AMA letter to CMS: Repeal ICD-10

Written by Jill Raykovicz

On Wednesday, the American Medical Association wrote a letter to the US Department of Health and Human Services calling for a repeal of the ICD-10 implementation, slated to be required by all covered entities October 1st, 2014.  AMA Executive Vice President and CEO, Dr. James L. Madara, reasoned ICD-10  “is not expected to improve the care physicians provide their patients and, in fact, could disrupt efforts to transition to new delivery models.”

Financial Burdens and Vendor Readiness

Dr. Madara voiced particular concern for smaller sized practices, where some estimates of the ICD-10 price tag could reach over $225,000, which, he writes, merely compounds other financial hardships such as costs to comply with Stage 2 Meaningful Use, overcoming any impending ePrescribe and PQRS penalties, as well as mitigating the 2 percent across-the-board sequestration cuts now pushed into 2023.

The letter released the results of a report by Nachimson Advisors, which revealed fewer than half (47 percent) of physicians say their practice management system vendor plans on delivering an ICD-10 software upgrade. Of those who are expecting an upgrade, 26 percent expect to receive it before April, 24 percent before July, 13 percent before October, and 1 percent after the October 1st deadline.  These timelines, the AMA argues, is insufficient to perform the necessary testing to ensure the software is working as intended.

Dr Madara also implored Medicare to conduct true end-to-end testing with at least 100 different physician practices of varying size and specialties.  Dr. Madara writes, “We believe end-to-end testing is essential for ensuring the health industry will not suffer massive disruptions in claims and payment processing and ultimately risk physicians’ ability to care for their patients.”

Advance Payment
 Options

Dr. Madara also appeals for an “Advance Payment” policy for the more serious cases that would jeapordize a provider’s ability to treat Medicare patients due to non-payment of services. This would apply to those services that have been submitted but not yet paid for date of service after October 1st, 2014, where the provider has already tried unsuccessfully to recoup payment from their contractor but is still weeks or months away from receiving reimbursement.  Dr. Madara reminds CMS a similar policy went into effect after the implementation of the National Provider Identifier (NPI) in 2008, and proposed the following parameters where advance payment would be afforded to providers:

1. When a physician has submitted claims but is having problems getting the claim paid to reach the contractor due to problems on the contractor’s end
2. When a physician has not been paid for at least 90 days
3. When they attest that at least 25 percent of their patients are Medicare and;
4. When they attest that at least 25 percent of their reimbursements are from Medicare.

Two-Year Implementation Grace Period

To battle the learning curve physicians and coders will experience as they gain a better understanding of the specificity required for ICD-10, Dr Madara proposes a two-year “implementation period” during which Medicare will not be allowed to deny payment based on the specificity of the ICD-10 code, and provide feedback to the physician on any coding concerns.  Medicare would also agree not to recoup payment due to lack of ICD-10 specificity during this grace period.

Conclusion

While the AMA confirms their commitment to the successful transtion to new payment and delivery models, and the adoption of technology to promote care coordination,  the letter concludes that  ICD-10 is “unlikely to improve the care physician provide to their patients and takes valuable resources away from implementing delivery reforms and health information technology”.

42,000 Impacted by Insurance Hard Drive Breach

A Wisconsin health insurance group has notified nearly 42,000 of its members that their protected health information may have been compromised following a HIPAA privacy breach.

Back in December, Unity Health Plans Insurance Corporation, which serves some 140,000 members, discovered a unencrypted portable computer hard drive containing health records of 41,437 individuals was missing from the University of Wisconsin-Madison School of Pharmacy. Officials say the school had this information as part of a benefits program evaluation.

Member names, dates of birth, name of prescription drugs and dates of service were contained on the device.

“(We’re) reviewing all our policies and trying to reeducate employees,” Jennifer Woomer Dinehart, spokesperson for Unity Health, told Healthcare IT News. Woomer Dinehart would not confirm or clarify what the company-wide encryption policy was.

“We are sorry this happened and want to provide pertinent information concerning the occurrence along with the steps we are taking to minimize any potential impact,” read a Jan. 30 company notice.

To date, out of the more than 80,000 HIPAA breach cases OCR has received since 2003, only 17 of them have resulted in fines thus far.

Just this past December, the five-hospital Riverside Health System in southeast Virginia announced that the PHI of nearly 1,000 patients had been compromised in a privacy breach that continued for four years. From September 2009 through October 2013, a former Riverside employee inappropriately accessed the Social Security numbers and electronic medical records of 919 patients. The breach wasn’t discovered until Nov. 1 following a random company audit.

 

Originating Source

Skype With Patients? HIPAA Says “No Go”

Oklahoma medical board sanction against Thomas Trow, MD, sparked concern over the practices of telemedicine and telepsychiatry. Using Skype, Trow conducted online video appointments and prescribed controlled substances to a patient who ultimately succumbed to an overdose. Trow never saw the patient in person before prescribing the drugs. As a result, the Oklahoma medical board published a ruling on January 16 of this year, stating that telemedicine, “Technology must be HIPAA compliant.”

With growing excitement, doctors and patients are “seeing” each other online through a range of video chat technology platforms. In fact, healthcare innovation like telemedicine is vital to the changing landscape of patient demands and government-driven insurance. For many, the Oklahoma telemedicine ruling brings welcome clarification and an opportunity to educate providers about this new way of practicing HIPAA-compliant telemedicine.

“The last thing the U.S. healthcare system needs is to abandon the idea of telemedicine,” said Daniel Gilbert, president and CEO of CloudVisit Telemedicine. “The technology has tremendously positive implications for providers and patients. To lose out because of one platform — a platform that was never designed as a medical tool — would be real detriment.”

Since the Oklahoma ruling does not specifically cite any brand names, many physicians are left wondering, “Is Skype HIPAA compliant?” Skype’s privacy policy simply states that they, “will take appropriate organizational and technical measures to protect the personal data…” and owner, Microsoft Corp.’s Business Associate Agreement (BAA) explicitly omits Skype. To better understand Skype’s security, one must turn to the Health Insurance Portability and Accountability Act (HIPAA).

  • Telemedicine is a HIPAA-compliant method for patient appointments
  • Online video appointments must be conducted via a HIPAA-compliant telemedicine platform
  • Business Associate Agreement (BAA) must exist between the healthcare provider and the company responsible for the telemedicine technology
  • The BAA must guarantee the HIPAA compliance of all measures for security practices and data encryption
  • Providers must obtain informed patient consent prior to conducting online video appointments
  • In absence of a BAA and informed consent, Skype is not HIPAA compliant

“It’s important to keep in mind that Microsoft never intended Skype to be a medical tool,” reminds Gilbert. “Beyond significant HIPAA issues, Skype has many operational shortcomings. CloudVisit provides tools for scheduling and billing, plus treatment notes and more. Skype has none of these features.”

In fact, a search of the word “telemedicine” on the Skype website comes up empty. They do not claim to be HIPAA compliant, nor do they position themselves as a resource for the medical community.

As stated, healthcare practices and patients have a lot to gain from online video appointments. The right technology can be highly effective and appropriate for follow-up care, routine appointments, and mental health consultations once a provider-patient relationship is established in person.

CloudVisit Telemedicine provides a HIPAA-compliant telemedicine and telepsychiatry platform for scheduling, conducting, tracking, and billing online video appointments with patients. CloudVisit enters into a BAA with every client.

 

Originating Source

This 5-Minute Video Could Save Your Practice

Almost every business uses a multi-function copy machine that copies, scans, prints and possibly faxes information. What most people don’t realize is that many of these machines have hard drives that store all information that the machine has access to. Think of these machines as computers that store a digital record of every copy it makes, every document it scans and every page it prints.

Copying patient information

If your organization copies insurance explanation of benefits (EOBs), patient insurance cards or uses a multi-function printer to print out letters to patients, all that information could be sitting on the hard drive of your copier. If this information is not properly destroyed before you return the machine to a leasing company, recycle the machine, sell the machine or throw the machine out; all that patient information might cause a HIPAA data breach.

Watch this video!

The below video from CBS news gives valuable information about the risks of copy machines.

Note: Affinity Health Plan who is featured in the video, received a $1,215,780 HIPAA fine (that’s right… $1.2 MILLION) because of one copy machine that contained 344,579 records with protected health information (PHI)

[youtube id=”TCKr5WgVVN8″ width=”600″ height=”350″]

ICD-10 – Not Just A Coder’s Problem

by Jill Raykovicz

The deadline to transition ICD-10 for all covered entities is October 1, 2014.   If that seems like a long way off, it isn’t.   In terms of actual work days[1], this timeframe is compressed to six months for medical and other healthcare practices to train staff, communicate with vendors, test software systems and claim files, and evaluate current processes to determine in what areas ICD-10 will affect day-to-day office functions.

IMPACT ON REIMBURSEMENT

If this sounds like a problem reserved for coders and billing staff, it isn’t.   CMS’  ICD-10 Implementation Guide for Physician Practices advises,  “Consider getting a line of credit to cover cash flow disruptions due to changing reimbursement models, delays in claims processing and re-processing, staff learning curve and long-term effects of the ICD-10 transition”[2]

Although  CPT and HCPC based reimbursements will not change with the ICD-10 transition, indirectly, fee-for-service payments may have a potential to be adversely affected for the following reasons:

  • Denials will increase because of  incomplete or inaccurate translation of payment rules in payer systems as they attempt to translate these rules from ICD-9 to ICD-10
  • Payments will be delayed because of challenges in claim processing in the ICD-10 environment.

Increased detail contained in ICD-10-CM means that the documentation required will change dramatically.   The level of severity, comorbidities, complications, sequalae, manifestations, and causes that characterize the patient’s condition increases within the ICD-10 coding guidelines.

 

PLANNING IS EVERYTHING

ICD-10 Coordination Manager

Every office should have an ICD-10 Coordination Manager. Depending on the size of the practice, this could be one person or a committee of persons responsible for communication and coordination with staff, providers, and vendors on key dates and project timelines for an ICD-10 pre and post go-live.

The Coordination Manager will also:

  • Coordinate training schedules and verify staff has attended and completed.
  • Set an ICD-10 project budget in terms of training and software upgrade  costs, coding books and guides, re-printing of encounter or referral forms with the new codes, if necessary, and other costs associated with ICD-10.
  • Determine if re-training is necessary, as we get closer to the October 2014 timeframe.  

He or she (or they) should ensure accurate coding decisions are being made, clinical documentation supports the new ICD-10 specificity requirements, and associated lags in productivity are identified and communicated.

Training

Speaking of training, although most ICD-10 literature advises staff and providers receive training no more than six to nine months from implementation, it is imperative to reserve slots now before classes fill up, or before less than desirable dates and times are the only ones left for either on-site training or off-site seminar.  Don’t wait to contact professional associations around the April 2014 timeframe to find out the on-site ICD-10 trainer’s only availability is the same week Suzie in the business office goes out for surgery.  Or, the only off-site workshop with any seats available is the week before Jane, your charge entry clerk, returns from maternity leave.  

Resources

CMS, the American Academy of Professional Coders (AAPC)American InformationManagement Association (AHIMA) and Workgroup for Electronic Data Interchange(WEDI) all have information on ICD-10 training and factors to success.

WEDI and CMS have partnered in taking a proactive approach to answer questions and concerns regarding the ICD-10 transition.  Organizations can submit questions, free of charge, to an online database.

IN CONCLUSIONExpect no more delays or movement of the October 1st, 2014 deadline.  Ready or not, here ICD-10 comes. Through planning, resource management, and effective leadership, medical and other healthcare practices can mitigate disruptions in cash flow as a result of ICD-10.


[1] Based on regular Monday through Friday office hours

[2] ICD Implementation Guide for Small and Medium Practices, p. 31

Physician Practice Consultants is led by Jill Raykovicz, MHA, CMPE, CPC.  Jill has over 15 years’ experience in physician practice management.  She has a strong passion for leveraging this experience and expertise within the private-practice setting, in order to assist independent practices struggling to keep up with changes in healthcare reform, pay-for-performance quality measures, and shrinking reimbursement from third party payers.

Jill holds a Master of Health Administration from Cornell University, is a board-certified medical practice executive (CMPE) through the American College of Medical Practice Executives, and is a Certified Professional Coder (CPC) with the American Association of Professional Coders.

She is also a member of the National Society of Certified Healthcare Business Consultants and the North Carolina Healthcare Information and Communication Alliance ICD-10 Taskforce.

Jill may be reached at jill@physician-practice-consultants.com

What is Reasonable and Appropriate for Your Specific Environment

These days we deal with resistance and denial towards HIPAA compliance. There are many reasons given for incomplete or ineffective compliance programs. We have heard everything from long rambling rants against the government, claims of not applicable to me and plenty of “we don’t have the _____” (fill in: time, money, resources) to explain away the compliance gaps.

There is, however, one case that concerns me when we find it. A practice or business is given a standard list of HIPAA Security implementation recommendations. The problem is that the list of recommendations doesn’t always include a review of what is reasonable and appropriate for the specific environment. The result is a group frozen by fear, sticker shock or worse paying for services and equipment that may be overkill for them. The Security Rule explains in the General Rules section just what should be considered in determining what is reasonable and appropriate for a specific environment (emphasis added):

HHS recognizes that covered entities range from the smallest provider to the largest, multi-state health plan. Therefore the Security Rule is flexible and scalable to allow covered entities to analyze their own needs and implement solutions appropriate for their specific environments. What is appropriate for a particular covered entity will depend on the nature of the covered entity’s business, as well as the covered entity’s size and resources.

Therefore, when a covered entity is deciding which security measures to use, the Rule does not dictate those measures but requires the covered entity to consider:

Its size, complexity, and capabilities,

Its technical, hardware, and software infrastructure,

The costs of security measures, and

The likelihood and possible impact of potential risks to e-PHI.

No, this doesn’t mean you can decide you are so small and the rules are too complex to follow them at all. That is definitely not what reasonable and appropriate means in this context. What it does mean, though, is that you can determine how to implement the standards, both required and addressable, but apply these considerations to your implementation plans.

Our approach is to always define the environment before defining the plan. The Security Risk Analysis is first in the list of requirements for a reason. But, keep in mind, that even the tasks performed in the Risk Analysis should be confirmed as reasonable and appropriate for your specific environment.

 

Reposted with permission from: http://smallproviderhipaa.com/2013/10/31/what-is-reasonable-and-appropriate-for-your-specific-environment/

Worker’s Reluctant to Follow Company BYOD Policy

Even at companies with BYOD (bring-your-own-device) policies, users may still be reluctant to officially register their tablets and smartphones with IT, instead preferring to covertly access the network. That’s according to a new study that shows employees are concerned about losing their personal data if they officially register their devices with the IT organization at their company. To ensure compliance with policies, managed services providers (MSPs) may need to win over small and mid-sized businesses (SMBs) employees with promises to protect personal data.

Aruba Networks, Inc. (ARUN) conducted the survey of more than 3,000 employees around the world. American respondents, specifically, fear the loss of personal data more than other regions of the world, the study revealed. Around 66 percent of American respondents claimed that they fear the loss of data, compared to the 45 percent of Europeans and 40 of Middle Easterners who felt the same.

More than 50 percent of Americans said their IT department takes no steps to ensure the security of corporate files and applications on their personal devices, a concern that has forced many employees to keep personal devices away from IT departments. Seventeen percent of Americans have not told their employers that they use a personal device for work. If you think that’s frightening, keep reading.

Eleven percent of American respondents said they would not report a compromised device, while 36 percent said they would not report leaked data immediately.

According to the survey, these numbers come from a distrust of IT departments and employee fear about what IT may do with personal data. Forty-five percent of respondents in the United States worry about their IT department’s access to personal data.

Should MSPs include policies and guarantees to customers’ employees on personal data?

There need to be incentives from the company to persuade employees to follow BYOD policy.  Furthermore, there must be a culture of transparency and trust from IT to help calm the fears workers have.

Our Mobile Device Management (MDM) solutions allow our technicians and engineers the ability to monitor and manage the mobile device but they do not have access to personal items such as text messages or pictures.  If there is ever a question of what we can or can not do, we give the client a complete tour of our MDM platform.

The importance of a highly secure IT environment coupled with the lack of adherence of workers to BYOD policies gives rise to major concerns.  Companies of all sizes need to rethink their policies and procedures regarding BYOD.  Also, ensure the MSP or IT provider is trustworthy and operates in complete transparency.  The goal is to protect your company, your IT environment, your customers and your employees.

Companies, especially small businesses, that ignore BYOD are playing Russian roulette.  Everyday workers are using secure business networks to do things on their mobile devices which are highly unsecured and dangerous to the IT environment.  For some verticals, such as healthcare, these oversights can led to a breach and bring disastrous implications.

Want to have a discussion about protecting your business and your employees?  Give us a call find out how we can help.

How To Select The Best Printer For Your Needs

There are a couple of things you need to first understand before you purchase a printer. They include;

1. LaserJet or Inkjet.
Both LaserJet and Inkjet printers have advantages and disadvantages. 

Inkjet printers are cheaper to buy than LaserJet printers. They also have very good quality print outs. However, the cost of maintaining an Inkjet printer is very high. Also, Inkjet printers make a lot of noise while printing and are slower than LaserJet printers.

LaserJet printers are expensive when buying but very cheap to maintain. Their print quality is very high and they make less noise when printing. They print faster than Inkjet printers.

2. All-In-One or Print-only.
The next thing you need to consider is whether you just want a print-only device or you need to scan copy fax and print. 

Print-only printers are cheaper than All-In-One printers. However, they have limited functionality.

On the other hand, All-In-One printers have scanners, copiers and printers all put in one device. They are a little bit more expensive but very handy especially in an office setting. All-In-One printers also save space as they contain three different devices in one.

Some All-In-One printers have fax. When getting an All-In-One, always confirm if it has fax as not all of them have fax. In most cases All-In-Ones that have fax are more expensive. 

3. Print Or Scan Quality.
Various aspects of print and scan qualities can be compared between different models. Print resolution is usually measured in dots per inch (DPI). The higher the number of dots per inch the better the printer.

Inexpensive inkjet models usually generate black-only prints at least as high as 600×600 DPI. Color models, meanwhile usually start as high as 4800×1200. Laser jets, meanwhile, typically produce 1200×1200 DPI or better black-only prints and 1200×600 or better color prints.

Scan quality is measured using both bit-rate and DPI measurements. If scanning is an important feature, seek an all-in-one device that offers optical scan resolutions of at least 600×1200 DPI and at least a 24-bit scan rate. Again, higher numbers are better (a scanner that boasts 36- or 48-bit technology will produce even higher-quality scans). Be sure to consider the differences between an inline scanner, in which 8.5-inch x 11-inch pages are easily scanned by passing them through a sheet feeder, and a flat-bed scanner, in which odd-size documents can be easily scanned just by placing them on the glass. In environments where multiple-page documents will frequently be scanned, ensure you select a model that boasts an automatic feed tray.

4. Network Capabilities.
The days where parallel cables where used to connect printers to computers are long gone. In fact, most laptops nowadays do not even have parallel ports. Most printers nowadays are connected to computers via USB cables.

Many printers now boast integrated wireless LAN connectivity. Other models feature embedded network interface cards, making it possible to connect printers to a local area network via a standard wired Ethernet cable, and thereby usable by multiple PCs simultaneously. Still others feature integrated Bluetooth support, which makes it possible for laptop users (among others) with Bluetooth functionality to print wirelessly without the requirement that a local area network even be present. 

When reviewing a printer or multifunction device purchase, be sure to consider your organization’s needs. If multiple users will need to access the printer or all-in-one’s scanning functions, network-equipped models can eliminate the need to purchase multiple units or configure a single PC to host print services for other systems. If many users access the local area network wirelessly, be sure to consider a printer model that also includes WLAN connectivity.

Article Source: http://www.articlebiz.com/article/1051611508-1-how-to-select-the-best-printer-for-your-needs/

Go The Extra Mile

If you want a quick way to boost your profits, you need to make sure you are going the extra mile to look after your best customers, before someone else does. 

Think hard about your biggest clients or customers. Can you think of something you did that they would say shows you have over-delivered for them? Not just things they would expect as standard, but really going the extra mile? Have you ever sent them your product and given them free samples of something else? Have you supported them in a charity venture they were undertaking? Have you helped them get through a crisis in their business just because you could rather than because you had to? Or have you phoned and taken them for lunch just to talk about how you can help them? 

If the answer to those questions is no, start thinking about how you can differentiate your business and what you can do to show how important those customers are to you. People often go the extra mile when they are trying to win new business, but often forget that retaining customers is more important than winning new ones. 

Don’t mistake these things for the standard “corporate entertaining” stuff. Everyone has been invited to work dos, races, parties and so on – and most people would never make a decision based on these things. I’m talking about personal, relevant and wow things that really show that you are going the extra mile for your customers – not that you have big budgets to spend! 

Keep these principles in mind: 

• Always under-promise and over-deliver, never the other way round;

• Never tell your customers no because that’s “the policy”;

• Have quicker response times to everything than your competitors;

• Think about the long term value of these customers, not what this might cost today;

• If they are in a hole, do whatever you can to get them out of it – even if you aren’t obliged to;

• Be personal in what you do – people do business with people, not faceless companies.

If you haven’t done these things, now is the time to get busy quickly. Customers need to be reminded constantly that you value them and are doing more than just giving them what they pay for. People hate being taken for granted and being treated as if you have the right to their money and you need to make an emotional connection with people to get them to stick with you and your business. 

So, take action NOW – this week, find a way to go the extra mile this week for at least one of your key customers, whenever or however you can.

Article Source:  http://www.articlebiz.com/article/1051611307-1-go-the-extra-mile/