The Department of Health and Human Services Office of Inspector General will analyze the accuracy of $14.6 billion in meaningful use payments made to hospitals by Medicare between 2011 and 2016. Initially this year, the OIG estimated physicians were wrongfully paid $729 million under meaningful use payments.
Medicare incentive payments were authorized over a 5-year period to hospitals that adopted electronic health record (EHR) technology. From January 1, 2011, through December 31, 2016, the Centers for Medicare and Medicaid Services made Medicare EHR incentive payments to hospitals totaling $14.6 billion, the OIG stated.
The Government Accountability Office recognized wrong incentive payments as the primary risk to the Medicare EHR incentive program. An OIG report described the obstacles that CMS faces in overseeing the Medicare EHR incentive program. In addition, previous OIG reviews of Medicaid EHR incentive payments found that state agencies overpaid hospitals by $66.7 million and would in the future overpay these hospitals an additional $13.2 million, the OIG claimed.
“These overpayments resulted from inaccuracies in the hospitals’ calculations of total incentive payments,” the OIG said. “We will review the hospitals’ incentive payment calculations to identify potential overpayments that the hospitals would have received as a result of the inaccuracies.”
On another front, the OIG will be analyzing the precision of telemedicine payments under Medicare.
Medicare Part B covers expenses for telehealth services on the telehealth list when those services are delivered via an interactive telecommunications system, provided few conditions are met. To support rural access to care, Medicare pays for telehealth services provided through live, interactive videoconferencing between a beneficiary located at a rural originating site and a practitioner situated at a distant site.
Showing posts with label OIG. Show all posts
Showing posts with label OIG. Show all posts
Thursday, July 20, 2017
Tuesday, June 27, 2017
Medicaid data not still available for system and oversight
A system developed to make better the completeness, precision and timeliness of Medicaid data is not yet getting the job done, in accordance with a new audit by the Department of Health and Human Services’ Office of Inspector General.
Information from the Transformed Medicaid Statistical Information System (T-MSIS) was supposed to assist ensures the effective administration and oversight of the Medicaid data program, involving enhancing the ability to recognize potential fraud while improving program efficiency.
Although, while the CMS (Centers for Medicare and Medicaid Services) had planned to implement T-MSIS with states on a rolling basis, with the aim of having all states submitting data monthly by July 2014, the OIG notes in its report that early implementation challenges have resulted in delays with T-MSIS.
“These delays were caused by technological issues during data testing and by competing priorities for states' IT resources,” according to the OIG’s audit. “As a result, the goal for when T-MSIS will contain data from all state Medicaid programs has been repeatedly postponed.”
Previous year, the federal government and states spent $574 billion on Medicaid, benefitting more than 74 million enrollees. But, without T-MSIS data, the ability to recognize trends or patterns demonstrating potential fraud, waste, and abuse in the program—as well as stop or mitigate the impact of these activities—is primarily diminished.
However, CMS expects that all states will be reporting to T-MSIS by the end of 2017, auditors reveal that just 21 of 53 state programs were submitting data to T-MSIS as of December 2016, and that it is unclear whether an end-of-the-year target date can be met.
“As states and CMS sustain to work together to submit Medicaid data into T-MSIS, they continue to raise concerns about the completeness and reliability of the data,” the report warns. “Particularly, states indicate that they are unable to report Medicaid data for all the T-MSIS data elements. Furthermore, even with a revised data dictionary that gives definitions for each data element, states and CMS report concerns about states’ varying interpretations of data elements. If states don’t have uniform interpretations of data elements, the data they submit for these elements won’t be consistent across states, making any analysis of national trends or patterns inherently unreliable.”
“Successfully getting all states’ data into T-MSIS needs states and CMS to prioritize T-MSIS implementation,” summarizes the report. “Because of CMS’s history of delaying target dates for execution, OIG is concerned that CMS and states will delay further instead to assign the resources required to deal the outstanding challenges.”
Auditors continue to suggest that CMS develop a deadline for when T-MSIS data will be available for program analysis and other management functions, contending that “without a fixed deadline, some states and CMS may not make the full implementation of T-MSIS a management priority.”
CMS officials weren’t immediately available for comment. However, in its written response to the OIG, the agency reported that since December 2016 more states—40 altogether—have successfully started submitting data to T-MSIS.
Nevertheless, while progress has been made on the number of states submitting data to T-MSIS, CMS concurred with OIG on the requirement for reliable data. In its written comments, the agency highlighted its ongoing work to improve data quality.
Specifically, CMS demonstrated that it has 2 major goals for T-MSIS data quality: transparency for users, and a continuous, ongoing improvement process with states to strengthen the Medicaid data quality. To realize these aims, the agency said it is undertaking a variety of actions, involving information for users on data quality, one-on-one technical assistance to states to ensure their data will be usable, as well as a post-production data quality review with a subset of states to establish an effective working process for improving data quality.
Additionally, CMS informed the OIG that it convened a Technical Evaluation Panel to gain initial feedback on data quality and usability. In accordance with the agency, the panel assessed a subset of T-MSIS data to identify anomalies in the data and potential challenges with using the data for analysis. CMS intends to use the panel’s findings to inform efforts to improve the states’ data quality.
Information from the Transformed Medicaid Statistical Information System (T-MSIS) was supposed to assist ensures the effective administration and oversight of the Medicaid data program, involving enhancing the ability to recognize potential fraud while improving program efficiency.
Although, while the CMS (Centers for Medicare and Medicaid Services) had planned to implement T-MSIS with states on a rolling basis, with the aim of having all states submitting data monthly by July 2014, the OIG notes in its report that early implementation challenges have resulted in delays with T-MSIS.
“These delays were caused by technological issues during data testing and by competing priorities for states' IT resources,” according to the OIG’s audit. “As a result, the goal for when T-MSIS will contain data from all state Medicaid programs has been repeatedly postponed.”
Previous year, the federal government and states spent $574 billion on Medicaid, benefitting more than 74 million enrollees. But, without T-MSIS data, the ability to recognize trends or patterns demonstrating potential fraud, waste, and abuse in the program—as well as stop or mitigate the impact of these activities—is primarily diminished.
However, CMS expects that all states will be reporting to T-MSIS by the end of 2017, auditors reveal that just 21 of 53 state programs were submitting data to T-MSIS as of December 2016, and that it is unclear whether an end-of-the-year target date can be met.
“As states and CMS sustain to work together to submit Medicaid data into T-MSIS, they continue to raise concerns about the completeness and reliability of the data,” the report warns. “Particularly, states indicate that they are unable to report Medicaid data for all the T-MSIS data elements. Furthermore, even with a revised data dictionary that gives definitions for each data element, states and CMS report concerns about states’ varying interpretations of data elements. If states don’t have uniform interpretations of data elements, the data they submit for these elements won’t be consistent across states, making any analysis of national trends or patterns inherently unreliable.”
“Successfully getting all states’ data into T-MSIS needs states and CMS to prioritize T-MSIS implementation,” summarizes the report. “Because of CMS’s history of delaying target dates for execution, OIG is concerned that CMS and states will delay further instead to assign the resources required to deal the outstanding challenges.”
Auditors continue to suggest that CMS develop a deadline for when T-MSIS data will be available for program analysis and other management functions, contending that “without a fixed deadline, some states and CMS may not make the full implementation of T-MSIS a management priority.”
CMS officials weren’t immediately available for comment. However, in its written response to the OIG, the agency reported that since December 2016 more states—40 altogether—have successfully started submitting data to T-MSIS.
Nevertheless, while progress has been made on the number of states submitting data to T-MSIS, CMS concurred with OIG on the requirement for reliable data. In its written comments, the agency highlighted its ongoing work to improve data quality.
Specifically, CMS demonstrated that it has 2 major goals for T-MSIS data quality: transparency for users, and a continuous, ongoing improvement process with states to strengthen the Medicaid data quality. To realize these aims, the agency said it is undertaking a variety of actions, involving information for users on data quality, one-on-one technical assistance to states to ensure their data will be usable, as well as a post-production data quality review with a subset of states to establish an effective working process for improving data quality.
Additionally, CMS informed the OIG that it convened a Technical Evaluation Panel to gain initial feedback on data quality and usability. In accordance with the agency, the panel assessed a subset of T-MSIS data to identify anomalies in the data and potential challenges with using the data for analysis. CMS intends to use the panel’s findings to inform efforts to improve the states’ data quality.
Saturday, March 4, 2017
New scheme seems to use deceptive phone line to get personal information
The phone number of a hotline being utilized by the Office of the Inspector General of the Department of Health and Human Services apparently is being used by scammers to get personal information from people who consider they are talking to OIG staff. New scheme seems to use deceptive phone line to get personal information.
The OIG hotline accepts tips and complaints about potential scam and mismanagement including HHS programs, which OIG inquires.
Although, HHS now is warning clients that scammers are altering the numbers that appear on caller ID devices; when the criminals call, devices display the HHS hotline phone number (1-800-HHS-TIPS). Victims who receive the calls are at risk for offering the scammers personal information that can be used to raid a bank account or perform other fraudulent activity.
New scheme seems to use deceptive phone line to get personal information.
The OIG affirms that it doesn’t use the hotline number to make outgoing calls; the organization is advising consumers not to answer phone calls that purportedly come from HHS. The agency further is asserting that it remains safe to call the hotline to report fraud or mismanagement, and it specifically motivates those who might have been victimized by the phone call hoax to contact the agency by straightly calling the hotline.
The agency counsels consumers to not provide data over the phone to a person posing as from HHS, like Social Security numbers, dates of birth, credit card numbers, driver license numbers, bank account numbers or mother’s maiden names.
When calling HHS to report fraud, involve date and time you got the phone call and details about the call. People also can file a complaint with the Federal Trade Commission.
The OIG hotline accepts tips and complaints about potential scam and mismanagement including HHS programs, which OIG inquires.
Although, HHS now is warning clients that scammers are altering the numbers that appear on caller ID devices; when the criminals call, devices display the HHS hotline phone number (1-800-HHS-TIPS). Victims who receive the calls are at risk for offering the scammers personal information that can be used to raid a bank account or perform other fraudulent activity.
New scheme seems to use deceptive phone line to get personal information.
The OIG affirms that it doesn’t use the hotline number to make outgoing calls; the organization is advising consumers not to answer phone calls that purportedly come from HHS. The agency further is asserting that it remains safe to call the hotline to report fraud or mismanagement, and it specifically motivates those who might have been victimized by the phone call hoax to contact the agency by straightly calling the hotline.
The agency counsels consumers to not provide data over the phone to a person posing as from HHS, like Social Security numbers, dates of birth, credit card numbers, driver license numbers, bank account numbers or mother’s maiden names.
When calling HHS to report fraud, involve date and time you got the phone call and details about the call. People also can file a complaint with the Federal Trade Commission.
Friday, September 2, 2016
N.J. made incorrect Medicaid EHR incentive payments
The New Jersey (N.J) Department of Human Services made incorrect Medicaid EHR incentive payments to fifteen hospitals, in accordance to an audit by the Department of Health and Human Services’ Office of Inspector General.
The net or average rate of the erroneous payments by New Jersey totaled $2.5 million, auditors told. 10 hospitals were overpaid $2.4 million, while 5 hospitals were underpaid $137,000, which resulted in a net overpayment of almost $2.3 million. The state agency didn’t always pay EHR incentive program payments in accordance with the federal and state needs, summarizes the report.
Furthermore, the OIG discovered that New Jersey made incorrect Medicaid EHR incentive payments to 2 extra hospitals. Although, auditors confirmed that the state agency adjusted these payments after their audit time period. Moreover, New Jersey didn’t report 1 professional incentive payment to the CMS National Level Repository (NLR), a registration and verification network that consists of data on contributors participating in the Medicaid and Medicare EHR incentive programs.
“The incorrect Medicaid EHR incentive payment errors happened because the state agency’s program integrity contractor failed to recognize few mistakes and inconsistently applied this latest program’s complex needs,” claims the OIG report. “The reporting error happened because of a technical error.”
The report points out that the Government Accountability Office has recognized faulty payments as the primary risk to the EHR incentive programs.
“These programs might be at higher threat of improper payments in comparison to other programs because they’re latest and have complex needs,” assert auditors.
OIG suggested that New Jersey take the following corrective measures:
- Refund to the federal government nearly $2.3 million in net overpayments made to the fifteen hospitals.
- Adjust the fifteen hospitals’ rest over incentive payments to account for the faulty calculations (hoped to result in future cost savings of $514,107).
- Work with CMS to make sure that the 1 unreported professional incentive payment is reported to the NLR.
- Consider the calculations for other hospitals in the state that weren’t among the 33 that auditors analyzed, to evaluate whether payment adjustments are required and refund to the federal government any overpayments recognized.
Friday, August 19, 2016
OIG: CMS data center wireless systems susceptible
A wireless penetration test of data centers functioned by the Centers for Medicare and Medicaid Services (CMS) have recognized susceptibilities in network security controls.
The testing by the Department of Health and Human Services’ Office of Inspector General was performed at thirteen CMS data centers and services utilizing tools and techniques usually utilized by attackers to acquire unauthorized approach to wireless networks and sensitive information.
“However the Centers for Medicare and Medicaid Services (CMS) had security controls that were effective in stopping few kinds of wireless cyber-attacks, we recognized 3 major susceptibilities in security controls over its wireless systems,” claims an OIG report.
“The susceptibilities that we recognized were collectively and, in few cases, individually significant,” investigators stated. “However we didn’t recognize evidence that the susceptibilities had been exploited, exploitation could have resulted in unauthorized approach to and disclosure of personally identifiable data, as well as disruption of critical operations. Additionally, exploitation could have compromised the confidentiality, integrity, and presence of CMS’s information and wireless systems.”
In accordance to OIG, CMS demonstrated that these vulnerabilities were the outcome of “improper configurations and failure to complete essential upgrades that CMS initially identified and reported as having been presently underway.”
Auditors suggested that CMS should make better its security controls to deal the identified wireless system vulnerabilities. “When executed, these suggestions should further strengthen the data security of CMS’s wireless systems,” adding that “due to the sensitive nature of our findings, we’ve not listed the detailed suggestions in this summary report.”
In its written response to the report, CMS concurred with all of OIG’s findings and claimed that it had already dealt several of the problems and is in the procedure of taking care of the rest. The report points out that CMS commented separately on the more detailed information OIG sent to the organization, which demonstrated that it had accepted the responsibility for resolving the susceptibilities.
Thursday, June 2, 2016
DoD inspector asks whether EHR decline of agency will be met
The Defense Department’s policies to implement a new electronic health record (EHR) system by the month of December may not be realistic, in according to a new audit from the DoD Office of the Inspector General.
In July 2015, the Pentagon granted a $4.3 billion contract award to a Leidos-Cerner team to modernize DoD’s EHR system. Called the Defense Healthcare Management System Modernization (DHMSM), the integrated system is designed to replace legacy military health systems and promote greater efficiencies by leveraging commercial-off-the-shelf Cerner Millennium solution.
An initial deployment is slated for December, when the EHR will be rolled out to DoD locations in the Pacific Northwest. But the OIG is concerned that the DHMSM program schedule might not meet initial operational capability needs by the end of this year.
“While the DHMSM program office has recognized the threats and mitigation strategies, it is still at risk for obtaining an EHR system by the December 2016 initial operational capability date due to the risks and potential delays involved in developing and testing the interfaces required to interact with legacy systems, ensuring the system is secure against cyber attacks, and ensuring the fielded system works correctly and that users are properly trained,” concluded the OIG report, which was released on Tuesday.
However, speaking that similar day at the ONC Annual Meeting in Washington, DC, Stacy Cummings, program executive officer for the Defense Healthcare Management Systems program, gave no indication that the EHR implementation schedule might be at risk because of potential delays with interfaces and inadequate training.
“We are going to be doing testing both prior to and during the deployment to make sure that our interfaces are working, to ensure that the workflows are working, as well as to make sure that it’s operationally suitable for our needs in the Department of Defense,” said Cummings, who oversees DoD’s EHR modernization, including the operational, infprmation exchange and interoperability initiatives.
She added that DHMSM is contributing in training, change management and coaches to aid the deployment of the new EHR. “As we deploy to a location, we are not just training people how to use the system,” stated Cummings. “We’re actually teaching them how to take advantage of the business processes and the decision support that is inherent in the commercial tool.”
Nonetheless, the OIG suggested that Cummings, as the program executive officer for Defense Healthcare Management Systems conduct a schedule analysis to determine whether the December 2016 initial operational capability deadline is achievable and remain to monitor DHMSM program threats and report to Congress quarterly on the progress of the program.
In July 2015, the Pentagon granted a $4.3 billion contract award to a Leidos-Cerner team to modernize DoD’s EHR system. Called the Defense Healthcare Management System Modernization (DHMSM), the integrated system is designed to replace legacy military health systems and promote greater efficiencies by leveraging commercial-off-the-shelf Cerner Millennium solution.
An initial deployment is slated for December, when the EHR will be rolled out to DoD locations in the Pacific Northwest. But the OIG is concerned that the DHMSM program schedule might not meet initial operational capability needs by the end of this year.
“While the DHMSM program office has recognized the threats and mitigation strategies, it is still at risk for obtaining an EHR system by the December 2016 initial operational capability date due to the risks and potential delays involved in developing and testing the interfaces required to interact with legacy systems, ensuring the system is secure against cyber attacks, and ensuring the fielded system works correctly and that users are properly trained,” concluded the OIG report, which was released on Tuesday.
However, speaking that similar day at the ONC Annual Meeting in Washington, DC, Stacy Cummings, program executive officer for the Defense Healthcare Management Systems program, gave no indication that the EHR implementation schedule might be at risk because of potential delays with interfaces and inadequate training.
“We are going to be doing testing both prior to and during the deployment to make sure that our interfaces are working, to ensure that the workflows are working, as well as to make sure that it’s operationally suitable for our needs in the Department of Defense,” said Cummings, who oversees DoD’s EHR modernization, including the operational, infprmation exchange and interoperability initiatives.
She added that DHMSM is contributing in training, change management and coaches to aid the deployment of the new EHR. “As we deploy to a location, we are not just training people how to use the system,” stated Cummings. “We’re actually teaching them how to take advantage of the business processes and the decision support that is inherent in the commercial tool.”
Nonetheless, the OIG suggested that Cummings, as the program executive officer for Defense Healthcare Management Systems conduct a schedule analysis to determine whether the December 2016 initial operational capability deadline is achievable and remain to monitor DHMSM program threats and report to Congress quarterly on the progress of the program.
Tuesday, May 3, 2016
OIG Finds Data Security problems with VA Audit Logs
In accordance to a recent VA Office of Inspector General (OIG) report, the Veterans Benefits Administration ignored to implement suitable audit logs that would identify data security violations in the Veterans Benefits Management System (VBMS).
Previous month, OIG was notified by an anonymous entity that the Veterans Benefits Administration had not integrated proper audit logs in the VBMS, a claims processing system.
Upon investigation, OIG found officers at the Veterans Benefits Administration failed to develop satisfactory system requirements in the VBMS that would ensure that accurate audit logs were made.
Without correct audit logs, Information Security Officers could not effectively identify, report, and react to data security problems in the VBMS, OIG pointed out. The organization also could not track if an employee improperly processed a claim.
OIG founded that the VBMS was not compliant with audit log procedures and regulations after testing the functionality at 2 facilities in Texas and one in Washington. Seventeen VA Regional Office workers were tasked with inappropriately accessing the same-station veteran worker compensation claims in VBMS and Information Security Officers were inquired to review the audit logs.
Monday, February 7, 2011
OIG’s List of Most-Wanted Health Care Fugitives
Check out OIG’s first-ever list of most-wanted health care fugitives.
These 10 individuals have allegedly defrauded taxpayers of more than $124 million. For OIG, tracking more than 170 health care fugitives is a challenge, but you can help. If you have a tip about a featured most-wanted fugitive, send the information our way!
These 10 individuals have allegedly defrauded taxpayers of more than $124 million. For OIG, tracking more than 170 health care fugitives is a challenge, but you can help. If you have a tip about a featured most-wanted fugitive, send the information our way!
Thursday, December 10, 2009
Cardiology Billing
Cardiology Billing
If you are not aware and prepared for the 2009 cardiology billing and coding changes you may be leaving a lot of money uncollected. The 2009 coding and billing changes are the most significant for cardiology that have been seen since the mid 1990s.
While the average physician will see slightly over a 1% increase in Medicare fees, Cardiologists will see a 2% reduction in fees. This is mainly the result of lower payments for office-based imaging. Cardiologist that have a higher than average use of imaging services will see decreases in their Medicare fees far in excess of 2%, while other cardiologists may be able to achieve an increase in Medicare fees.
Here are examples of some of the upcoming changes:
• All of the codes previously used to submit charges for implanted device follow-up have been deleted and replaced with new codes. Not only have the old codes been replaced, but they have been replaced with a more updated code set that provides codes for checks of devices with leads in 3 chambers, codes specific to a remote (internet) device check, codes for following ICM devices, codes for per procedural checks, etc.
• Global periods related to device follow-up now include global periods of 30 or 90 days. The new codes are now service specific (i.e., either an interrogation evaluation of a programming evaluation).
• Wearable cardiac telemetry devices (for instance Cardio net type service) now have specific codes. You no longer bill with an unlisted code. These new codes include the complication of global periods.
• Codes that bundle multiple echo services under a single code have been introduced. Examples include a single CPT for bundling an echo with both a Doppler and color flow and a stress echo CPT that bundles both the stress test and stress echo.
As the examples above demonstrate, the magnitudes of this year’s cardiology billing changes are more significant that has been seen in recent years. Without proper education, training, software upgrades and billing resources cardiology practices may see marked reductions in collections and increases in AR.
Importance of Cardiology Billing
Medical billing is a crucial health care service that supports physicians by submitting and collecting the payments from insurance companies and patients. One needs to be an expert to ensure that the bills are collected fully and in a timely fashion. It is quite common for over 20% of a practice's potential revenue to remain unclaimed because of improper coding and weak collection strategies. Outsourcing medical billing is growing in popularity as an approach for addressing this tremendous loss of practice income. The range of outsourcing options runs from extremely large organizations to individual freelancers who work from home to provide medical billing services.
Medical billing is a highly complex area and it requires experience-based knowledge and expertise to contend with insurance companies. When it comes to cardiovascular billing, the situation gets even more complex. Such complexity can be handled only by a company that is staffed with well trained cardiology billing professionals. The medical billing specialist must be familiar with the specific codes and rules that make up the world of cardiac billing. Cardiovascular coding and cardiac billing cannot be done by everyone, it is a highly specialized field and it is not possible to be successful in collecting the bills fully from the insurance companies without the proper skills and training.
As the cost of providing cardiology related healthcare services continues to rise, medical institutions and cardiology practices cannot afford to leave revenue uncollected by billing companies or freelancers that are not knowledgeable in cardio billing. It is also important to keep in mind some companies may promote themselves as large cardiac billing service providers but in reality they sub-contract the cardiovascular billing to freelancers who work from home. Hiring such companies will lead to lost revenue because of the lack of proper process, controls, and training.
One of the major drawbacks of hiring a company that does not specialize in cardiology billing is their lack of familiarity with the procedures and the terminologies used. Even if the medical billing company serves one or two cardiologists, they will lack the depth and breadth of expertise required for successful cardiology billing. Moreover if the hired company does not specialize in cardiovascular billing, then they will not have the expertise to effectively appeal denied claims or answer questions raised by the insurance companies. A company that does not encompass a wide range of cardiology billing experience will find it difficult to track underpayments since multiple procedure rules, nuclear camera rules and cardiology procedures have significantly more complicated contractual adjustment rules than a typical family doctor or internist's claims. In addition, the billing software and system design of a generalist billing company will often be insufficient for the more complicated requirements of reporting and insurance follow-up required in cardiology billing.
These billing complications extend to the patient collections arena as well. The patient collection process for specialists like cardiologists is more complicated because of the large patient balances often owed, the complexity of the procedures/EOBs that must be explained to patients that do not understand their bills and the typically older population cardiologists serve. A medical billing service with expertise in cardiology billing knows how to deal with these situations. Billing services without such experience will increase the risk of both lower patient collections and upset patients confused about their bill.
To avoid all these billing related pitfalls cardiologists need to utilize specialized cardiology billing services. It is not advisable for an internist to perform cardiac surgery, similarly someone without training in cardiovascular coding and cardiology billing is not qualified to offer reliable billing services for cardiovascular practices.
2009 Challenges in Cardiology Billing
If you are not aware and prepared for the 2009 cardiology billing and coding changes you may be leaving a lot of money uncollected. Not since the mid 90’s have cardiology seen such significant coding and billing changes as have been put in place in 2009. Across the board the average Medicare fee increased just 1.1 percent. Cardiology in general fared worse than average, experiencing an average decrease of 2% due primarily to decreases in payments for in-office imaging. Keep in mind the 2% reduction is an average number. Some practices will be well above this (especially heavy users of echo services) and others will actually see fee increases.
Here are examples of some of the upcoming changes:
- Sweeping changes in the codes for following up on implanted devices (sweeping as in all of the old codes are gone and the new ones have significant differences). The new codes include such things as specific codes or internet (remote) device checks, codes for devices with leads in 3 chambers, ICM device follow-up codes, and codes for per procedural checks.
- 30 and 90 day global periods are now in place for follow-up for some devices. Also, the new codes are specific to either an interrogation evaluation or a programming evaluation. The codes are no longer dependent on whether reprogramming occurred.
- Wearable cardiac telemetry devices (for instance Cardio net type service) now have specific codes. You no longer bill with an unlisted code. These new codes include the complication of global periods.
- Codes that bundle multiple echo services under a single code have been introduced. Examples include a single CPT for bundling an echo with both a Doppler and color flow and a stress echo CPT that bundles both the stress test and stress echo.
As the examples above demonstrate, the magnitude of this year’s cardiology billing changes is more significant that has been seen in recent years. Without proper education, cardiology billing training, software upgrades and billing resources cardiology practices may see marked reductions in collections and increases in AR.
Staffing
Based on the experience of Cardiology Billing Partners there are four key elements to creating a world-class billing staff:
Recruit, train and retain the best billing staff:
The leading billing organizations recruit best staff. A dedicated, specialized HR team evaluates applicants—applicants must pass a proprietary billing testing process assessing both skill and will. This process shouldn’t be different from the recruiting process of a Fortune 500 organization. The leading billing organizations train to develop desired quality. Junior staff members must pass demanding training programs—junior team members are developed into billers, capable of following the measured and monitored billing process. In addition, staff is trained throughout the year in latest payer rules, follow-up techniques and compliance guidelines. A dedicated Compliance Officer is responsible for all additional HIPAA and OIG training. Best staff is retained; weak staff released. The billing organizations staff is evaluated every year to assure proper development and progress. Evaluations are based on tangible, measurable targets and quality indicators. Best performers are properly rewarded and lowest 10% of performers are asked to leave. This should be done methodically in an effort to continuously improve the quality of billing staff.
Specialization of the billing team: The top billing organizations’ billing team is composed of dedicated specialists in demographic data entry, charge posting, follow up, and patient collections. Each position is designed to excel in its role and is properly supervised and incentivized. Provide the staff with solid analytics support; Besides providing the clients with continuous practice analytics focused on clients’ practice improvements (coding, contracting, profitability, marketing, etc) , the leading billing organizations’ Analytics Group should offer strong analytics support to the billing staff. The Analytics Group should trend and measure payers response times, rejection trends, payment rates ,etc in order to properly focus the billing staff. They should also measure various elements of the internal billing process for continuous improvements. Incentives for billing staff: All positions in billing process are monitored and incentivized to perform optimally for your account. The incentive system while highly motivating for the staff, falls within the parameters established by the OIG for an acceptable incentive system in a medical billing environment. The best performers should be rewarded accordingly.
Outsourcing
One of the key advantages of billing outsourcing is the clear alignment of incentives between the practice and the billing company. The billing company only gets paid when the practice gets paid while the practice’s staff gets paid irrespective of results. There is also an incentive for the billing company to perform better—the better it performs the more it collects for the practice and in turn the more it earns (and vice versa). This is not true for in-house staff whose wages are fixed irrespective of performance and quality of work. This issue, however, is often not fully understood or appreciated by many providers. These providers frequently say: “the staff works directly for me in my office-- they are more loyal and will do a better job and I can see what they are doing”. From our experience, this is simply not true. I recently spoke with a partner at a busy cardiology practice. While one of the billers was out sick, some paperwork was required and the supervisor went out looking for it. When the supervisor opened the missing biller’s desk, a stack of unfiled, old claims was also discovered. It turned out about $40,000 of them were past timely filling deadlines. They were lost. I repeat—the practice lost $40,000! When the biller returned from her leave, she was “sternly” reprimanded. Let me say it one more time—she was reprimanded. No: not fired, but reprimanded. Either way, the practice lost $40,000 in just this one instance alone. When I asked the doctor why a more severe action was not taken, he explained to me that "we already have staffing problems and did not want to alienate the billing staff any further.” The guilty biller was apparently moved to the front-desk role and is now responsible for gathering demographic information and money. I also asked how it was possible that the billing supervisor missed that $40,000. Did they not reconcile charges and payments and track charges, payments and write-offs? To this the doctor replied that “their system did not provide this level of reporting and no such reports were ever given to him”. Since, the practice was using a new release of a major billing software, I know this system has such capabilities—it is just that either (1) no one knows how to use the system—that’s bad or (2) they just don’t want to bother—that’s’ worse! Just imagine how much money is probably lost there annually. At Cardiology Billing Partners we deal with these issues methodically and comprehensively: All the charges, payments and write-offs are visible to you. We track everything so no charges (batches, days or places of service, etc) can be missed.
If we have your charges and do not submit them properly--- Cardiology Billing Partners will reimburse your practice for what you would have been paid by the payers based on your allowable. What this means is that you never suffer financially if we drop the ball. Try to have your billers reimburse you if they drop the ball. Cardiology Billing Partners also provide clients with access to our system so that they can see real time status of their account. We will give you client portal access to reports and dashboard functionality 24/7. At any time, you or your practice manager can go in and check status of claims, payments, patient balances, etc. No more excuses that “the system cannot do this”! We often hear from the physicians how hard and long they work for ever decreasing reimbursements. All this is true. However, too often we also see practices (through various reasons) hurt themselves financially—over and over again. No—your staff will not work harder for you just because you employ them; and no- the biller who lost you $40,000 will not do any better job collecting money and gathering information from patients. You will probably need to “sternly” reprimand them again. A high performing cardiology medical billing company with complete transparency and full alignment of incentives is the surest path to medical billing excellence and strong financial performance for your cardiology practice.
If you are not aware and prepared for the 2009 cardiology billing and coding changes you may be leaving a lot of money uncollected. The 2009 coding and billing changes are the most significant for cardiology that have been seen since the mid 1990s.
While the average physician will see slightly over a 1% increase in Medicare fees, Cardiologists will see a 2% reduction in fees. This is mainly the result of lower payments for office-based imaging. Cardiologist that have a higher than average use of imaging services will see decreases in their Medicare fees far in excess of 2%, while other cardiologists may be able to achieve an increase in Medicare fees.
Here are examples of some of the upcoming changes:
• All of the codes previously used to submit charges for implanted device follow-up have been deleted and replaced with new codes. Not only have the old codes been replaced, but they have been replaced with a more updated code set that provides codes for checks of devices with leads in 3 chambers, codes specific to a remote (internet) device check, codes for following ICM devices, codes for per procedural checks, etc.
• Global periods related to device follow-up now include global periods of 30 or 90 days. The new codes are now service specific (i.e., either an interrogation evaluation of a programming evaluation).
• Wearable cardiac telemetry devices (for instance Cardio net type service) now have specific codes. You no longer bill with an unlisted code. These new codes include the complication of global periods.
• Codes that bundle multiple echo services under a single code have been introduced. Examples include a single CPT for bundling an echo with both a Doppler and color flow and a stress echo CPT that bundles both the stress test and stress echo.
As the examples above demonstrate, the magnitudes of this year’s cardiology billing changes are more significant that has been seen in recent years. Without proper education, training, software upgrades and billing resources cardiology practices may see marked reductions in collections and increases in AR.
Importance of Cardiology Billing
Medical billing is a crucial health care service that supports physicians by submitting and collecting the payments from insurance companies and patients. One needs to be an expert to ensure that the bills are collected fully and in a timely fashion. It is quite common for over 20% of a practice's potential revenue to remain unclaimed because of improper coding and weak collection strategies. Outsourcing medical billing is growing in popularity as an approach for addressing this tremendous loss of practice income. The range of outsourcing options runs from extremely large organizations to individual freelancers who work from home to provide medical billing services.
Medical billing is a highly complex area and it requires experience-based knowledge and expertise to contend with insurance companies. When it comes to cardiovascular billing, the situation gets even more complex. Such complexity can be handled only by a company that is staffed with well trained cardiology billing professionals. The medical billing specialist must be familiar with the specific codes and rules that make up the world of cardiac billing. Cardiovascular coding and cardiac billing cannot be done by everyone, it is a highly specialized field and it is not possible to be successful in collecting the bills fully from the insurance companies without the proper skills and training.
As the cost of providing cardiology related healthcare services continues to rise, medical institutions and cardiology practices cannot afford to leave revenue uncollected by billing companies or freelancers that are not knowledgeable in cardio billing. It is also important to keep in mind some companies may promote themselves as large cardiac billing service providers but in reality they sub-contract the cardiovascular billing to freelancers who work from home. Hiring such companies will lead to lost revenue because of the lack of proper process, controls, and training.
One of the major drawbacks of hiring a company that does not specialize in cardiology billing is their lack of familiarity with the procedures and the terminologies used. Even if the medical billing company serves one or two cardiologists, they will lack the depth and breadth of expertise required for successful cardiology billing. Moreover if the hired company does not specialize in cardiovascular billing, then they will not have the expertise to effectively appeal denied claims or answer questions raised by the insurance companies. A company that does not encompass a wide range of cardiology billing experience will find it difficult to track underpayments since multiple procedure rules, nuclear camera rules and cardiology procedures have significantly more complicated contractual adjustment rules than a typical family doctor or internist's claims. In addition, the billing software and system design of a generalist billing company will often be insufficient for the more complicated requirements of reporting and insurance follow-up required in cardiology billing.
These billing complications extend to the patient collections arena as well. The patient collection process for specialists like cardiologists is more complicated because of the large patient balances often owed, the complexity of the procedures/EOBs that must be explained to patients that do not understand their bills and the typically older population cardiologists serve. A medical billing service with expertise in cardiology billing knows how to deal with these situations. Billing services without such experience will increase the risk of both lower patient collections and upset patients confused about their bill.
To avoid all these billing related pitfalls cardiologists need to utilize specialized cardiology billing services. It is not advisable for an internist to perform cardiac surgery, similarly someone without training in cardiovascular coding and cardiology billing is not qualified to offer reliable billing services for cardiovascular practices.
2009 Challenges in Cardiology Billing
If you are not aware and prepared for the 2009 cardiology billing and coding changes you may be leaving a lot of money uncollected. Not since the mid 90’s have cardiology seen such significant coding and billing changes as have been put in place in 2009. Across the board the average Medicare fee increased just 1.1 percent. Cardiology in general fared worse than average, experiencing an average decrease of 2% due primarily to decreases in payments for in-office imaging. Keep in mind the 2% reduction is an average number. Some practices will be well above this (especially heavy users of echo services) and others will actually see fee increases.
Here are examples of some of the upcoming changes:
- Sweeping changes in the codes for following up on implanted devices (sweeping as in all of the old codes are gone and the new ones have significant differences). The new codes include such things as specific codes or internet (remote) device checks, codes for devices with leads in 3 chambers, ICM device follow-up codes, and codes for per procedural checks.
- 30 and 90 day global periods are now in place for follow-up for some devices. Also, the new codes are specific to either an interrogation evaluation or a programming evaluation. The codes are no longer dependent on whether reprogramming occurred.
- Wearable cardiac telemetry devices (for instance Cardio net type service) now have specific codes. You no longer bill with an unlisted code. These new codes include the complication of global periods.
- Codes that bundle multiple echo services under a single code have been introduced. Examples include a single CPT for bundling an echo with both a Doppler and color flow and a stress echo CPT that bundles both the stress test and stress echo.
As the examples above demonstrate, the magnitude of this year’s cardiology billing changes is more significant that has been seen in recent years. Without proper education, cardiology billing training, software upgrades and billing resources cardiology practices may see marked reductions in collections and increases in AR.
Staffing
Based on the experience of Cardiology Billing Partners there are four key elements to creating a world-class billing staff:
Recruit, train and retain the best billing staff:
The leading billing organizations recruit best staff. A dedicated, specialized HR team evaluates applicants—applicants must pass a proprietary billing testing process assessing both skill and will. This process shouldn’t be different from the recruiting process of a Fortune 500 organization. The leading billing organizations train to develop desired quality. Junior staff members must pass demanding training programs—junior team members are developed into billers, capable of following the measured and monitored billing process. In addition, staff is trained throughout the year in latest payer rules, follow-up techniques and compliance guidelines. A dedicated Compliance Officer is responsible for all additional HIPAA and OIG training. Best staff is retained; weak staff released. The billing organizations staff is evaluated every year to assure proper development and progress. Evaluations are based on tangible, measurable targets and quality indicators. Best performers are properly rewarded and lowest 10% of performers are asked to leave. This should be done methodically in an effort to continuously improve the quality of billing staff.
Specialization of the billing team: The top billing organizations’ billing team is composed of dedicated specialists in demographic data entry, charge posting, follow up, and patient collections. Each position is designed to excel in its role and is properly supervised and incentivized. Provide the staff with solid analytics support; Besides providing the clients with continuous practice analytics focused on clients’ practice improvements (coding, contracting, profitability, marketing, etc) , the leading billing organizations’ Analytics Group should offer strong analytics support to the billing staff. The Analytics Group should trend and measure payers response times, rejection trends, payment rates ,etc in order to properly focus the billing staff. They should also measure various elements of the internal billing process for continuous improvements. Incentives for billing staff: All positions in billing process are monitored and incentivized to perform optimally for your account. The incentive system while highly motivating for the staff, falls within the parameters established by the OIG for an acceptable incentive system in a medical billing environment. The best performers should be rewarded accordingly.
Outsourcing
One of the key advantages of billing outsourcing is the clear alignment of incentives between the practice and the billing company. The billing company only gets paid when the practice gets paid while the practice’s staff gets paid irrespective of results. There is also an incentive for the billing company to perform better—the better it performs the more it collects for the practice and in turn the more it earns (and vice versa). This is not true for in-house staff whose wages are fixed irrespective of performance and quality of work. This issue, however, is often not fully understood or appreciated by many providers. These providers frequently say: “the staff works directly for me in my office-- they are more loyal and will do a better job and I can see what they are doing”. From our experience, this is simply not true. I recently spoke with a partner at a busy cardiology practice. While one of the billers was out sick, some paperwork was required and the supervisor went out looking for it. When the supervisor opened the missing biller’s desk, a stack of unfiled, old claims was also discovered. It turned out about $40,000 of them were past timely filling deadlines. They were lost. I repeat—the practice lost $40,000! When the biller returned from her leave, she was “sternly” reprimanded. Let me say it one more time—she was reprimanded. No: not fired, but reprimanded. Either way, the practice lost $40,000 in just this one instance alone. When I asked the doctor why a more severe action was not taken, he explained to me that "we already have staffing problems and did not want to alienate the billing staff any further.” The guilty biller was apparently moved to the front-desk role and is now responsible for gathering demographic information and money. I also asked how it was possible that the billing supervisor missed that $40,000. Did they not reconcile charges and payments and track charges, payments and write-offs? To this the doctor replied that “their system did not provide this level of reporting and no such reports were ever given to him”. Since, the practice was using a new release of a major billing software, I know this system has such capabilities—it is just that either (1) no one knows how to use the system—that’s bad or (2) they just don’t want to bother—that’s’ worse! Just imagine how much money is probably lost there annually. At Cardiology Billing Partners we deal with these issues methodically and comprehensively: All the charges, payments and write-offs are visible to you. We track everything so no charges (batches, days or places of service, etc) can be missed.
If we have your charges and do not submit them properly--- Cardiology Billing Partners will reimburse your practice for what you would have been paid by the payers based on your allowable. What this means is that you never suffer financially if we drop the ball. Try to have your billers reimburse you if they drop the ball. Cardiology Billing Partners also provide clients with access to our system so that they can see real time status of their account. We will give you client portal access to reports and dashboard functionality 24/7. At any time, you or your practice manager can go in and check status of claims, payments, patient balances, etc. No more excuses that “the system cannot do this”! We often hear from the physicians how hard and long they work for ever decreasing reimbursements. All this is true. However, too often we also see practices (through various reasons) hurt themselves financially—over and over again. No—your staff will not work harder for you just because you employ them; and no- the biller who lost you $40,000 will not do any better job collecting money and gathering information from patients. You will probably need to “sternly” reprimand them again. A high performing cardiology medical billing company with complete transparency and full alignment of incentives is the surest path to medical billing excellence and strong financial performance for your cardiology practice.
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