In the News

RAC (Recovery Audit Contractors) has continued to stay in the forefront of every practitioner and practice administrator's mind.  It also seems to have remainded at the forefront of the IRS' mind as well - 18,000 new agents have currently been assigned to this project.

RAC is continuing to prove itself to be not only profitable for the government, but quite a money making operation for the auditors who are able to receive payouts of 22.5% of the monies brought in through RAC audits.  Diversified Collection Auditors is the name of the New Jersey handlers group.

RAC was spawned off of the premise that it would minimize the burden on providers.  However, in 2008, during the pilot stage, RAC eased the burden to the tune of 17 billion dollars in collected refunds, and the pilot soon became the reality.

The Medicaid RAC program is due to be put into effect before 2011.

Although RAC has a look-back date of three years, meaning that is how far auditors can request charts dated from, with a show of "good cause" this period can be extended - back to the original date the practitioner enrolled in teh Medicare program.  RAC covers Medicare parts A, B, C, and D.

RAC does have specific request limits:

Solo practitioners are limited to 10 records every 45 days per group NPI number,  
Groups of 2 to 5 practitioners are limited to 20 records every 45 days,
Groups with 6 to 15 practitioners are limited to 30 records every 45 days, and
Groups with 16 or more practitioners are capped at 50 records every 45 days. 

For other Part B, the limits are:

1% of the average monthly Medicare services,
a maximum of 200 records per NPI number every 45 days.

RAC also has a specific Appeals Process.  This process is as follows:

Redetermination back to the contractor - 120 days
Reconsideration to QIC - 180 days
Administrative Law Judge - 60 days
Medicare Appeals Council - 60 days
Federal District Court - 60 days

One reason RAC is so successful is because practitioners do not challenge decisions.  Practitioners should take advantage of all RAC discussion periods.  They have forty-one (41) days from the intial overpayment demand to appeal the decision and sixty (60) days from the redetermination decision to make a timely appeal.

The ultimate responsibility for correct coding lies with teh practitioner.  The number one reason for claim denial is lack of medical necessity.  Seventy-two percent (72%) of the time, physicians code incorrectly; twenty-eight percent (28%) of the time they undercode.  Judging by those numbers, accurate coding is done, in the best scenario, twenty-eight (28%) of the time.

For the security of the practitioner, a good rule of thumb is to have an AAPC (American Academy of Procedural Coders) certified coder perform a "snapshot audit" of chart documentation and coding at least one time per year.  This type of audit should follow the "never look back" rule and focus solely on the previous day's charts - not yet filed with the insurance companies.  The AAPC certified coder should either be obtained by, or notify, the practitioner's legal representative and the practitioner's accountant of the intent of the audit and sign all necessary NDA's (non disclosure agreements) before commencing the audit.  The audit should include a comprehensive retraining of proper coding and documentation techniques.

July 13, 2010 - CMIO.net

The Centers for Medicare & Medicaid Services (CMS) and the Office of the National Coordinator for Health IT (ONC) issued the final rules on Meaningful Use and Standards and Certification, which providers must follow in order to benefit from the approximate $27.3 billion in financial incentives over 10 years, authorized under the HITECH Act’s EHR incentive program.

Those who joined in the announcement were Kathleen Sebelius, Secretary of the U.S. Department of Health and Human Services, Donald Berwick, MD, new CMS Administrator, David Blumenthal, MD, the National Coordinator for Health IT and Regina Benjamin, MD, MBA, Surgeon General

The department published proposed meaningful use requirements on Jan. 16. The proposal prompted some 2,000 comments. Today, the HHS released a final regulation for the first two years (2011 and 2012) of this multiyear incentive program.

“Electronic health records are the foundation of a high performing and high quality health system,” said Sebelius. “When the record is properly designed and implemented, it is a powerful force for increasing physician and patient satisfaction.  We hope that other provider groups will embrace these standards.” She noted that only 20 percent of hospitals and 10 percent of physicians use basic EHRs.

The centerpiece of the program begins in 2011, when doctors and providers can receive incentives for the use of IT. “In order to receive these incentives, providers will need to embody these standards, as it was never our goal to use technology for technology’s sake,” Sebelius said.

Likewise, Blumenthal wrote in an editorial that was simultaneously released in the New England Journal of Medicine: “HITECH’s goal is not adoption alone but ‘meaningful use’ of EHRs—that is, their use by providers to achieve significant improvements in care. The legislation ties payments specifically to the achievement of advances in healthcare processes and outcomes.”

The final regulation is divided into two groups: a set of core objectives that constitute a starting point for meaningful use of EHRs and a separate menu of additional important activities from which providers will choose several to implement in the first two years, Blumenthal explained.

June 28, 2010 - Mary Mosquera, Government Health IT

The Centers for Medicare and Medicaid Services (CMS) plans to combine data on healthcare quality required by the health IT meaningful use plan into its ongoing physician quality reporting and incentive program.  The new health reform law required CMS to integrate its Physician Quality Reporting Initiative (PQRI) with data from the HITECH Act's meaningful use provisions by Jan. 1, 2012.

Under the PQRI, physicians who participate in Medicare can receive incentives for reporting various quality measures, a select number of which are aimed at those who want to report using EHRs.  Providers who become meaningful users of EHRs, as laid down by the HITECH Act will also be eligible for incentive payments. A final rule on that is expected soon.

The CMS has requested public comment on how it should integrate the two programs, included within a proposed rule about changes in Medicare physician payments for 2011. CMS expects to publish the proposed rule July 13.  “In an effort to align PQRI with the EHR incentive program, we propose to include many ARRA core clinical quality measures in the PQRI program, to demonstrate meaningful use of EHR and quality of care furnished to individuals,” the proposed rule says.

Meaningful use measures that physicians could use for PQRI reporting through electronic health records include such things as blood pressure measurement for hypertension, body mass index screening and prevention care follow up, and drugs to be avoided in the elderly, the CMS says. 

Tammy Mudge, Senior Consultant

Advances in the healthcare field affect all systems within your practice. Like the human body, when one system starts to fail the entire “body” can shut down. It is more important than ever to make sure your systems are strong. All too many practices are like the non- compliant patients they themselves dread. It is the practices that don’t take the same advice their providers give their patients that will struggle to survive. Preventative maintenance and complete “physicals” can detect the silent killers of your practice; early detection can be the key to survival.

Practice managers and administrators are busier than ever, so as situations arise, they grab for an over-the-counter remedy, that quick “band aid” to cure their symptoms. “Acute” exams are done when they can find a spare moment; a quick spot check of the finances, or a patient visit comparison. All of these have great value. However, they do not replace the need to give your practice a complete physical. So what is the down and dirty on how to determine if you are a healthy practice? Simply apply some SOAP.

Subjective: Review the pain points or chief complaints of the practice. Review all preventative maintenance, i.e. procedures, protocols, and standards currently in place, such as HIPAA, employee manuals, and training, along with quality measure reviews and current technology.

Objective: Detailed workflow analysis should be done to identify any bottlenecks, inconsistencies, potential patient safety issues, and common risk factors. Review of all manuals and policies to make sure they are up to date and will measure up to the highest current standards. Financial reports and policies need close attention. Is your practice taking advantage of all financial incentives? Identify all the areas in which your practice may be losing money. Intensive internal chart reviews identify many documentation and billing issues that can put your practice at risk.

Assessment: How does your practice measure up to today’s standards? Are you ready to select, adopt, and implement an EMR system? If you have already done so, are you a meaningful EMR user and/or will your current system allow you to reach that goal? Do you have the right processes and procedures in place? Identify all areas that are putting your practice, patients, and financial stability at risk.

Plan: Just as a great provider will prescribe medications, lifestyle changes, and additional education to keep you healthy, a great healthcare consultant will provide the same services. They will know when to refer you to additional specialists if a need falls outside of the scope of their expertise and will continue to provide you with the care you need to stay healthy and strong.

Sometimes it can be in your best interest to get an outside company’s perspective on the items mentioned in this article. If you choose this route, make sure you select your consultant using the same considerations you would take when selecting a provider. Seek a professional team with the reputation and experience needed to protect the life of your practice.

Click here to read Tammy's article in the Summer 2010 edition of the NJMGMA newsletter where is was recently published! 

June 18, 2010 - CMIO.net

The Office of the National Coordinator for Health IT (ONC) today issued a final rule to establish a temporary certification program for EHR technology, which established processes that organizations will need to follow in order to be authorized by the National Coordinator to test and certify EHR technology.

Use of "certified EHR technology" is a core requirement for providers who seek to qualify to receive incentive payments under the Medicare and Medicaid EHR Incentive Programs provisions authorized in the Health IT for Economic and Clinical Heath (HITECH) Act, according to the Department of Health and Human Services.  HITECH was enacted as part of the American Recovery and Reinvestment Act (ARRA) of 2009.

HHS also reported that the Centers for Medicare & Medicaid Services will soon issue final regulations to implement the EHR Incentive programs.

Certification is used to provide "assurance and confidence" that a product or service will work as expected and will include the capabilities for which it was purchased, the agency said.  EHR certification should make those assurances to healthcare providers, according to HHS, that the EHRs they adopt have been tested and includes the required capabilities they need "to use the technology in a meaningful way."

In March, HHS issued a notice of proposed rulemaking (NPRM) entitled Proposed Establishment of Certification Programs for Health IT.  The NPRM proposed the establishment of two certification programs for purposes of testing and certifying EHRs - one temporary and one permanent.  The temporary certification program final rule issued today will become effective upon publication in the Federal Register.  The final rule for the permanent certification program is expected to be published this fall.

"By purchasing certified EHR technology, hospitals and eligible professionals and hospitals will be able to make EHR purchasing decisions knowing that the technology will allow them to become meaningful users of electronic health records, qualify for the payment incentives and begin to use EHRs in a way that will improve quality and efficiency in our health care system," said David Blumenthal, MD, national coordinator for health information technology.  "We hope that all health IT stakeholders view this rule as the federal government's commitment to reduce uncertainty in the health IT marketplace and advance the successful implementation of EHR incentive programs."

This final rule is issued under the authority provided to the National Coordinator for Health Information Technology in section 3001(c)(5) of the Public Health Service Act (PHSA) as added by the HITECH Act.

For more information about the temporary certification program and rule, click here. 
Click here to download the Final Certification Rule. 

June 7, 2010 - Rob Kurtz, Becker's ASC Review

SourceMedical has announced it is collaborating with Health Informatics Consulting to help surgery centers implement electronic health records more efficiently and faster.  

Health Informatics Consulting, which is vendor neutral and has no financial interest in the vendors it works with, will help its ASC clients transition to SourceMedical's Vision and Vision EHR solutions, should they choose the platform.

"One of the many benefits of working with Health Informatics Consulting is their stellar reputation and experience," said Scott Palmer, president and COO of SourceMedical's surgery division, in a press release.  "The firm's ability to deliver a quick and seamless transition from a paper-based environment to an EHR enables ASCs to more rapidly experience the full benefits offered through our Vision EHR.  We look forward to a long relationship as they continue their success in working with ASCs." 

Tuesday, April 6. 2010

U.S. Department of Health and Human Services Secretary Kathleen Sebelius announced today that more than $267 million has been awarded to 28 additional non-profit organizations to establish Health Information Technology Regional Extension Centers (RECs). This investment, funded by the American Recovery and Reinvestment Act of 2009, will help grow the emerging health information technology (health IT) industry which is expected to support tens of thousands of jobs ranging from nurses and pharmacy techs to IT technicians and trainers.

RECs enable health care practitioners to reach out to a local resource for technical assistance, guidance, and information on best practices. RECs are designed to address unique community requirements and to support and accelerate provider efforts to become meaningful users of electronic health records.

“Health care in our country is community-based. Today’s awards represent our ongoing commitment to make sure that health providers have the necessary support within their communities to maximize the use of health IT to improve the care they provide to their patients,” said Secretary Sebelius. 

To read the rest of the article on the HHS website click here.

January 14, 2010 - Mary Mosquera, GovHealthIT.com

The National Institute of Standards and Technology awarded Booz Allen Hamilton Inc. a contract to help develop a testing method and processes for certifying electronic health record systems.

The $400,000 contract, announced Jan. 13, calls for the consulting firm to help NIST build a testing framework for health IT, a certification "process document" and other planning tools.  NIST announced the short-term contract on the Federal Business Opportunities Web site Jan. 13.

The work is part of a larger contract BAH already has with NIST for health IT consulting services, according to the announcement.  The just-announced contract will provide a bridge until NIST finished a competition for providers to complete the work.  

NIST said it had two goals for the program: to develop testing and certification documents to help set up a health IT certification program, and to set up a "proficiency testing framework" for authorizing certification and testing organizations.

NIST was provided $20 million under the American Recovery and Reinvestment Act to help the OFfice of the National Coordinator for Health IT build a "testing infrasctucture that support the security and interoperability of EHR systems," according to the agency.

The terms of the recent meaningful use rules require providers to use certified EHR systems to qualify for federal health IT incentives.  Dr. David Blumenthal, the national health IT coordinator, has said that he will announce early this year a process through which a number of different organizations could certify EHR systems.

Currently, the Certification Commission for Health IT is the sole organization set up to certify the performance of EHR systems. 

December 24, 2009 - Diana Manos, Senior Editor and Jack Beaudoin, VP Healthcare IT News

WASHINGTON - The Senate passed a sweeping healthcare reform bill Thursday morning by a 60-39 margin, all but ensuring that President Barack Obama will get one of his legislative priorities written into law in early 2010.

The Senate bill must now be reconciled with the House version, which was passed earlier this fall.  When those differences are resolved, a final vote of approval from Congress is all that stands in the way of the President's signature enacting the bill into law. 

December 21, 2009 - HIMSS.org

A $60 million Strategic Health IT Advanced Research Projects (SHARP) was announced last Friday by Dr. David Blumenthal, National Coordinator for Health Information Technology.  The SHARP funding will strengthen the health information technology infrastructure through the competitive award of approximately four cooperative agreements focused research in areas where breakthrough advances are needed to address barriers to the adoption of health IT.  

For more information click here

To download the application click here

December 02, 2009 - Diana Manos, Senior Editor Healthcare IT News

WASHINGTON - Health and Human Services Secretary Kathleen Sebelius and David Blumenthal, MD, the National Coordinator for Health Information Technology, have announced $235 million in grants supporting non-profit organizations and local governments that can exemplify the positive impact of healthcare IT on population health. 

For more information click here

To download the application click here

BELLE MEAD, NJ  (August 19, 2009) – Two new ambulatory surgical centers under construction in Northern New Jersey will streamline and improve the quality of care for patients through a partnership with Health Informatics Consulting, a leader in healthcare technology.

TRENTON, N.J., Sept 29, 2008 /PRNewswire via COMTEX/ -- Stephanie "Stevie" Davidson, president and CEO of Health Informatics Consulting, www.hi-consulting.net has been appointed by New Jersey Gov. Jon S. Corzine to serve on the state Health Information Technology Commission, a new body created to jump-start the much-needed conversion to computerized patient records by doctors.