Medicare’s Value-Based Purchasing (VBP) program for hospitals, mandated by the Affordable Care Act, took off upon the release of final regulations on April 29, 2011. VBP marks the start of true pay-for-performance, as opposed to pay-for-reporting, at the hospital level. The intent is to pay for better value, patient outcomes and innovations, and not simply to reward volume of services. As we enter 2012, we are halfway through the first performance period. Anesthesiologists should begin analyzing and planning how they might partner with their hospitals in achieving the scores necessary to earn VBP incentives.The hospital scores are based on Clinical Process of Care measures (70%) and on Patient Experience of Care (30%) as measured by completed Hospital Consumer Assessment of Healthcare Providers and Systems (HCAHPS) surveys. Hospitals receive points for achievement and improvement for each measure in the two domains, with the greater set of points counting toward the domain total....
Another Medicare compliance deadline approaches, and it has attracted a fair amount of attention. The good news is that it will apply to few pain physicians and even fewer anesthesiologists. Sometimes it is necessary to explain a new rule or requirement just so that our readers know not to worry. This is one of those times.By July 1, 2012, those physicians and facilities that are affected are expected to be in compliance with the “3-day payment policy.” The 3-day payment window applies to certain outpatient services provided by hospitals and hospitals’ wholly owned or wholly operated entities, including physician practices.The policy has applied to diagnostic services and related non-diagnostic services since 1998. The Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act of 2010 broadened the definition of related non-diagnostic services that are subject to the payment window to include any non-diagnostic service that is clinically related to...
A change to some language in the Anesthesia Services chapter of the Medicare National Correct Coding Initiative (NCCI) manual recently created considerable confusion among participants in the on-line discussion maintained by the Medical Group Management Association (MGMA) for the Anesthesia Administration Assembly (AAA).The information that gave rise to the confusion has been clarified. The NCCI has confirmed that there has been no policy change here; epidurals and blocks placed preoperatively for the management of postoperative pain are still separately reportable and not bundled into the anesthesia service unless they are used as the method of administering the anesthesia itself. Because the issue of post-op pain management is a perennial hot topic, we take this opportunity to help ensure that no incorrect interpretations take root.Chapter II of the NCCI manual, “Anesthesia Services,” was revised effective January 1, 2012. It contains a number of statements that are consistent with the established principles of billing...
Owners of ambulatory surgical centers (ASCs) often wish to receive a share of the professional fees paid to their anesthesiologists and nurse anesthetists. ASC owners and anesthesiologists and CRNAs have adopted—or at least proposed—numerous corporate and contractual structures over the last few decades to accomplish this transfer of revenues. The federal Anti-Kickback Statute (AKS), which prohibits a broad range of payments for referrals, has generally caused conservative lawyers to advise against such arrangements. Some attorneys and other advisors who are less risk-averse have helped their clients to go ahead.
The HHS Office of the Inspector General (OIG) has just provided some guidance on the issue. The guidance takes the form of an Advisory Opinion (No. 12-06) (posted June 1, 2012), which means that the decision is not binding on any parties, including the OIG. Nevertheless, the Advisory Opinion spells out how the OIG would apply the AKS principles to two common...
Inspector General Daniel Levinson of the Department of Health and Human Services has stated in his Spring 2012 Semiannual Report to Congress that his office expects to recover $1.2 billion from audits ($483 million) and investigations ($748 million) concluded during the first half of 2012. Between October 2011 and March of this year, the OIG also brought 346 new criminal cases and 138 civil actions.
Information technology is playing as important a role in the OIG as it is in every other health care arena. In his Executive Summary, Mr. Levinson said:
Over the past 6 months, OIG has stepped up our focus on data analytics as a critical tool for enhancing our fraud, waste, and abuse activities. We are using advanced data analytics to help us conduct risk assessments; more effectively pinpoint our oversight efforts; and significantly reduce the time and resources required for audits, investigations, evaluations, and other program...