Select Your Billing Company Carefully

Select Your Billing Company Carefully

Many practices enjoy the benefits of outsourcing their billing functions, which allows them to concentrate on providing patient care. Choose the wrong billing company, however, and you may end up with even greater distractions and financial frustration.

To be sure you choose a billing company that meets your needs efficiently—and does so compliantly—do some homework to answer the questions below:

What credentials/experience does the billing service have? For example, how long have they been in business and what is their reputation? Is the billing company registered or licensed by the state they are in, if their state requires such registration/licensing? Do they carry professional liability insurance? Do they provide a written contract for their services which spells out their and your responsibilities in this business relationship? How many clients do they have, and do they have any clients similar in size/patient mix as your own practice? Are you able to contact current and/or previous clients, to ask their opinions of the service’s performance?

Does the billing company have experience in your specialty? Does the billing company have experience and, if not, do they understand the unique factors that affect your specialty? Do they have an appreciation for the issues surrounding your coding, reimbursement, denials, and appeals? If not, do they have the resources to get up to speed, to your satisfaction, so that your revenue does not suffer?

What types of training does the staff have/receive? For example, does the billing service’s management hold a certification from a professional billing organization? Are billers/coders professionally certified? Does the service provide ongoing education and guidance for staff?

What resources does the biller provide for its staff? Are all guidebooks (CPT®, HCPCS, etc.) up-to-date? Does the service have a written compliance plan? If so (and you need to be sure it is so), can you review the plan?

Speaking of Compliance …

What is the procedure to protect the privacy of information? Does the service have a compliance officer? Does the billing company provide secure encrypted email communications consistent with Health Insurance Portability and Accountability Act (HIPAA) requirements? Does the billing company use home-based employees and, if so, what precautions are taken to ensure HIPAA compliance?

What are the company’s technical capabilities? Do they electronically process and submit claims, either directly to Medicare or through a clearinghouse? How often are claims submitted to the clearinghouse? What’s the process for third-party payers? Does the service use batch controls to minimize data entry and other errors? Will the service help your practice with forms, superbill design, office processes, etc.?

How does the biller handle claim changes? In other words, what’s their protocol for changing CPT® or ICD-9 codes if errors are discovered? What’s the protocol for missing information?

What type of financial reporting does the billing company provide? For instance, can the practice request ad-hoc reports? Can the service provide reports to determine physician compensation levels? If the practice is capitated, can the billing service report on capitated service utilization? Can your practice access billing data at its office? How robust are the month-end reports?

How is the billing company’s follow up? Specifically, how successful are they with appeals? What parameters do they use to determine if they will appeal a denial or underpayment? What kind of accounts receivable follow-up procedures does the billing service have? How often does the service follow up on payer accounts?

How much will it all cost? If the billing company’s fee is based on a percentage, is it a percentage of charges, or a percentage of receipts (the latter is better)? How are refunds handled? Are they netted out of receipts, so your practice is not paying the billing company for money returned to the payer? Does the billing service charge a start-up fee?

If the answers to any of the above questions are not to your satisfaction, keep looking until you find a billing service that meets expectations. Remember: Even though you are outsourcing, the practice is ultimately responsible for its own claims, and you need a billing company you can trust.

Experienced Staff Is Crucial

Even if the billing company is not coding for you, it’s a good idea for them to have at least one certified coder on staff. Appeals require the knowledge of a coder, and compliance also demands the increased knowledge that a certified coder can bring to the table. Even the billers need to know aspects of coding—although they do not need to be certified—to do an excellent job in billing for your practice. Key areas of education include rules and regulations, where to find the information for Medicare, Medicaid, your private payers, etc., modifiers, correct order of diagnoses, bundling and National Correct Coding Initiative (NCCI) edits, what separate procedures are, etc. You do not want a billing company that is just providing data entry.

Best Bets

My recommendation is to find a billing company with experience in your specialty, with a proven track record in compliantly optimizing practice revenue. I would not recommend entering into a billing company relationship without a written contract that very explicitly spells out both your, and their, responsibility.

Compliance is no longer an option. The Accountable Care Act mandates a compliance plan for all practices, with minimum requirements to be spelled out by the Office of Inspector General (OIG). A practice cannot afford to contract with a billing company that does not have a living, breathing, and operating compliance plan in place.

I also suggest checking out the billing company’s recommendations. Talk to both current and past clients, if possible. Find out what the benefits of working with the billing company are, and what you need to make the relationship function flawlessly. Clients should be able to confirm what the company has told you during the sales phase of your relationship.

Finally, do not expect to see your full income generated by the billing company for approximately four months. It takes about that long for them to get a full queue of your billing to the payers and a revenue stream to start flowing into the practice. Make sure you keep collecting on the accounts receivable that was in process when you contracted with the billing company to keep the bank account healthy during this four-month period.

HITECH-related HIPAA Changes Final

Dramatic modifications to the Health Insurance Portability and Accountability Act’s (HIPAA) Privacy, Security, Enforcement, and Breach Notification Rules that will impact your practice are finalized and begin to take effect next month.

The omnibus final rule, developed to help implement HITECH regulations in the American Recovery and Reinvestment Act and shore up electronic privacy rules in the 17-year-old act, includes changes to how providers and payers must protect personal health information (PHI) and the focus of enforcement from voluntary to punitive. The rule also makes business associates (BA) more accountable for breaches of PHI, with the risk of financial penalties.

The Centers for Medicare & Medicaid Services (CMS) maintains the changes provide the public with increased protection as penalties are increased for noncompliance based on the level of negligence with a maximum penalty of $1.5 million per violation. The changes also strengthen the HITECH breach notification requirements by clarifying when breaches of unsecured health information must be reported to HHS. These changes broaden who is responsible and extends consequences to more parties, including small practice, payers, and BAs like billing services or clearing houses.

CMS says the new rule expands individual rights. For example, patients can request a copy of their electronic medical records in electronic form. When individuals pay by cash they can instruct their provider not to share information about their treatment with their health plan. The omnibus rule sets new limits on how information is used and disclosed for marketing and fundraising purposes and prohibits the sale of an individuals’ health information without their permission.The rule also streamlines individuals’ ability to authorize the use of their health information for research purposes. The rule makes it easier for parents and others to give permission to share proof of a child’s immunization with a school and gives covered entities and BAs up to one year after the 180-day compliance date to modify contracts to comply with the rule, the health agency says.

1. The new rule increases liability for noncompliance for practices. Tiered penalties range from $100 to $50,000 per violation, depending on culpability. Under the new rule, HHS can impose monetary penalties without exhausting informal options.
2. The new rule imposes direct liability for BAs and subcontractors, a change that puts billing services and their clients more at risk because a practice is now liable for what its billing service does.
3. The rule introduces an objective test of whether PHI has been compromised and requires notification. The four elements are:
• Nature and extent of PHI in the incident
• Recipient of the PHI
• Acquisition or viewing status of PHI
• Mitigation of the risk after disclosure
• The new rule requires patient authorization for all communication of PHI for marketing purposes, closing a loophole that allowed health care organizations, drug companies, and others to use PHI for direct marketing to patients without permission.
• The new rule better defines what a BA is, clarifying how much interaction with PHI an entity can have before it becomes a BA, and establishing additional accountability for those entities.
• The rule loosens what can be used for fund-raising communications, allowing demographic information, dates of service, department, physician, outcome, and payer status for fund-raising and related BAs. Patient authorization is required.
• The rule makes it easier for your patients to authorize PHI to be used for more than one research effort, allowing a patient to designate PHI can be used for multiple and future research efforts at once.

Overall, the new rule clarifies the definition of a covered entity or BA, the responsibilities that each carry, and punishments associated with a lack of compliance. It doesn’t change the basics; an entity or BA must still have a plan, a designated compliance officer, education, analysis of gaps, and privacy notices for patients and their family members. Under the rule’s changes to definition of compliance, culpability, and correction, however, practices need to reassess efforts this year to avoid unexpected fines or punishment.

Certified EHR Technology

Certified EHR Technology

What is a certified EHR?

In order to capture and share patient data efficiently, providers need an EHR that stores data in a structured format. Structured data allows patient information to be easily retrieved and transferred, and it allows the provider to use the EHR in ways that can aid patient care.
 

CMS and the Office of the National Coordinator for Health Information Technology (ONC) have established standards and other criteria for structured data that EHRs must use in order to qualify for this incentive program.
 

To get an incentive payment, you must use an EHR that is certified specifically for the EHR Incentive Programs. Certified EHR technology gives assurance to purchasers and other users that an EHR system or module offers the necessary technological capability, functionality, and security to help them meet the meaningful use criteria. Certification also helps providers and patients be confident that the electronic health IT products and systems they use are secure, can maintain data confidentially, and can work with other systems to share information.
 

Please Note: EHRs certified or qualified for other Medicare incentive programs may not be certified for this program. Also, if you already own an EHR, it may not be certified for use in the EHR Incentive Programs.
 

To learn which EHR systems and modules are certified for the Medicare and Medicaid EHR Incentive Programs, please visit the Certified Health IT Product List (CHPL) on the ONC website: http://healthit.hhs.gov/chpl

Electronic Health Record (EHR) or Electronic Medical Record (EMR)? Sometimes people use the terms "Electronic Medical Record" or "EMR" when talking about Electronic Health Record (EHR) technology. Very often an Electronic Medical Record or EMR is just another way to describe an Electronic Health Record or EHR, and both providers and vendors sometimes use the terms interchangeably. For the purposes of the Medicare and Medicaid Incentive Programs, eligible professionals, eligible hospitals and critical access hospitals (CAHs) must use certified EHR technology.

What is the CMS EHR Certification ID?
During attestation, CMS requires each eligible professional, eligible hospital and critical access hospital to provide a CMS EHR Certification ID that identifies the certified EHR technology being used to demonstrate meaningful use. This unique CMS EHR Certification ID or Number can be obtained by entering your certified EHR technology product information at the Certified Health IT Product List (CHPL) on the ONC website: http://healthit.hhs.gov/chpl
 

NOTE: The ONC CHPL Product Number issued to your vendor for each certified technology is different than the CMS EHR Certification ID. Only a CMS EHR Certification ID obtained through the CHPL will be accepted at attestation

Eligible professionals, eligible hospitals and critical access hospitals can obtain a CMS EHR Certification ID by following these steps:

1.      Go to the ONC CHPL website:  http://healthit.hhs.gov/chpl

2.      Select your practice type by selecting the Ambulatory or Inpatient buttons.

3.      Search for EHR Products by browsing all products, searching by product name or searching by criteria met.

4.      Add product(s) to your cart to determine if your product(s) meet 100% of the CMS required criteria.

5.      Request a CMS EHR Certification ID for CMS attestation. The CMS EHR Certification ID contains 15 alphanumeric characters.

Definition of Meaningful use

Meaningful Use

What is meaningful use?

Electronic health records can provide many benefits for providers and their patients, but the benefits depend on how they're used. Meaningful use is the set of standards defined by the Centers for Medicare & Medicaid Services (CMS) Incentive Programs that governs the use of electronic health records and allows eligible providers and hospitals to earn incentive payments by meeting specific criteria. For details about the incentive programs, visit the CMS website.

The goal of meaningful use is to promote the spread of electronic health records to improve health care in the United States.

The benefits of the meaningful use of EHRs include:

• Complete and accurate information. With electronic health records, providers have the information they need to provide the best possible care. Providers will know more about their patients and their health history before they walk into the examination room.
• Better access to information. Electronic health records facilitate greater access to the information providers need to diagnose health problems earlier and improve the health outcomes of their patients. Electronic health records also allow information to be shared more easily among doctors' offices, hospitals, and across health systems, leading to better coordination of care.
• Patient empowerment. Electronic health records will help empower patients to take a more active role in their health and in the health of their families. Patients can receive electronic copies of their medical records and share their health information securely over the Internet with their families.

Background: Legislation and Regulations
The Health Information Technology for Economic and Clinical Health (HITECH) Act provides the Department of Health & Human Services (HHS) with the authority to establish programs to improve health care quality, safety, and efficiency through the promotion of health IT, including electronic health records and private and secure electronic health information exchange.

Background: Legislation and Regulations
The Health Information Technology for Economic and Clinical Health (HITECH) Act provides the Department of Health & Human Services (HHS) with the authority to establish programs to improve health care quality, safety, and efficiency through the promotion of health IT, including electronic health records and private and secure electronic health information exchange.

Under HITECH, eligible health care professionals and hospitals can qualify for Medicare and Medicaid incentive payments when they adopt certified EHR technology and use it to achieve specified objectives.

Four regulations have been released, two of which define the “meaningful use” objectives that providers must meet to qualify for the bonus payments, and two of which identify the technical capabilities required for certified EHR technology.

• Incentive Program for Electronic Health Records: Issued by CMS, these final rules define the minimum requirements that providers must meet through their use of certified EHR technology in order to qualify for the payments for Stages 1 and 2 of meaningful use.
• Standards and Certification Criteria for Electronic Health Records: Issued by the Office of the National Coordinator for Health Information Technology (ONC), these rules identify the standards and certification criteria for the certification of EHR technology, so eligible professionals and hospitals may be assured that the systems they adopt are capable of performing the required functions.

The U.S. Department of Health and Human Services recently announced the release of the final rules for Stage 2 of meaningful use and updated certification criteria and standards. Learn more about the final rules and read about meaningful use clinical quality measures.

Stages of Meaningful Use

 

 

In order to achieve meaningful use, eligible providers and hospitals must adopt certified EHR technology and use it to achieve specific objectives.

These meaningful use objectives and measures will evolve in three stages over the next five years:

The Stages involved in Implementing EHR and getting Meaningful Use Incentives: