August 2014 Client Newsletter
August 1, 2014
HEPATITIS A VACCINES
Medicare covers Hepatitis B vaccination, but Hepatitis A is not covered by Medicare for routine vaccination. Some other insurers may cover it – but be sure to verify benefits or collect payment on the day of service.
However, Medicare & some other insurers do cover it if the patient was exposed to Hepatitis A. The routine immunization diagnosis codes cannot be used, you must use Dx codes V01.79, V02.60 or V02.69 to indicate that the vaccine is not routine and that the vaccine being given is because the patient was exposed to the disease.
OPEN PAYMENTS PROGRAM REVIEW AND DISPUTE
– EIDM) and the Open Payments system in order to view the data reported by industry that will be made public on September 30, 2014.
Registration is a voluntary process, but it is required if a physician wants to review data reported by industry relating to financial interactions industry has had with physicians.
Registration for physicians and teaching hospitals will be conducted in two phases for this first Open Payments reporting year. There is no official end date for when physicians need to finish the registration steps. However, in order to review or dispute data submitted by industry for the 2013 reporting period, physicians must be registered – and have reviewed any data reported about them – on or before August 27, 2014, the end of the initial 45-day review and dispute period. Please keep in mind that identity verification can take some time; CMS recommends completing the registration process as soon as possible and not waiting until the end of this initial 45-day review and dispute period.
Two Phases of Registration
Register in the CMS Portal - HAPPENING NOW:Enterprise Portal (the gateway to EIDM) http://tinyurl.com/pat3ngx
- This Use the Phase 1 Step-by-Step CMS Enterprise Portal Registration for Physicians and Teaching Hospitals presentation for guidance on how to complete this first portion of the registration.
- Register in the Open Payments System – HAPPENING NOW: Register in the Open Payments system to complete the registration process and have the opportunity to review and dispute data submitted by applicable manufacturers and applicable group purchasing organizations (GPOs) prior to public posting. Use the Quick Reference Guide on how a physician can register in the Open Payments system.
- Review – July 14 through August 27, 2014: If you have any concerns about the data's accuracy, this is the time to dispute and correct the data submitted by industry. Use the Quick Reference Guide on how to initiate and dispute a record in the Open Payments system. Share the Quick Reference Guide on how to accept or reject a nomination with individuals that will be your Authorized Representative.
Note: Any data that is disputed, if not corrected by industry, will still be made public but will be marked as disputed. Learn more about the review and dispute process.
IF A PATIENT REQUESTS YOU NOT TO BILL THEIR INSURANCE
HIPAA Privacy gave patients the right to request a provider not bill their insurance as long as they paid in full, but the provider was not required to agree. However, HITECH made it a requirement for providers to comply as long as the patient paid in full on the day of service. If the patient does not pay, or their check bounces, then HITECH simply requires a reasonable effort to collect the payment. If that is not successful, then the provider is permitted to file an insurance claim.
Key points - the best steps to take to stay compliant with HITECH:
- Have the patient sign a formal, written request that information relative to self-paid services not be disclosed (usually called a Restrictions on Uses and Disclosures Form). The patient’s signed restriction on such disclosures absolutely precludes the provider from submitting a claim for those services. As noted above, the provider is protected from any allegation regarding provider contract breach for not billing by the patient or the carrier, even if such an obligation existed.
- Flag the medical records somehow so they are not disclosed to the health plan should the health plan make a request. The easiest way is to keep them in a separate file. If that’s not an option, clearly mark the record as “Not for Disclosure for Payment or Health Care Operations.”
- If you are sending the records to another provider (which is permissible), make sure the other provider knows the records cannot be sent to the health plan due to the patient’s request. A big red stamp or other notation saying the records may not be disclosed in response to a carrier’s payment or health care operations request should suffice.
VIRTUAL CREDIT CARDS (VCC's)
One more suggestion if you are approached by an insurance company to accept VCC’s – ask them the cost of: 1. VCC, 2. Gift cards, and 3. ACH EFT.” And feel free to get us involved to help sort thru the “chatter.” The ACH EFT is usually very low - $.25-.35 cents and may be worth it.
BILLING G0444TO MEDICARE WITH AN AWV
Subsequent Annual Wellness Visits (G0439) ARE being paid with G0444.
Reminder that Medicare will not cover the G0444 (Annual Depression Screening) on the same day as their:
Welcome to Medicare (G0402Initial Preventive Physical Exam, IPPE)
Initial Annual Wellness Visit (G0438).
We recommend performing on separate days for G0402.
HOME HEALTHCARE CERTIFICATION FORMS
G0179 is a Home Health Care Certification for a patient you had previously certified.
G0180 is a Home Health Care Certification for a patient's initial certification.
You can use any legitimate diagnosis code(s) which is appropriate to the patient's health issue.
Note: if another physician (MD/DO/DPM) has already filed a certification for this patient and the same period of time, you will not be paid.