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Tag Archives: Prepare

Making a checklist to prepare for the OPPS final rule

Making a checklist to prepare for the OPPS final rule

Editor’s note: Jugna Shah, MPH, president and founder of Nimitt Consulting, writes a bimonthly column for Briefings on APCs, commenting on the latest policies and regulations and analyzing their impact on providers.

 

The 2017 OPPS final rule will not be out for a couple of weeks, but that doesn’t mean providers can’t be thinking about what their action plan will be once the rule is released.

With only 60 days between the final rule’s release and the January 1 implementation date, providers will be ahead of the curve by spending time now and thinking about the processes they may need to review, change, or implement based on what CMS finalizes and the sort of financial impact the final rule is likely to have.

While I don’t know with 100% certainty what CMS will finalize, revise, delay, or back away from, I offer providers this list of what they should look at immediately upon the rule’s release.

 

Section 603

With Congress mandating payment changes for all non-grandfathered (those not billing under OPPS prior to November 2, 2015) off-campus, provider-based departments (PBD) starting January 2017, it was no surprise that CMS discussed this issue in the proposed rule. But it was a huge surprise to read CMS’ proposals, which, if finalized, would greatly impact otherwise protected grandfathered locations under Congress’ Section 603.

For example, CMS proposed that if an off-campus PBD moves, changes ownership, or expands its services beyond what it was providing as of November 2, 2015, as defined by APC-based clinical families, then its grandfathered status would be impacted. While this may sound relatively simple, the payment and operational impact would be a nightmare.

There is another aspect of Section 603 and CMS’ proposal to use the Medicare Physician Fee ­Schedule (MPFS) as the "applicable payment system" for ­Medicare Part B services provided at non-grandfathered locations or deemed "non-excepted." Specifically, there are many services for which the MPFS has no facility component for the facility costs associated with performing the procedure because they are only provided in hospital outpatient departments or ambulatory surgery centers. For these services, the industry has to wonder what CMS was thinking, as the agency cannot possibly expect to pay nothing for services that would continue to be rendered in off-campus PBDs.

CMS’ unexpected and hastily configured proposals create such large operational and financial problems that the industry is hoping the agency will simply retreat and delays the implementation of Section 603, or at a minimum revert to paying grandfathered facilities under the OPPS for all of their services, regardless of clinical service expansion, site relocation, or ownership changes. There is precedent for CMS to postpone implementation beyond statutory deadlines. If there were ever a situation where delay is advised, this is one.

Hopefully, providers sent in a surfeit of comments regarding these and other issues and outstanding questions related to the agency’s Section 603 implementation proposals. I hope CMS will acknowledge its proposals have administrative, operational, and financial gaps that are so large, it will be impossible to move forward by January. But even if CMS does choose to put off its proposals until proper payment mechanisms are developed, Congress was clear in its language requiring changes by January 1, 2017, so something is likely going to have to occur.

CMS’ proposals, if finalized, would have drastic long-term implications for all providers, including those who believe that their grandfathered status would protect them; the sad reality is that under CMS’ proposals, there will be massive operational and financial impact, so this is the first topic in the final rule that everyone should review.

 

Packaging proposals

Providers have gotten used to CMS expanding packaging in each OPPS rule, as the agency calls packaging an essential part of a prospective payment system. With CMS’ expansion of lab packaging from date of service to claim level this year, we should not be surprised if the agency finalizes its proposal of expanding the conditional packaging logic of CPT codes assigned to status indicators Q1 and Q2 to the claim level.

Claim-level packaging of these types of ancillary services will have a huge financial impact on providers submitting multiday claims, such as those for chemotherapy and radiation therapy services, despite the fact that multiday claims for these types of services are not required.

Currently, status indicators Q1 and Q2 are packaged into other OPPS services when provided on the same date of service, even when submitted on a claim that spans more than one day. If CMS finalizes its proposal, providers that continue submitting multiday claims when monthly or series claims are not required should not be surprised when they find themselves no longer receiving separate payment for many services.

This is the time for providers to assess whether they submit multiday claims for any services beyond the required repetitive services listed in the Medicare Claims Processing Manual, Chapter 1, section 50.2.2. While it is true the manual states that is is an option to bill nonrepetitive services on multiday claims, it did not have financial implications. At least, until this year, with the claim-based packaging of labs and proposal for claim-based packaging of Q1 and Q2 services. Providers should determine why they are billing multiday claims and what it would take to change their billing processes. If they elect not to move away from multiday claims, then assessing the financial impact that will occur is an important exercise to go through prior to January 1.

The other packaging proposal providers should look for in the final rule involves the use of modifier -L1 for reporting unrelated laboratory tests when they occur on a claim with other OPPS services. CMS proposes to delete the modifier for CY 2017 as it believes that the vast majority of labs should be packaged regardless of whether they are unrelated to other OPPS payable services.

This would have a big impact on providers who provide reference laboratory or nonpatient services, which the agency requires to be reported on the same claim as other OPPS services performed on the same date. Today, the use of the -L1 modifier allows providers to identify these services as separate and unrelated to the other OPPS services so that payment is received from the Clinical Laboratory Fee Schedule.

If CMS finalizes its proposal to eliminate modifier -L1, we can hope the agency will also update its instructions for reporting reference laboratory services so they can be separately paid even when provided on the same date of service or claim as other OPPS services. If CMS does not make a change, then providers can again expect to see a large financial impact. Both of these packaging proposals should be looked at immediately in the final rule.

 

Device-intensive procedures

The final set of proposals providers will want to review relates to the changes proposed for device-intensive procedures. This is a place where we hope to see CMS finalizing changes as proposed.

For example, CMS proposes to use the implantable device cost-to-charge ratio (CCR) to calculate pass-through device payments for hospitals that file cost reports designating that cost center, as this is a more accurate CCR for determining separate pass-through payment. Currently, only about two-thirds of hospitals use the implantable device CCR, which means the remaining one-third need to examine their cost reporting process.

Providers should determine whether they are in the group that reports the implantable cost center; if a provider is not reporting, it should find out why and begin making changes. This will have an impact on facilities’ ability to generate much better pass-through payment going forward, when applicable. It will also ensure future payment rates for device-intensive procedures reflect more accurate payment of the device.

Finally, it will be interesting to see whether CMS finalizes the addition of another 25 comprehensive APCs (C-APC) encompassing 1,844 additional status indicator T services; if it does, a financial impact analysis of these services will also be important, as this will be a large increase in C-APCs for a one-year span.

I plan to discuss these and other final rule changes in my next column, as well as in HCPro’s annual OPPS final rule webcast December 1 (see www.hcmarketplace.com for details), but in the meantime I hope the above checklist will be useful to providers now and in the first weeks of the rule’s release.

HCPro.com – Briefings on APCs

Prepare for JustCoding’s redesign by downloading quiz certificates, preregistering

The team at JustCoding is proud to announce a revamped and redesigned website launching soon. The new site will include great new features and make it easier than ever to browse our content, track your CEs, and more.

Before the new site launches, we ask all of our Basic and Platinum customers to print out their certificates for quizzes they’ve already taken. We will not be able to transfer quiz history to the new site. To get past CE certificates after the new site launches, you will have to retake the quizzes. Click here to access your current certificates.
 
Our new site will also require Free users to register to access the weekly free article, mini-poll, free quizzes, and other resources. Don’t worry—it’ll take less than a minute. Please click here and you’ll be all ready when the new site launches. If you are already a JustCoding Basic or Platinum subscriber, you don’t need to do anything—we’ll send you information when it’s time to access the new site!
 
New on JustCoding Platinum!      
2016 outlook in Special Reports and NewsHIM department focuses for next year
This report from HIM Briefings (formerly Medical Records Briefing) looks at trends that may emerge in 2016 and what your organization may want to focus on. 

HCPro.com – JustCoding News: Inpatient

Prepare for JustCoding?s redesign by downloading quiz certificates, preregistering

The team at JustCoding is proud to announce a revamped and redesigned website launching soon. The new site will include great new features and make it easier than ever to browse our content, track your CEs, and more.

Before the new site launches, we ask all of our Basic and Platinum customers to print out their certificates for quizzes they’ve already taken. We will not be able to transfer quiz history to the new site. To get past CE certificates after the new site launches, you will have to retake the quizzes. Click here to access your current certificates.
 
Our new site will also require Free users to register to access the weekly free article, mini-poll, free quizzes, and other resources. Don’t worry—it’ll take less than a minute. Please click here and you’ll be all ready when the new site launches. If you are already a JustCoding Basic or Platinum subscriber, you don’t need to do anything—we’ll send you information when it’s time to access the new site!
 
New on JustCoding Platinum!
ICD-10-CM quiz in Special Reports and News: Use this 10-question quiz to determine how well you understand ICD-10-CM coding for coding endocrine diseases.

HCPro.com – JustCoding News: Outpatient

How to Prepare For Your Medical Assistant Exam

Books, notes, past year questions and revision texts are scattered all over the place. This can only mean one thing; exams are around the corner and the jitters are creeping up faster than you expected. Medicine has never been an easy course, and even though this isn’t the whole big doctor or surgeon thing, preparing for a medical assistant exam is just as nerve wrecking. So, what do you do? Well, the smart thing to do would be to calm down and keep yourself down to earth while preparing for your exam.

You should start off by making sure that you are calm and free from butterflies in your stomach. Do some light exercise and deep breathing, then clear your mind and get a hold of your emotions. In order to study effectively, you need to rid of any negative pre-examination emotion such as anxiety and worry. If you still find yourself extremely anxious, then try going for a long walk or take a drive around the neighborhood. This should help put you at east for awhile.

Next, don’t study hard, study smart. Instead of reading straight out of your textbook for hours and hours trying to digest the information, try briefly going through it once then make your own notes and mind maps to help. During classes, pay attention to the lecturer instead of jotting down notes and doodles on the sidelines. Then, as soon as you get back, review what you’ve gone through in class and start making notes. This way, when it gets closer to your exam, instead of lugging around the huge textbooks and revision books, you could just use your notes. If it helps, make them into flashcards and carry them around in your pockets or bag. With this, you could always go through your notes while waiting for the bus or in a queue.

Read, revise, redo. The best way to make sure that you’re well prepared to gain your medical assistant certificate would be to go repeatedly go over your work, dividing your time between subjects or chapters. Once you’re done with each section, try doing a couple of questions as it would help strengthen your memory and show you how much you actually know. If you don’t have enough questions with you, use the internet and look it up on your search engine.

Aside from all that has been mentioned, in order to make sure that your mind is in perfect functioning order, you would need to keep your physical self in good condition too. Get sufficient rest and don’t ignore those eye bags. If you’re the kind of person who has adjusted to late nights and simply can’t change, make sure you get a continuous 6-8 hours of sleep a day and avoid burning the midnight oil the day before your examination. Also, drink plenty of water and eat your greens. You don’t want to be catching the flu anytime near your exam day.

In a nutshell, effective studying is easy as long as you put your mind to it. So kick off those jitters and hit the books because you’re going to be the one to ace the upcoming exam!

For more information about medical assistant duties and certified medical assistant exam, visit MedicalAssistantOpportunities.com.

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[Announcement] Helping Small Practices Prepare for the Quality Payment Program

The Quality Payment Program is proposed to implement the new, bipartisan law changing how Medicare pays clinicians, known as the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). On June 20, HHS announced $ 20 million to fund on-the-ground training and education for Medicare clinicians in individual or small group practices of 15 clinicians or fewer. These funds will help provide hands-on training tailored to small practices, especially those that practice in historically under-resourced areas including rural areas, health professional shortage areas, and medically underserved areas.

As required by MACRA, HHS will continue to award $ 20 million each year over the next five years, providing $ 100 million in total to help small practices successfully participate in the Quality Payment Program. In order to receive funding, organizations must demonstrate their ability to strategically provide customized training to clinicians. And, most importantly, these organizations will provide education and consultation about the Quality Payment Program at no cost to the clinician or their practice. Awardees will be announced by November 2016.

For More Information:

 

See the full text of this excerpted HHS press release (issued June 20).

The Medical Management Institute – MMI – Medical Coding News & MMI Updates