January 2016 Client Newsletter
You Can Charge for Services to Increase Your Revenue
Well visits and sick visits on the save day: Just a reminder that providers are absolutely allowed to bill BOTH a SICK visit and a WELL visit on the same day. There is nothing inappropriate about that - as long as both services are performed and properly documented. Some patient education may be necessary to explain why it is reasonable for you to provide services, but you are entitled to be paid for those services.
The following services are covered by Medicare and other insurers as indicated below:
- Annual Well Visits: covered by all Medicare plans and many other insurers. Very common with HMO's, less so for other plans. No deductible or co-insurance applied.
- Medicare allows: G0402 = $179.74, G0438 = $185.38, G0439 = $125.90).
- Transitional Care (99495 = $177.69, 99496 = $250.42)
- Chronic Care ($43.71 ~ per 20 minutes). You can contract out or hire an LPN /RN to handle the majority of this work.
- Advance Care Planning/End-of Life (new with Medicare effective 1/1/16). 99497 = $91.24 for the first 30 minutes. 99498 = $79.10 for each additional 30 minutes).
See details below. If performed on the same day as an Annual Well Visit (G0402, G0438, or G0439), the Medicare Deductible and co-insurance are waived - so would be paid in FULL.
These can be added onto office and facility (hospital and nursing home) visits. Your staff can use your EHR, NaviNet, or the HealthPac Scheduler to verify benefits in advance.
Office providers not taking advantage of the above programs may want to consider looking at very carefully. In many case, you are likely already providing all or part of these additional services to your patients - for free.
Feel free to call with any questions. We can provide the requirements to bill each of the above services.
2016 Medicare Part B Deductible & Co-insurance
The 2016 Medicare Part B Deductible for 2016 is $166. Any clients who would like the 2016 edition of the Medicare Co-insurance table, just let Rich know.
Also, with the large number of non-Medicare high deductible plans, we strongly encourage collection of co-pay, co-insurance and deductibles on the date of service. Even if you do not collect the full allowed amount, collecting 50-75% early in the year is good business. Entering the third year of the ACA plans, patients are no longer surprised at these requests. Accepting credit and debit cards is also now the "norm" for providers. Our highest performing clients enforce firm financial policies in this regard, unless the patient can document financial hardship.
Medicare Approves End-of-Life Counseling
While CMS approved coverage and payment for End-of-Life Counseling (called "Advanced Care Planning" - ACP), they are leaving implementation up to each MAC.
NJ Participating Allowed Amounts for 99497 and 99498 are $91.24 and $79.10, respectively, in the office. Slightly lower if performed at a place of service outside the office: $83.98 and $78.70, respectively.
- 99497 covers a discussion of advance directives with the patient, a family member, or surrogate for up to 30 minutes.
- 99498 is an add-on code for each additional 30 minutes of discussion.
According to what we have read so far, End of Life Counseling can also be paid in addition to office and hospital visits, and in addition to the Medicare annual wellness visit. Be sure to let us know if you will be performing this service and/or need it added to your charge form.
OIG 2016 Work Plan Outlines Short Term Goals - Ambulance
The Department of Health and Human Services (HHS) Office of the Inspector General (OIG) issued its annual Work Plan for 2016 outlining its goals and targets for the coming year. The OIG is the independent oversight body within HHS that works to prevent fraud and abuse within the Medicare and Medicaid Programs. This document reflects where OIG hopes to focus its efforts in the coming year.
As stated in the plan, OIG intends to continue its heavy scrutiny of ambulance services due to high levels of questionable billing practices related to medical necessity and level of transport.
The OIG's Work Plan states: Ambulance services-questionable billing, medical necessity, and level of transport. "We will examine Medicare claims data to assess the extent of questionable billing for ambulance services, such as transports to dialysis facilities that potentially never occurred or potentially were medically unnecessary. We will also determine whether Medicare payments for ambulance services were made in accordance with Medicare requirements. Prior OIG work found that Medicare made inappropriate payments for advanced life support emergency transports. Medicare pays for emergency and non-emergency ambulance services when a beneficiary's medical condition at the time of transport is such that other means of transportation would endanger the beneficiary. (Social Security Act, § 1861(s)(7).) Medicare pays for different levels of ambulance service, including basic life support, advanced life support and specialty care transport. (42 CFR § 410.40(b).) (OAS; W-00- 11-35574; W-00-12-35574; W-00-13-35574; W-00-14-35574; various reviews; expected issue date: FY 2016)."
Contractor Selected for Phase 2 HIPAA Audits
The Department of Health and Human Services (HHS) Office of Civil Rights (OCR) has announced FCi Federal will be the contractor for the second phase of HIPAA privacy audits that will begin in early 2016. These Phase 2 audits are intended to examine compliance with HIPAA privacy, security and breach notification laws for both covered entities and their business associates.
The HITECH Act requires HHS to perform periodic audits of covered entity and business associate compliance with the HIPAA Privacy, Security and Breach Notification Rules. HHS Office for Civil Rights (OCR) enforces these rules, and in 2011, OCR established a pilot audit program to assess the controls and processes covered entities have implemented to comply.
OCR officials have indicated that they intend to release an audit protocol document before the next round of audits begin. This document will allow prospective targets to know what FCi Federal expects. According OCR officials, the agency is expected to conduct 200 desk audits and 24 on-site audits in 2016. Previous complaints filed against entities will not factor into who is selected for audits.
Please call Rich with any questions.