Wednesday, October 19, 2016
Elizabeth N. Pitman
Waller, Lansden Dortch & Davis, LLP
On October 15, 2016, the Department of Health and Human Services (HHS) released the final rule outlining its implementation of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) Quality Payment Program (QPP). The QPP applies to clinicians or groups with more than $30,000 in Medicare Part B allowed charges and more than 100 Medicare patients. Clinicians or groups under either threshold or who are participating in Medicare for the first time in 2017 are exempted.
The QPP rewards value and outcomes via two tracks: Merit-based Incentive Payment Systems (MIPS) or Advanced Alternative Payment Models (Advanced APMs).
MIPS consolidates several existing programs that will be retired. Under MIPS, clinician performance will be measured on a 100 point scale in one or more of the following performance categories:
• Quality (50 points) – replaces the Physician Quality Reporting System (PQRS)
• Clinical Practice Improvement Activities (15 points) – a new category
• Advanced Care Information (25 points) – replaces Meaningful Use
• Cost (10 points) (0 points required in 2017) – replaces the Value-Based modifier Clinicians scoring above a designated threshold may receive higher Medicare payments and those below the minimum threshold will experience a reduction in Medicare payments.
Clinicians qualifying for services delivered through an Advanced APM are exempt from MIPS, will avoid payment penalties and will receive increased Medicare payments. The final list of qualifying Advanced APMs will be published by January 1, 2017.
Transition Options for 2017
Depending on their level of participation in 2017, MIPS eligible clinicians will be subject to negative or positive payment adjustments beginning January 1, 2019. Clinicians have until March 31, 2018 to submit data collected. The possibilities for clinicians are as follows:
No MIPS or Advanced APM Participation
MIPS eligible clinicians who do not report any data for 2017 and do not participate in an Advanced APM will be subject to a negative 4% payment adjustment. Minimum MIPS Participation To avoid a negative payment adjustment, clinicians must report one of the following for at least a full 90-day period in 2017: (1) one measure in the quality category, (2) one activity in the improvement activities category, or (3) the required measures of the advancing care information category.
Greater MIPS Participation
Clinicians who chose to report more than the minimum data will be eligible for a positive payment adjustment. Clinicians who are exceptional performers in MIPS (ideally reporting data in all three categories for the entire year and achieving a score of 70 or higher) are eligible for an additional positive payment adjustment for the first six years of the program.
Advanced APM Participation
Qualified Providers (QPs) are Clinicians who receive 25% of Medicare payments or see 20% of Medicare patients through an Advanced APM. QPs are excluded from MIPS and qualify for a 5% bonus incentive payment in 2019. Clinicians participating in an Advanced APM must submit the quality data as required by the Advanced APM. The Final Rule offers the potential for additional Advanced APMs and services provided at certain CAHs, RHCs, and FQHCs may be included in determining the threshold under the patient count method.
Small and Rural Practices
Clinicians practicing in small (≤ 15 clinicians) or in rural shortage areas have a reduced reporting burden and will receive increased technical assistance from HHS. Clinicians or groups with a low Medicare volume (≤ $30,000 or 100 Medicare patients) are excluded from the MIPS payment adjustment. HHS is also examining financial risk sharing options to better support small and rural practices. Special rules for the medical home Advanced APM apply. In addition, HHS has committed $20 million annually for the next 5 years to provide training and assistance specific to small and rural clinicians.
For 2017 MACRA reporting, HHS has provided clinicians with greater flexibility in meeting the reporting requirements by lowering the minimum reporting threshold, reducing the number of measures and permitting a 90-day reporting period for 2017. HHS has also accelerated the time-line for assessing whether clinicians meet the Advanced Alternative Payment Model (Advance APM) prior to the end of the MIPS reporting period. HHS expects that this transitional period should give clinicians the opportunity to develop a plan for moving toward accountable care models or revising care delivery practices enabling clinicians to generate higher Medicare payments in future years.
• Executive Summary of the Final Rule
• Quality Payment Program Website
• Quality Payment Program Overview Fact Sheet
Thank you to Keith Maune, Belmont University College of Law, for his assistance in preparing this article.
By: Lori M. Quiller, APR
Medical Association of the State of Alabama
in photo: Marsha Raulerson, M.D.
Reading Gives You Wings
BREWTON — According to Dr. Seuss in I Can Read with My Eyes Shut!, “The more that you read, the more things you will know. The more you learn, the more places you’ll go.” That’s a philosophy Brewton pediatrician Marsha Raulerson can easily get behind.
For more than 30 years, Dr. Raulerson has celebrated her young patients and encouraged their sense of adventure through reading by providing them with new books during their visits to her clinic. What began as the STARS program, or Steps to Achieve Reading Success, has for the past 20 years been affiliated with the National Reach Out and Read Program. Ten years ago, Dr. Raulerson, working with Polly McClure, launched the Alabama Chapter, American Academy of Pediatrics’ Reach Out and Read Alabama, that gives young children a foundation for success by incorporating books into pediatric care and encouraging families to read aloud together.
“We’ve given out truckloads of books to our patients,” Dr. Raulerson said. “I give a book to every child for every visit, no matter what the age of the child. My community probably contributes about $10,000 a year so we can buy new books because every patient can have a new book.”
In fact, no child who visits Dr. Raulerson’s clinic leaves empty handed. The books she chooses for her patients are not only age appropriate, but also story appropriate to each patient’s particular situation. The majority of her patients have special needs, and each book is intended to give her patients hope.
“I was a reading specialist before I went to medical school, and I would give books to my patients when I was a resident at the University of Florida. I’ve been giving books away since 1978, so my whole career, really. My feeling is that if you can read, you can do anything. I tell my patients that I majored in English in college, not science or math. But, when I went to medical school and had to take biology and chemistry, I could never have done that without the ability to read. If you can read, you can do anything you want!”
Dr. Raulerson laughed when she first realized how long she had been practicing in Brewton, and how many patients had come through her clinic. She shook her head and smiled an easy smile when she admitted that it didn’t initially dawn on her just how many generations of patients she had treated. “I have grand-patients!” she laughed!
“I have a lot of families of three generations of patients, and I remember them all. All my patients are so special to me, and they’ve all received so many books from the clinic. Now, when they tell me that those books helped to create a special bond with their children and grandchildren, that’s heartwarming.”
Given her years of advocacy for children, it’s difficult to imagine the landscape of medicine in Alabama without Dr. Raulerson, but she in fact very nearly did not get accepted into medical school. A native of Jacksonville, Fla., she took her qualifying exams for her doctorate when she ultimately settled on medical school. While she said she felt she was always meant to be a medical doctor, one person sealed the deal for her. Her name was Robbie.
Dr. Raulerson taught school to help put her husband through medical school, and then her husband was drafted and sent to Vietnam. While there, the Raulersons decided to adopt a Vietnamese child. When her husband found the youngest female child in the nursery of an orphanage, he knew this was their child. She was only a few weeks old. The Catholic priest agreed to the adoption to the Baptist couple, and Dr. Raulerson flew to Tokyo to meet her daughter, Robbie.
When Dr. Raulerson got home with Robbie, she was 5 months old and weighed only 8 lbs., was malnourished and very ill. She knew exactly what to do to take care of her daughter, but if any doubt was left as to whether she could be a physician, she wouldn’t doubt much longer. Dr. Raulerson said when she began applying to medical school, she knew the odds would not be in her favor. It was a time when there were not many women in the medical field, and she had a family. Every school she applied to turned her down, except one.
“I was accepted at Emory because of Robbie. They had a different way of interviewing at Emory. They would interview three applicants sitting at a long table. Each applicant was asked what was an event in your life that was really important. There was a football player at the end of the table that talked about being a quarterback. The other girl at the table talked about being homecoming queen. Then they asked me,” Dr. Raulerson paused. The story hanging in her throat fighting to get free. “I told them about when I saw my daughter for the first time. And, I got a telegram that night admitting me to Emory.”
Ironically, Dr. Raulerson transferred to one of the schools that initially rejected her application. Dr. Raulerson’s husband was already a standout fellow at the University of Florida, and his department petitioned the admissions committee to consider an applicant from Emory. She still laughs when she tells the story of being admitted to a school that initially rejected her because she had a family.
Many in Alabama haven’t had the pleasure of meeting this woman who loves to laugh and read to her patients. But after her work with the #IAmMedicaid social media campaign this spring, more people in the state definitely know her name. She estimates between 70 and 80 percent of her patients are Alabama Medicaid recipients, and many of the children in the campaign are her patients. In the end, BP oil money was partially used to reinstate the physician cut that was implemented on Aug. 1 and to shore up the embattled Medicaid budget. Still, according to Dr. Raulerson, it won’t be enough.
“That campaign had to work. It had no choice BUT to work,” she said. “Many of my patients’ families can’t pay their bills. We don’t have enough doctors now, so what happens when we can’t fund the ones who choose to stay? The system is broken.” During the Regular and Special Legislative Sessions, Dr. Raulerson’s editorials about the importance of fully funding Alabama Medicaid appeared in many of the state’s newspapers.
Although the Alabama Legislature is not in session today, there is still work that can, and should, be done, according to Dr. Raulerson.
Perhaps it’s because of her and her husband’s early struggles with starting their own family, or seeing so many of their patients live below the poverty level in Escambia County. Either way, as long as Dr. Raulerson can string together her outspoken words, the children of Alabama will always have another advocate.
“I’m doing a lot more writing now,” she explained. “I feel like I have to. An article I wrote in 1997 about the importance of fully funding Medicaid is just as important today as it was 20 years ago. Nothing has really changed in all that time other than the number of our patients on Medicaid. Something has to change. We have to change. We have to choose to support our kids.”
Dr. Raulerson is a past president of the Medical Association of the State of Alabama, the Alabama Chapter, American Academy of Pediatrics, and VOICES for Alabama’s Children. She is a board member of The Children’s First Foundation.
Tuesday, October 18, 2016
By: Lisa Kianoff, CPA.CITP, CGMA
Vice President of Warren Averett Technology Group
You know them as vitals. You keep up with vitals on all your patients.
So, by the time you see your first patient of the day, you usually have a history of what might also be called their Key Performance Indicators. These KPIs, along with the latest information, enables you to uncover health patterns, determine the questions to ask and start to advise.
Now put your healthcare practice on the exam table. Can you answer these 10 Questions about the vitals of your healthcare practice?
1. What are the earnings of individual profit centers?
2. How are physician extenders (nurse practitioners/PA’s) contributing to profitability each month?
3. What is the contribution to profit by each physician?
4. How do profit centers compare, month to month? Year to year?
5. What are overhead allocations at each profit center, each month?
6. What profit centers do best for the practice?
7. How do you reduce costs, manage risks and streamline financial processes?
8. How do you know when it is the right time to add a new specialist?
9. What are labor costs per patient visit?
10. Where are you bleeding the most?
Fortunately, if you’re like most healthcare organizations, the 2 primary systems you already have in place may contain most all you need to answer those questions:
Practice Management (PM) is your go-to system for the practice: medical records, patient information, scheduling and medical billing. These systems provide revenue numbers and metrics vital to your ability to analyze your data. Look to these systems for metrics such as employee count, patient visits, square footage, number of providers and other types of non-financial data.
Accounting / ERP System is your core foundational system for all financial related activities. It includes accounts payable, labor and other cost components that details your financial picture. And detail from Payroll – in-house or outsourced – should be pulled into your ERP along with revenue and other non-financial metric information.
The revenue centric view healthcare organizations get from their Practice Management system is not enough. You need the ability to analyze revenue in combination with related costs to understand profitability by relevant business segments such as location, specialty, doctor, procedure or department.
Your accounting / ERP system is the most logical place to connect all this information. You bring in non-financial data such as employee counts, patient visits, square footage, number of providers and revenue data from your PM system and combine it with the revenue and expense information in your ERP and now you have data to analyze in new ways in dashboards and on financials. Calculations like expenses per square foot, revenue per professional, expenses per employee, and revenue per patient visit can now be incorporated into financials, dashboards and general reporting. Insist on reports that empower you to analyze your financials. And for the metrics you always want front and center, build it into your executive or user dashboards or knowledgebase.
What unlocks all this is your foundation, a chart of accounts designed to produce/view financial information for each multi-faceted component of your practice. Drill into General Ledger Detail for reports on GL Segments or Dimensions that can track:
• Physician Extenders (Nurse/PA)
• Specialties / Ancillaries
• Clinic or location
• Patient Type
• Entities / Companies
• Your choice
To understand profitability by relevant business segments you must be able to analyze revenue with related costs. What diagnosis would you stand behind without metrics at these multiple levels?
Practice Managers, Controllers and Physicians need financial reports that are accurate and comprehensive so they have visibility to see what impacts financial performance – positively and negatively.
Upper management need big picture views, with the ability to slice data as needed. For managers, make it personally relevant with specific reports that focus on revenue and expense only for each one’s selected areas of responsibility.
Focus On Your Health
So how do you feel about the vitals on your healthcare organization? You will have more confidence when your team members have access to the KPIs to help them continually improve your practice focused where they have some control and/or responsibility.
You will improve your service and your bottom line through seeing and understanding the metrics and financials of your entire healthcare organization.
Like the patient who regularly gets their vitals checked, a healthcare organization has to regularly monitor its vitals. Take these 10 questions along with you the next time you visit with the professionals you use to help and guide you with questions on business or finance. Having confidence in the answers means you have what you need to know to be healthy.
Lisa Kianoff, CPA.CITP, CGMA, is Vice President of Warren Averett Technology Group. She was founder and President of L. Kianoff & Associates, Inc. which merged with Warren Averett in 2015. Contact: Lisa.Kianoff@warrenaverett.com
Monday, October 17, 2016
The Laura Crandall Brown Foundation will host the 3rd Annual “Get Busy Fighting” golf tournament, presented by Viva Health, on November 4th at Oxmoor Valley Golf Course. The event honors local gynecologic (GYN) cancer survivor and advocate, Ginny Bourland. Ginny was diagnosed with Stage IV ovarian cancer in the summer of 2011. With no prior medical conditions and leading an otherwise healthy lifestyle, Bourland took particular notice when her sudden weight gain was unresponsive to increased exercise and diet changes. She persisted in finding an answer despite both her general practitioner and gynecologist attributing the symptoms to decreased metabolism and stress. “I knew that none of those explanations really sufficed,” said Ginny. “This was not normal for me.” That persistence led her to the ER, where Bourland said she was determined to find answers. Indeed, after a CT scan, Bourland was told she likely had a type of abdominal cancer. Within 24 hours, an oncologist confirmed it instead as ovarian cancer. Since 2011 she has had three recurrences and become an active fundraiser and advocate in the community for gynecologic cancer research and awareness efforts. She is married to husband Shea and stays busy raising their two beautiful children, Will and Bella, and at her job as an actuary at VIVA Health, which is the tournament’s presenting sponsor for the third year in a row. “Ginny is a fantastic co-worker, and an even better person,” said Tony Ceasar, Director of Marketing & Communications at VIVA Health.
“We are proud to serve as the presenting sponsor for this event, and to honor Ginny and her impact on the community in this way.” “We are excited to partner with the Bourlands on this 3rd annual event,” said Mary Anne King, Executive Director of the Laura Crandall Brown Foundation. “Ginny touches everyone she meets in a positive way, whether it’s with her story or her wonderful personality. She is a daily example of how personal strife can be channeled into an opportunity to give hope and help others. That idea is something Laura (Crandall Brown) also personified, and is the reason the foundation exists today.”
The tournament will feature a four person scramble format, with prizes for 1st, 2nd and 3rd place teams. Online Registration is available at www.thinkoflaura.org/getbusyfighting. Entry fees are $125/golfer or $500/team and include greens fee, cart, drink tickets, and entry to the awards lunch. Sponsorships are still available. For more information, contact email@example.com. Proceeds from the golf tournament will benefit the Laura Crandall Brown Foundation’s mission of early detection of ovarian cancer, GYN cancer awareness, and patient support.
About GYN Cancers and the Laura Crandall Brown Foundation’s Impact:
There is no reliable early detection test for ovarian cancer. Currently 85% of cases are detected in late stages, and over half of women diagnosed will die within five years. Furthermore, all GYN cancers together (ovarian, cervical, uterine, vulvar, and vaginal) affect more than 90,000 women in the U.S., and cervical cancer is the only GYN cancer that can be prevented with the use of screening tests. Without early detection and screening tests, awareness is key. The Laura Crandall Brown Foundation is a 501(c)(3) nonprofit that was established in 2009 by family and friends of Laura Crandall Brown, who died of ovarian cancer at the age of 25. Our mission is offering hope through research for early detection of ovarian cancer, empowering communities through gynecologic cancer awareness, and enriching lives through patient support.
For more information www.thinkoflaura.org For more information contact Lindsay Giadrosich, Special Events & Awareness Coordinator (205) 427-0256 firstname.lastname@example.org
Thursday, October 13, 2016
By: Ryan McGinty
President / CEO at OCERIS, Inc.
With the increased adoption of electronic health records, IT has become an integral part of most medical offices. However, it is not always an integral part of the annual budget. Even the most modest office needs to be prepared financially for typical upgrade cycles. Without a dedicated IT support company, these upgrade cycles may seem like a mystery. Meanwhile, overzealous hardware salespeople can encourage a more aggressive upgrade schedule than actually needed. So what is the perfect balance between getting the maximum lifespan of a device and replacing it before it fails? Here are some general guidelines:
The most important part of any IT setup, servers should always be given priority in a budget. In healthcare, uptime is critical. Even if EHR or practice management software is hosted in the cloud, an onsite server can be an important piece of the IT puzzle. Servers generally should be replaced between three to five years in age. Even if the server manufacturer offers extended support contracts, the risk of component failure becomes a real problem past five years. As a server ages, the possibility that some worn out parts won’t have an available replacement also becomes an issue. Replacing early while the original server is still working well is optimal.
While not mission critical, having an important desktop fail can be an unwelcome surprise. Desktops also should follow the three to five year recommendation, the same as servers, but it can be more of a sliding scale depending on the importance of the machine. For instance, if a desktop is used as the sole way to do transcription, it would be best to proactively replace the system as it approaches the three year mark, rather than wait for it to fail at an inopportune time. It will also give time to ensure that any proprietary hardware interfaces (for example, transcription equipment, lab equipment, etc.) work with the replacement hardware and deal with any incompatibilities as time permits.
Laptops lifespans are typically shorter than desktops, primarily because of two things. First, laptops are moved around, dropped, and generally put through more rigorous physical paces. Second, they have batteries. Batteries, depending on how they are used and charged, can last anywhere from two to five years, but typically do not last more than three years under normal business usage. The ability to replace the main battery varies wildly between vendors and models. Even if the battery is easily replaced, the cost of replacement may be prohibitive and that money better applied towards replacing the entire laptop.
Because of the variety and varying lifespans of peripherals, the replacement interval should be judged on a case-by-case basis. Weigh the importance of the peripheral against the replacement cost if there is evidence it is starting to wear out. More expensive devices, such as enterprise class printers, may be repairable while less expensive versions, such as small office printers, are cheaper to replace than repair.
IT is sometimes an afterthought when planning the small business budget - at least until things start failing and the replacement costs, as well as inconveniences, start to pile up. Knowing the probable lifespans of your devices can help you determine a proactive replacement schedule to divide the cost up over time - and minimize the chance of failures before they happen.
Thursday, October 6, 2016
by: Lauren Hughey, MD
I have had many patients come in lately looking for a natural, clean, chemical-free option for facial rejuvenation. What could be better than your own Growth Factors? Nothing added- 100% natural and all yours! This is what PRP microneedling offers you. We do a simple blood draw from your arm and behind the scene, we siphon off the plasma that contains your platelets that are naturally rich in growth factors. Platelets heal wounds, and when deposited on the face with the microneedling device, we see "a healing" of our aged cells. This cellular rejuvenation means improved texture, lightening of dark spots, shrinking of pores, and just an overall fresher look! We can even use PRP on stretch marks and to stimulate hair growth. PRP is also being used in many other specialties to treat injured tendons and muscles and promote wound healing.
This is a new and exciting cutting edge technology that allows us to harness our own body's healing power.
Dr. Lauren Hughey
Wednesday, October 5, 2016
By: Marchelle Cagle, CPC,CPC-I, CEMC,CPB,CMOM
Cagle Medical Consulting, LLC
So the IT guy says you have to renew your password every 30 to 60 days but we have so many passwords to remember in healthcare already! Where they all are stored? Electronic medical record systems, in the office, hospital systems, insurance sites, HR systems, accounting and payroll systems etc. You get the picture by now.
We are already so burdened down with patients, billing and revenue, coding correctly, pay cuts!
I understand it is so challenging to work in the healthcare now and the virtual world we now live in.
So why must we take this serious! It seems innocent to let your co-worker use your password just this once until he or she receives theirs.
Everyone in healthcare need to understand these words “Cyber Attack”! In 2015 there were 10 breaches all made in the month of December of very serious nature reported to HHS Office of Civil Rights.
Let’s take a look 5 of these breaches!
1. 12/01: Centegra Health System, Il, affected 2,929 people.
A mailing snafu may have exposed personal information of patients.
2. 12:01: Cottage Health, Calif. Affected 11,000 people
In a statement, Cottage Health officials said limited information from as many as 11,000 patients was exposed. "Cottage Health recently hired a team of cyber security experts to test our data systems," the statement said. "This team discovered a single server that was exposed. We immediately shut down this server and began an investigation."
3. 12/02 Univesity of Colorado Heath, Co. 827 people affected.
A nurse at Poudre Valley Hospital was fired for viewing patients' medical records out of personal curiosity, the Coloradoan reported. University of Colorado Health, which operates PVH and Medical Center of the Rockies in Loveland, is notified patients that an employee inappropriately accessed their electronic medical records.
4. 12/03 Blue Cross Blue Shield of Nebraska, 1,872 people affected
Blue Cross and Blue Shield of Nebraska notified beneficiaries that a printing error caused some dental explanation of benefits forms to be sent to the wrong customers. The forms revealed treatment and services that the insurer paid for their insured.
5. 12/8 Maine General Health and subsidiaries, 500 people affected
On Nov. 13, 2015, the FBI notified MaineGeneral that agents had detected MaineGeneral data on an external website that is not accessible by the general public. The data affected includes the dates of birth and emergency contact names, addresses, and telephone numbers for certain patients referred by a treating physician to MaineGeneral Medical Center for radiology services since June 2009.
See also: MaineGeneral, FBI probe cyber attack.]
These incidents can cost from thousands of dollars to millions of dollars. Ways to avoid these problems! Perform risk analysis assessments; provide education and training, policies and procedures. Role playing can be helpful to make these situations real to your employees and to ensure success in the event of a breach or cyber attack. The best advice I can offer is to treat these systems and records as if it is your own bank account. Be consistent with your HIPAA training and make it a constant work in process!
Don’t fret be consistent take advantage of the people in the know that can make your life easier!
Marchelle Cagle, CPC,CPC-I, CEMC,CPB,CMOM
Cagle Medical Consulting, LLC