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CERT A/B Contractor Task Force: Will it Streamline Coding and Billing?

August 21, 2013


United with a shared goal, all Medicare Administrative Contractors (MACs) joined forces in an August 20, 2013 national conference call to announce the formation of a new combined Part A and Part B Medicare Contractors Task Force. This Task Force will be addressing educational issues of concern leading to the Medicare improper payment errors as calculated from the Centers for Medicare & Medicaid Services (CMS) Comprehensive Error Rate Testing (CERT) Program. The new initiative is independent from the CERT team and CERT Contractors’ roles, which are responsible for calculating the Medicare fee-for-service improper payment rate. During the conference call, the Part A and Part B Contractors provided an overview of the Task Force objectives and how they plan to proceed in the next few years. The Contractors’ view this new partnership as a benefit to the provider community in that this level of collaboration and consistency will help to reduce costly claim denials. The role of the A/B Task Force will be to:


Will You Be Reimbursed Fairly For Patients Enrolled In Health Insurance Exchanges?

August 14, 2013


Beginning on October 1, 2013, numerous Health Insurance Exchanges (HIE) will be open for business allowing millions of uninsured people to begin fulfilling a mandate established by the Affordable Care Act (ACA). Starting then on January 1, 2014 providers will begin to feel the impact of the ACA when these newly-enrolled subscriber's health insurance plans come into play.


Inpatient or Observation? CMS May Finally be Dealing with a Long-Standing Confusing Rule

August 7, 2013


The Centers for Medicare & Medicaid Services (CMS) and Members of Congress, have raised concerns about hospitals’ use of observation stays and short inpatient stays. Over the years there has been confusion as to when a patient should be classified as an inpatient as opposed to an outpatient or in observation status. CMS proposed a hospital inpatient prospective payment system (IPPS) rule for FY 2014, published in the May 10, 2013 Federal Register, updating the current observation rule. The proposal would streamline the rule in that admissions spanning at least two midnights will presumptively qualify as inpatient admissions for payment (under Medicare Part A); when an admission spans less than two midnights it will be considered an outpatient visit (paid under Medicare Part B). CMS does allow the documentation in the medical record to overcome these presumptions. For example, a patient who is only in the hospital for one midnight census can be considered an inpatient if he or she left earlier than expected by the physician and the documentation in the medical record supports the physician's expectation that the patient would be in the hospital longer. The proposed rule can be found on the Government Printing Office website.


Bridging the Healthcare Gap? Nurses and Physician Assistants Taking over Physicians’ Duties.

July 31, 2013


Recently, nurses and physician assistants have seen an expansion in their scope of practice, allowing them to perform tasks that have traditionally been reserved for licensed physicians. The reason for this trend is twofold. First, it is widely agreed that our country is currently experiencing a physician shortage, especially in the primary care arena. Secondly, with the enactment of the Patient Protection and Affordable Care Act (“PPACA”) in 2010, millions of Americans will soon gain health insurance coverage, and the current healthcare system does not have enough physicians to administer their care. The reasons supporting and opposing expanding nurses and physician assistants’ scope of practice are many. It is with this landscape and the consistently diminishing reimbursement to healthcare providers, generally, that the industry is presented with the challenge of providing more patients with quality care more efficiently.


Achieving Gold, Silver, or Bronze Hospital Ratings: What The Rating Systems Means And Why Should Hospitals Be Concerned?

July 24, 2013


Hospital Compare was introduced in April 2005 as part of the Centers for Medicare & Medicaid Services (CMS) Hospital Quality Initiative. The Hospital Quality Initiative uses a variety of tools to help stimulate and support improvements in the quality of care delivered by hospitals. The intent is to help improve hospitals’ quality of care by distributing objective, easy to understand data on hospital performance, and quality information from consumer perspectives.


CMS 2014 Outpatient Prospective Payment System (OPPS) Proposed Rule Could Significantly Impact Hospital Evaluation and Management (E/M) Coding and Reimbursement

July 17, 2013


The Centers for Medicare and Medicaid Services (CMS) is proposing to collapse the current five levels of outpatient visit codes with a single Healthcare Common Procedure Coding System (HCPCS) code for each unique type of outpatient hospital visit; one for clinic and one for each type of emergency department visit (24 hour and non-24 hour). CMS believes that collapsing the current five levels of codes to one level will: 1) remove incentives hospitals may have to provide medically unnecessary services or expend additional, unnecessary resources to achieve a higher level of visit payment under the hospital Outpatient Prospective Payment System (OPPS); 2) reduce administrative burden and be easily adopted by hospitals; and 3) allow a large universe of claims to be utilized for rate setting.


What Does a One Year Delay Mean for Healthcare Providers?

July 10, 2013


Last week, the Obama Administration announced in a Treasury Department blog post, that the White House said it would delay until 2015 the Affordable Care Act’s (ACA) requirement that businesses with more than 50 employees offer insurance. Those businesses were to face a $2,000 per worker penalty (minus the first 30 workers) for not doing so starting next year. According to the Administration this is designed to meet two goals. First, it will allow the Administration time to consider ways to simplify the new reporting requirements consistent with the law. Second, it will provide time to adapt health coverage and reporting systems while employers are moving toward making health coverage affordable and accessible for their employees. "We have heard concerns about the complexity of the requirements and the need for more time to implement them effectively," Mark Mazur, PhD, assistant secretary for tax policy at the Treasure Department, noted in his blog post announcing the move. "We recognize that the vast majority of businesses that will need to do this reporting already provide health insurance to their workers, and we want to make sure it is easy for others to do so.”


Patient Financial Interactions and Satisfaction

July 2, 2013


The key to improving all aspects of performance (clinical, financial and operational) is to really listen to what your patients are saying and act on those insights. With the movement to Hospital Value-Based Purchasing (VBP) and the integration of the Hospital Consumer Assessment of Health Providers and Systems (HCAHPS) survey into a portion of the Inpatient Prospective Payment System (IPPS) hospitals are targeting how they may better communicate with their patients to improve their satisfaction with their total care experience.


Addressing Medicare Payment Differences Across Sites of Care

June 26, 2013


The Medicare Payment Advisory Commission (MedPAC) has been addressing Medicare payment differences across ambulatory settings. Currently, Medicare’s payment rates often vary for the same ambulatory services provided to similar patients in different settings, such as physicians’ offices, hospital outpatient departments (OPDs), and ambulatory surgical centers (ASCs). Services that are covered under the fee schedule for physicians and other health professionals, also known as the physician fee schedule (PFS), have two payment rates: one for when the physician provides the service in his or her office (the non-facility rate) and another for when the physician provides the service in a facility such as a hospital outpatient department (OPD), other provider-based entity, or ambulatory surgical center (the facility rate). When a service is provided in a physician’s office, there is a single payment for the service. However, when a service is provided in a facility, Medicare makes a payment to the facility in addition to the payment to the physician. As more physicians shift from free-standing practices to hospital-based outpatient clinics, MedPAC is concerned Medicare spending will increase, as payment rates for hospital outpatient departments are higher than for physicians' offices.


Medicare Urges Seniors to Join the Fight Against Fraud

June 19, 2013


The Centers for Medicare and Medicaid Services (CMS) is ramping up their efforts to involve Medicare senior citizens in the government’s ongoing battle to fight health care fraud and abuse. Several new initiatives were recently announced by CMS:


CMS Compliance Countdown Calendars

June 12, 2013


Today’s discussion is about several fast-approaching deadlines.  These include: CMS e-prescribing penalty, Physician Quality Reporting System (PQRS), Electronic Health Records (EHR), Meaningful Use (MU), Health Insurance Portability Accountability Act (HIPAA), and the conversion from version 9 to 10 of the International Classification of Diseases codes (ICD-10).  Let’s review each of these programs and what their looming compliance or effective dates mean to health care providers’ future revenue.


Summary of the US Department of Health & Human Services Office of Inspector General Semiannual Report to Congress October 2012—March 2013

June 5, 2013


Every six months the Department of Health and Human Services (HHS) Office of Inspector General (OIG) Semiannual Report to Congress describes significant problems, abuses, deficiencies, and investigative outcomes undertaken by the Department. The Semiannual Report is often described as the OIG's “make good report” to support ongoing investigations and additional funding requests to Congress. This report provides some valuable insight to all health care providers on the war against fraud and abuse.


Advancements in Military Medical Care Help All of Us: Recognizing and Reimbursing New Treatments and Technology

May 29, 2013

Memorial Day was first widely observed in May 1868, to commemorate the sacrifices of the Civil War, when family members and citizens across the United States decorated the graves of more than 20,000 Union and Confederate soldiers. MiraMed Global Services (MMGS) would like to take a moment to thank all veterans and their families for the sacrifices they have made for our freedom.


CMS Instructions for Healthcare Providers and Facilities in the Event of a Disaster or an Emergency Situation

May 22, 2013


Natural disasters in America are always difficult. Our first concern is about the safety and welfare of the people involved. The buildings, the cars that are tossed around like toys and the personal belongings, while precious to their owners, quickly become meaningless when life and limbs are at risk. MiraMed Global Services' (MMGS) prayers are with the victims of the Moore, Oklahoma tornado this past Monday. Catastrophic events like the recent tornado, Hurricane Sandy, and flooding throughout the plains area a few months ago, make us all appreciate what is most important to us.


SPECIAL ALERT: Healthcare Providers Can File Claims for Repayment under MasterCard and Visa Class Action Settlement

May 15, 2013

Jackson, MI, May 15, 2013– MiraMed Global Services, Inc. (MiraMed) has announced Healthcare providers that accept Visa and MasterCard payments are among the “merchants” that may be able to collect a portion of the fees paid to the card issuers under the proposed settlement in the Payment Card Interchange Fee and Merchant Discount Antitrust Litigation pending in federal District Court in New York.


Office of Inspector General (OIG): Updated Special Advisory Bulletin on the Effect of Exclusion from Participation in Federal Health Care Programs

May 15, 2013

On May 8, 2013, the OIG released an updated 20-page Special Advisory Bulletin describing the scope and effect of the legal prohibition on payment by Federal health care programs for items or services furnished (1) by an excluded person or (2) at the medical direction or on the prescription of an excluded person. The updated Bulletin provides guidance to the health care industry on the scope and frequency of screening employees and contractors to determine whether they are excluded persons.


Eight Things Hospitals Must Know About the CMS 2014 Proposed IPPS

May 8, 2013

On April 26, the Centers for Medicare and Medicaid Services (CMS) released its display copy of the proposed 2014 Inpatient Prospective Payment System (IPPS) for acute care hospitals (Proposed Rule). The Proposed Rule will be published in the Federal Register on May 10. The following include some notable provisions of the Proposed Rule:


IRS: Meaningful Use Incentive Payments are Taxable Income

May 1, 2013

In a memorandum dated January 14, 2013, the Office of Chief Counsel (Office) of the Internal Revenue Service (IRS) took the position that recipients of incentive payments for meaningfully using electronic health records (EHRs) under the Centers for Medicare and Medicaid Services (CMS) EHR Incentive Programs (Programs) must claim such incentive payments as income for tax purposes. In its memorandum, the Office considered the following three issues:


OIG Self-Disclosure Protocol – To Disclose or Not to Disclose

April 24, 2013

In an enforcement environment such as the one in which we experience today, wherein the government gains roughly $7 for every $1 it puts into enforcement, healthcare providers and suppliers regularly find themselves faced with new and increasing compliance enforcement threats. A provider or supplier’s failure to comply with the healthcare laws and regulations could be brought to the OIG’s attention in a number of ways, including:


CMS and OIG Revisit EHR Software Exception and Safe Harbor

April 17, 2013

On April 10, the Centers for Medicare and Medicaid Services (CMS) and the Office of Inspector General (OIG) both issued proposed rules regarding arrangements involving electronic health records (EHRs) under the physician self-referral statute (Stark Law) and the Anti-Kickback Statute (AKS). Both the Stark Law and AKS currently have exceptions for certain arrangements involving the provision of EHR software to physicians in a position to refer patients back to the facility and are facing proposed changes.


The National Commission on Physician Payment Reform

April 10, 2013

For the last 15 years, the physician payment policy that has been closest to home for practicing physicians has involved repeated down-to-the-wire congressional interventions to avert large Medicare payment rate cuts specified by the sustainable growth rate (SGR) formula. Less visible, but potentially as important or more important over the longer term, has been a series of steps to revamp the resource-based relative value scale (RBRVS) which is the foundation of the Medicare Physician Fee Schedule (MPFS), with the goal of more accurately reflecting the relative costs of providing different physician services. The 2010 Patient Protection and Affordable Care Act (ACA) authorized initiatives to explore broader payment reforms such as accountable care organizations and bundled payments. Although the focus of physician-payment policy has been the Medicare program, the impact is much broader, since private insurers and Medicaid programs incorporate many of the Medicare changes into their systems of payment to physicians.


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