Accountable Care Expo – Dallas – Medical Auditing Solutions LLC August 1 2012


As many of you know the Patient Protection Accountable Care Act has a mandate requiring the implementation of cost containment managed care of patients, or Accountable Care Organization (ACO).  Many have been sitting on the sidelines waiting for the US Supreme Court Ruling on, and since they upheld ObamaCare….this is moving forward.  So, join Dallas area providers as they collaborate on HOW IN THE HECK to implement programs locally and make it work.  Providers and patients need to take a valid interest in being proactive versus treating the present situation.  You can view the agenda and register for the Dallas Accountable Care Expo to be held August 1, 2012 all day attendance is free except for the luncheon.  If you are not in the Dallas area, there are ACO Expos planned for Chicago and Las Vegas with others in the works.

Angela Miller, President of Medical Auditing Solutions LLC will be speaking on the Compliance Program Requirement.  All participants in an ACO must have a compliance program in place to participate so before March 2013.  Ms. Miller has over 18 years experience in corporate compliance programs, healthcare billing, collections, and coding audits.

Edward Vishnevetsky, Healthcare attorney with Munsch Hardt will be the luncheon Keynote Speaker on “Obstacles with ACO.”  Have you ever been able to listen to an attorney for the cost of lunch?  Well, mark this on your calendar and register now.  Mr. Vishnevetsky will also be speaking on the implications of the US Supreme Court Decision to uphold ObamaCare.

Bring your questions, concerns, and ideas on August 1, 2012.  It will be a day of speakers and exhibitor booths.

Angela Miller of Medical Auditing Solutions LLC has been in health care compliance, auditing, billing, collections and HIPAA for over 18 years.  Ms. Miller is Certified in Healthcare Compliance.  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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Compliance Programs Required 3/25/2013


Well, we thought with Health Care Reform Act of 2010 that providers had 3 years from the signature date to have a plan implemented. With the final provisions of the Patient Protection Affordable Care Act, you have until 3/25/2013…less than 2 months to have a compliance plan in place.   They make reference to the 7 element compliance program currently recommended as a basis for the program structure. The final rule has language that reads as though they will withhold payment to providers that do not have compliance program in place.  Don’t worry, we can help you with a simple compliance program that is affordable.

A few other items that impact business decisions. This takes effect 3/25/2011 for all new providers and March 2012 for all existing providers.

1.  Moratorium on Medicare, Medicaid & CHIP provider numbers based on products and number of suppliers in the area.  This may not be as easy anymore.

2.  Application fees of $500 each for all providers excluding physicians and nurse practitioners and their group practices. If a provider applied for Medicare and Medicaid then only one fee will be required, but proof of Medicare application may be required.

3.  New screening and Fingerprinting requirements. Note Florida has had fingerprinting in place for over 8 years. You have to have a criminal record and there are many fraudulent providers that currently do not have a record. This applies to owners of 5% or more of the company, directors and officers.

4.  Unscheduled & unannounced visits to check up on suppliers.

5.  Re-enrollment for Medicare every 3 years and Medicaid annually and fees will apply plus inflation rate for CPI.

6.  New state licensing requirements to come from this also.

If you do not have a compliance program or haven’t taken your seriously, it is a requirement that could result in suspended payments.

With proven experience in the health care compliance, We can help you with a compliance program policies and procedures as well as teach you to manage your program or help you manage the program to ensure you pass the government inspection to ensure effect within 3 years of implementation. They can request random audits for privacy and security to ensure you are meeting requirements and now they have added billing compliance.

We can also help you with provider applications to ensure they are done right the first time.

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.

HIPAA Privacy Settlement – $1 Million


With all the new enforcement efforts for privacy violations, better read this and take note.  If you are not sure you are HIPAA compliant MAS can provide security as well as chart and process assessment to help you.  This article is so important, I couldn’t find the short link so recopied exact with all Ms. Stamers contact information as well.

Rite Aid Agrees to Pay $1 Million to Settle HIPAA Privacy Case As Office of Civil Rights Proposes Tighter HIPAA Privacy & Security Regulations

August 4, 2010 <!–Cynthia Marcotte Stamer–>

Stay Tuned To Solutions Law Press For More Details

One of the nation’s largest drug store chains, Rite Aid Corporation and its 40 affiliated entities (Rite Aid) will pay $1 million to settle potential violations of the Health Insurance Portability and Accountability Act of 1996 (HIPAA) Privacy Rule.  The U.S. Department of Health and Human Services (HHS) Office of Civil Rights announcement of the HIPAA resolution agreement with Rite Aid and the concurrent negotiation of a separate consent order of potential FTC Act violations between Rite Aid and the Federal Trade Commission (FTC) follows HHS’ announcement of proposed changes to its HIPAA Privacy Rules and associated penalties in response to changes enacted under the Health Information Technology for Economic and Clinical Health Act of 2009 (HITECH Act).  The Rite Aid settlement and the proposed Privacy Rule changes illustrate the growing penalty risks that health care providers, health plans, healthcare clearinghouses and their business associates (Covered Entities) face for violating the Privacy Rules.

Rite Aid Resolution Agreement

The Rite Aid resolution agreements settle charges that Rite Aid failed to appropriately safeguard the privacy of its customers when disposing of identifying information on pill bottle labels and other health information. The settlements apply to all of Rite Aid’s nearly 4,800 retail pharmacies and follow an extensive joint investigation by the HHS Office for Civil Rights (OCR) and the FTC.

OCR opened its investigation of Rite Aid after television media videotaped incidents in which pharmacies were shown to have disposed of prescriptions and labeled pill bottles containing individuals’ identifiable information in industrial trash containers that were accessible to the public in a variety of Rite Aid locations in cities across the United States.  OCR and FTC previously settled a similar case involving the national drug store chain CVS in February 2009.

The HIPAA Privacy Rule requires covered entities to safeguard the privacy of patient information and other “protected health information” including during its disposal.  In addition to the detailed requirements for protection and safeguarding of protected health information and electronic protected health information under the Privacy Rules, breach notification rules added to HIPAA under the HITECH Act also generally require that Covered Entities investigate and provide timely notification of breach to patients, OCR and in some cases the media when “unsecured protected heath information” is breached.  Meanwhile, the FTC Act and associated regulations require those retailers and certain other parties receiving personal financial information to comply with certain requirements for the protection and use of that information and to provide certain notifications of their privacy polices for protecting personal financial information.

The joint OCR and the FTC investigations raised concerns that:

  • Rite Aid failed to implement adequate policies and procedures to appropriately safeguard patient information during the disposal process;
  • Rite Aid failed to adequately train employees on how to dispose of such information properly; and
  • Rite Aid did not maintain a sanctions policy for members of its workforce who failed to properly dispose of patient information.

Under the HHS resolution agreement, Rite Aid agreed to pay a $1 million resolution amount to HHS and must implement a strong corrective action program under which Rite Aid agreed to:

  • Revise and distribute its policies and procedures regarding disposal of protected health information and sanctioning workers who do not follow them;
  • Train workforce members on these new requirements;
  • Conduct internal monitoring; and
  • Engage a qualified, independent third-party assessor to conduct compliance reviews and render reports to HHS.

In addition, under its FTC consent order, Rite Aid separately agreed to external, independent assessments of its pharmacy stores’ compliance with the FTC consent order.

The HHS corrective action plan will be in place for three years; the FTC order will be in place for 20 years.

Proposed Privacy Rule Changes

The Rite Aid resolution agreement and consent order follows the July 8, 2010 publication by OCR of proposed changes to its existing HIPAA Privacy, Security, and Enforcement Rules in response to amendments enacted under the HITECH Act. Because of the lead time required to implement needed changes in policies, technology and training, Covered Entities need to begin preparations to adjust their health information privacy and data security policies and practices in anticipation of the finalization and implementation of these rules as well as to act quickly to submit their comments about the proposed changes.  .

The more than 220 page Notice of Proposed Rulemaking (NPRM) proposes to revise the existing Standards for Privacy of Individually Identifiable Health Information (Privacy Rule); the Security Standards for the Protection of Electronic Protected Health Information (Security Rule); and the rules pertaining to Compliance and Investigations, Imposition of Civil Money Penalties, and Procedures for Hearings (Enforcement Rule) issued under HIPAA.

The author of this update, attorney Cynthia Marcotte Stamer, has extensive experience advising and assisting health care providers and other health industry clients with HIPAA and other privacy and data security, reimbursement, compliance, public policy, regulatory, staffing, and other operations and risk management matters. Ms. Stamer also is regularly conducts training on HIPAA and other health industry compliance, management and operations matters.  You can get more information about her health industry experience here.  If you need assistance with these or other compliance concerns, wish to inquire about arranging for compliance audit or training, or need legal representation on other matters please contact Ms. Stamer at (469) 767-8872  or via e-mail here.  You may link to her on Plaxo and Linkedin as well where she posts she articles.

Patient Visits: Changes, Increase Revenue, & Ordered Services


“15 MINUTE THOUGHT”

New Patient Visit Requirements: Increase Your Revenue

MAS is pioneering an informational program that you can listen to over a cup of coffee while you organize your day or on your drive to work. The name of the program is “15 Minute Thought”.  These calls will be free and informative.  Our focus is to give you a new thought once per month to help improve your business during these tough regulatory times.  The call participation should be maintained although CME/CEUs are not attached, it documentation of education efforts.

We will discuss health care reform changes that impact the requirements for patient visits, date last seen, and chart documentation.  We will discuss how to make lemonade out these lemons!  We need to cease the opportunity to increase revenues out of these changes.  Spend 15 minutes and learn about changes that can stop your payments as well as how to increase your revenue.

Program your Phone and Calendar:

The 2nd* and 3rd Wednesday Every Month

July 21, 2010  at 8:30am-8:45am CST

Speaker:          Angela Miller, CHC, Compliance & Billing Expert & Edward Vishnevetsky of Thompson Coe

MAS Conference Call Dial-in#:         218-862-1300

Conference Code:                               622911

MAS Office number:                          972-459-1508

Who should call in?

All health care provider, Health care business owner or manager, Physicians, Home Health, DME, HME, Attorneys, Compliance Officer, and Office Managers

Follow MAS Blog for Schedule & Updates.  You can “follow” MAS on all social media and new blog links are published.  We only publish useful information and breaking news.

Blog:  http://www.angelamillermas.wordpress.com or via website
Linkedin:  http://www.linkedin.com/in/medicalauditingsolutions
Facebook:  http://www.facebook.com/home.php#!/AngelaMiller.MAS

Edward L. Vishnevetsky has extensive experience in the area of health law and commercial litigation. He routinely argues before state and federal courts in areas of health law, employment law, and complex commercial litigation, and also represents hospitals, physicians, durable medical equipment (DME) providers and manufacturers before various state and federal regulatory agencies. Edward advises health care clients on operational matters, liability exposure, privacy issues, federal and state health care regulatory compliance, health care reimbursement disputes, as well as risk management issues. He has represented individuals, physician groups, hospitals, ambulatory surgery centers, sleep laboratories, dialysis clinics, independent diagnostic testing facilities, and DME suppliers.

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.

“15 Minute Thought” Schedule – Free Informational Programs


“15 MINUTE THOUGHT”

MAS is pioneering an informational program that you can listen to over a cup of coffee while you organize your day or on your drive to work. The name of the program is “15 Minute Thought”.  These calls will be free and informative.  Our focus is to give you a new thought once per month to help improve your business during these tough regulatory times.

Program your Phone and Calendar:

The 2nd* and 3rd Wednesday Every Month                 at 8:30am-8:45am CST

* Indicates specific audience

MAS Conference Call Dial-in#:         218-862-1300

Conference Code:                               622911

MAS Office number:                          972-459-1508

MAS Fax:                                               214-461-0295

Who should call in?

Any health care provider, Health care business owner or manager, Attorneys, Compliance Officer, and Office Managers

Schedule & Topics

July 14, 2010               Bankruptcy Attorneys & other Attorneys:  What you need to know about Medical Receivables*

July 21, 2010               Patient Visits: Changes, Increase Revenue, & Ordered Services

August 11, 2010         Physicians: NP & PA Visits: Can the non-physician provider be billed under the physician?*

August 18, 2010         Payer Audits Giving “RAC’d” a Whole New Meaning: Tips to Manage Audits

September 8, 2010      Conflict of Interest: Pay Attention or Write a Big Check

September 15, 2010    Compliance Officer:  Who? What? …Really?

October 13, 2010        Dental Providers:  Reform & Common Audit Errors*

October 20, 2010        Reserve Chute: Not just for jumping out of planes

There will be guest speakers.  We will release the brief description of the call within the next 24 hours.  There are plans to have Edward Vishnevetsky of Thompson Coe, Darrell Armer of Looper Reed & McGraw, David Reimer of Dental Medical Economics as well as others guest such as Advocate, MD present over the next few months as we roll this program out.  You will hear thoughts from some of the best in the health care industry.  The guest schedules are not finalized and they may participate in programs setup on this schedule.  We may increase the number of calls depending on the attendance.

Follow MAS Blog for Schedule & Updates.  You can “follow” MAS on all social media and new blog links are published.  We only publish useful information and breaking news.

Blog:  http://www.angelamillermas.wordpress.com or via website
Linkedin:  http://www.linkedin.com/in/medicalauditingsolutions
Facebook:  http://www.facebook.com/home.php#!/AngelaMiller.MAS

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.