering your best ideas, built on years of experience and insight.  We want to know what areas you see for improvement in current program integrity efforts, as well as additional solutions that we should consider. Working together, we hope to identify innovative solutions that will provide taxpayers with a better return on the investments being made to combat the overpayments in these federal health care programs.

Below are the general categories in which we seek input, though some recommendations may include multiple categories:

&#61623      Program Integrity Reforms to Protect Beneficiaries and Prevent Fraud and Abuse

&#61623      Payment Integrity Reforms to Ensure Accuracy, Efficiency and Value

&#61623      Fraud and Abuse Enforcement Reforms to Ensure Tougher Penalties Against Those Who Commit Fraud

 

Entities interested in submitting white papers should email a PDF or Microsoft Word document to ProgramIntegrityWhitePapers@finance.senate.gov by June 29, 2012.  Submissions should include summary information about the entity or individual submitting a white paper, as well as phone and email contact information. White papers should be as succinct and concrete as possible.  When possible, please include cost-benefit or potential savings information.  Our staff will review submissions and compile a summary document highlighting key proposals later this year.

We appreciate your submission of thoughtful and constructive solutions, as we work to conduct targeted oversight to improve federal efforts to reduce fraud and abuse in Medicare and Medicaid. Together, we believe we can improve program integrity and be better stewards of taxpayer dollars.

Sincerely,

BAUCUS
HATCH
COBURN
WYDEN
GRASSLEY
CARPER

###

Texas Dental Providers – Take Aways from HHSC Committee Meeting 3/20/12


I listened to the live Texas Senate Committee meeting regarding the Health and Human Services Commission (HHSC) Charge 4 (dental & orthodontics) yesterday 3/20/12.  Unfortunately, this Senate Committee is concerned about the amount of money paid for orthodontic services and convinced Orthodontic services were provided at an abusive level and they want this money back.  I am providing what I took away from this meeting and we will discuss how to protect yourself.

  1. Senator Jane Nelson is willing to push thru legislation to allow parents in the treatment room.  I didn’t understand this…I suspect she has received a complaint from a parent where the Dental Provider refused to allow the parent in the treatment room.  My opinion is, this is one thing if the room has a door or if the patient is sedated because you do not want to add liability to your business.  Having a second company staff member in the room present will reduce risk as well.  As for HIPAA, what are your privacy and security policies for this situation?  If you do not have policies, they have been required since 2003 and 2009 respectively so very important to get this done.
  2. They want to go after dentist for the unlimited orthodontic visits.  Policy said “unlimited”!  Keep in mind if the Dental Provider was racking up unnecessary visits, it doesn’t matter if it is unlimited visits in policy, the visits were unnecessary therefore a potential fraud and abuse overpayment.  If these were legitimate visits and necessary, you should not pay that money back.  So policy for this is being reduced to 12 visits, they say.
  3. They pay for transportation to the dentist if the patient cannot afford it.  At present the patients are paid upfront or MCD pays the transportation company.  In the future, they will have to provide proof of visit and proof they used the transportation to be reimbursed.
  4. They are looking at bundling orthodontic rates versus per visit rate.
  5. More talk of suspending provider numbers based on allegations of credible fraud.  This is huge and critically important to include exit interviews with staff that is leaving the company.  You also need to have a compliance program with reporting mechanism in place.  If you collect $5M or more in Medicaid funds you were required to have a healthcare compliance program in 2007.  All other Medicaid providers are required to have a compliance program by 2013.
  6. Inspector General has 31 current investigations of Orthodontic practices at this time.
  7. Senator Jane Nelson and the committee want the business to have to be licensed and registered with the dental board similar to a pharmacy with the pharmacy board.  I suspect changes will follow for a proposal of such.  This will bring additional revenue into the Dental Board but it will permit investigations into complaints of ABC Dental versus the need for a dental providers name which is the current requirement.
  8. Expect audits to pick up on Orthodontic services.  They noticed as of 10/1/11 when the requirement to send molds went into place, request dropped and PARs were denied.  If you provided orthodontics to children under 13 or now 12, those are especially at risk for audit.
  9. They put a lot of emphasis on HLD Scores.  Where do you record these and how you measure to get the score?
  10. The TMHP Medicaid contractor responsible for reviewing this information basically rubber stamped requests.  They did not review for “medical necessity;”  it was primarily to make sure the form was completed and the HLD Score was >=26.  The Dental Director was terminated and they have hired a replacement.  They HHS/IG will be auditing the approved PARs (Prior Auth Requests) and recouping money.  The debate is if they will recoup from TMHP or from the provider.  Again, if the services were fraudulent and dishonest it, I fully expect they will go after the provider.  There is always a possibility if TMHP didn’t review and it did not meet the coverage criteria, they will try to recoup from the provider as well.  They expect these audits to be complete in 6-12 months and they have already started.
  11. By using Dental Managed Care Payers, these organizations have experience in other states and they have ideas on how to reduce Fraud & Abuse (F&A).  They think by using someone with experience to review and process these claims will reduce F&A.
  12. On the federal level, in 2010 Office of Audit Services contacted Texas inquiring about Orthodontic billing and providers.  So the federal government has taken notice of Texas and since they provide funding to the medicaid program, Texas has to respond to the concerns.
  13. No recruiting clients in parking lots….…this seems to be an issue.
  14. The HHSC office admitted the policies were such that it didn’t catch issues and the department processing was not staffed properly.
  15. I would expect a tremendous increase in audits and policy changes.
  16. Texas spent as much as 49 other states total from 9/1/08-5/28/11 on Orthodontic services.  An additional 500,000 kids were seen for checkups after the rates increased in 2008 by 50-100% than in previous years.
  17. The committee suggested HHSC do a Cost Benefit Analysis on providing orthodontic care to children and if that prevented excessive spending later if it were not done.

Now, what should you do?  I strongly recommend the following and sometimes it is good to get an outside consultant to review because of objectivity and the familiarity with issues being identified.

  1. Make sure you have HIPAA policies in place that are applicable to your business.
  2. Assess whether you need a healthcare compliance program now (because you were required in 2007) or if not make a plan to get this done.
  3. Items 1 and 2, a vital if you are investigated now even if not required.  Corporate culture is first questions the government asks.
  4. A sample audit of claims.  This is critical because you need to assess your risk as a company.  Assess the documentation versus coverage criteria.
  5. If audited, NEVER just cut a check for the overpayment requested!  Why, you ask?  The payer sees this as admission of guilt and if they haven’t extrapolated already they are more likely to do so.  This is not a good surprise to get in the mail6-12-14 months later!!  I have seen this happen.  Get a consultant and attorney and prepare a defense.  It will be less expensive to do when you get the audit than after the appeal process has started.

We work with several dental practices and the goal is to educate providers so they reduce risk and pass audits.  We also work with Looper, Reed, and McGraw LP, a law firm with attorneys that specializes in dental practices.  We work as a team with our practice and emphasize “proactive”operations.  We will be happy to schedule

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.

Angela Miller Speaking at AAOE Conference New Orleans May 2012


We are delighted to announce the course being presented by Angela Miller, President of Medical Auditing Solutions LLC: Developing Elements for an Effective Compliance Program, has been approved for 1 CEU through AAPC for your LIVE presentation. AAPC provides physician-based medical coders education and professional certifications.

American Association of Osteopathic Executives

Course Information:

Course Title:  Developing Elements for an Effective Compliance Program

Monday, 5/21/2012, from 3:15pm-4:30pm

Location: Hilton New Orleans Riverside  Room:  Belle Chase, subject to change

Register Now through the AAOE Conference Registration site:

http://www.aaoe.net/displaycommon.cfm?an=1&subarticlenbr=97

We look forward to seeing you at the conference and on the Riverboat Ride on Sunday, May 20, 2012. Call us to schedule an appointment to learn what we do or to learn what you need to ensure you have in place for your compliance program as well as your HIPAA Privacy & Security Programs.

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.

Training for Compliance & HIPAA Privacy and Security


Medical Auditing Solutions LLC launched the Compliance University in September 2011 and is please to announce that for 6 of the programs we have received Continuing Education Credits by Texas Occupational Therapist Association (TOTA) (15 hours) , Texas Board of Professional Counselors (6 hours minimum) , and BOC USA (9.5 hours).

What are you waiting for?  You have to train staff annually on compliance program requirements, fraud and abuse, billing,privacy and security. You have to be able to prove this training was given.  Does your staff have time to develop, track and update?  Did you know the OIG is auditing for these policies, training, sanction checks, and more in 2013 for providers that $5M in annual collections from Medicaid programs?  Did you know that OCR is auditing all types and sizes of healthcare providers from HIPAA privacy and security in 2012 and years to come?  Did you know the state inspector generals and health and human services will be auditing for these policies as well?  We can help you will all aspects of your compliance and HIPAA programs.

These requirements apply to all healthcare providers, DME, home health, physicians, and dental providers.  The size of your business does not matter for HIPAA.  As of  February 2013 for Compliance applies to all as well.

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.

ZPIC Audits What We’ve Learned from 2011 and other Audit Risks Webinar


Edward Vishnevetsky, healthcare attorney with Munsch Hardt has asked Angela Miller to join him as a guest speaker during his presentation next Thursday, February 9, noon-1pm CST.  Audits are inevitable at this point, so better be prepared and proactive for the audits that are coming.  Join us as we discuss ZPIC audits and other audits you can expect in 2012, such as HIPAA, OCR, Medicaid RAC, Commercial audit expansion. Also learn how best to prepare and prevent  adverse outcomes.

You are Invited to Join our Complimentary Medicare ZPIC Audit Webinar

Featuring Topics on:

Changes to Medicare ZPIC and RAC Audits
The Office of the Inspector General’s (OIG) take on Audits in 2012 based on the 2012 OIG Work Plan
Which HCPCS codes may be most vulnerable and subject to scrutiny
How DME suppliers can work with physicians, hospitals and manufacturers to assist in responding to audits
Tips on how to effectively respond to audits (based on lessons learned in 2011)
Other Audit Risk and Prevention

Presentation Given By:

Edward Vishnevetsky

Attorney at Munsch Hardt Kopf & Harr, P.C.

Featuring Guest Speaker:

Angela Miller

President of Medical Auditing Solutions LLC

Date: Thursday, February 9th, 2012

Time: 12:00-1:00 PM CST

Cost: Complimentary

To reserve your Webinar seat, please click here.

After registering you will receive a confirmation email containing information about joining the Webinar.

If you have any questions, please contact Ashley Thomas.

Edward Vishnevetsky has successful defends over 40 physicians, DME providers and HHAs against ZPIC, CERT, MAC and RAC Audits; achieved 100% success rate in removing providers from pre-payment audit.  Successfully defended over 100 providers through all stages of Medicare appeals, including the Administrative Law Judge (ALJ) level.  Read more at Munsch-Vishnevetsky

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.