February 20, 2012

Have you heard about the federal privacy and security compliance audit pilot program?  The Health Information Technology for Economic and Clinical Health (HITECH) Act, passed as part of the 2009 stimulus package, requires the Department of Health and Human Services (HHS) to conduct periodic audits to ensure covered entities and business associates are complying with the Health Insurance Portability and Accountability Act (HIPAA) Privacy and Security Rules and Breach Notification standards.  To implement this mandate, the HHS Office of Civil Rights (OCR) is piloting a program to perform up to 150 audits of covered entities to assess privacy and security compliance. The pilot phase began in November 2011 and will conclude by December 2012.

February 13, 2012

In any financial transaction, the person holding the money is at an advantage.  Getting money back from someone who should not have been paid is harder than not making the payment in the first place.   CMS knows this, and that is why it is placing a new emphasis on prepayment review of claims.  Originally slated to begin on January 1, 2012 the prepayment review initiative will now formally launch in June.  The number of prepayment reviews is going to increase from 1.2 million to 2.7 million claims per year.

February 6, 2012

Last week’s Alert discussed the growing trend toward including performance measures in contracts between hospitals and anesthesia groups.  We identified clinical quality, efficiency and patient satisfaction measures developed by the Surgical Care Improvement Project (SCIP), the Medicare Physician Quality Reporting System (PQRS), the American Society of Anesthesiologists (ASA), the Anesthesia Quality Institute (AQI), Press-Ganey and the Hospital Consumer Assessment of Healthcare Providers and Systems (HCAHPS).  All of these measures can be the basis of hospital or ambulatory surgery center contracts for performance-based payment.

January 30, 2012

Contracts between hospitals and anesthesia groups frequently include provisions for compensation for the anesthesiologists’ services to their institutions.  Estimates by speakers at this past weekend’s ASA Practice Management Conference ranged from 70 to 81 percent of anesthesia groups receiving payments from their hospitals.  The amount of compensation varies widely, depending on different factors such as payer and patient mix, size of the group, subspecialization, number of other anesthesia groups in the geographic area, salary costs, OR utilization rates and number and spread of anesthetizing locations outside the OR. 

January 23, 2012

The new calendar year is the last year in which “eligible professionals” (EPs) can begin to participate in the Medicare incentive program for electronic health records (EHRs) and receive the maximum available bonus payment, $44,000 over a five-year period.  Although the final regulations on the EHR program appeared in mid-2010, there is still a fair amount of confusion over whether anesthesiologists can qualify for the bonus.  In this Alert, we will review the cumulative requirements for participation in a program whose summary is deceptively simple:

January 17, 2012

Do you realize that we have just passed the 20th anniversary of the Medicare Fee Schedule?  A product of 1989 legislation, the Physician Fee Schedule went into effect on January 1, 1992.  (And William Hsiao, PhD, whose study of Resource-Based Relative Value Systems was the basis for the change from charge-based payment methodology, is still teaching at the Harvard School of Public Health today.)

January 9, 2012

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). 

January 3, 2012

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.

December 27, 2011

On Friday, December 23, President Obama signed legislation extending 2011 Medicare Fee Schedule payment rates for two months.

December 19, 2011

Texas has revised its statute on medical informed consent, 25 Texas Administrative Code, Chapter 601, effective January 16, 2012.  The new rules, adopted by the Texas Medical Disclosure Panel, require physicians to inform patients of the risks of anesthesia and/or perioperative pain management and to obtain their signed consent for these procedures.

December 12, 2011

ABC recently conducted a survey of clients and others to assess the anesthesiology community’s level of interest in a network of independent practices participating in joint quality improvement and cost-effectiveness initiatives.

December 5, 2011

The end of the year is a good time to review Medicare’s Physician Quality Reporting System (PQRS).  Several clients have recently raised questions about the PQRS program and it is likely that a number of other readers could use a refresher course.

November 28, 2011

In just under five weeks, on January 1, 2012, physicians, hospitals, health plans and claims clearinghouses will be required to be in compliance with the ASC X12 Version 5010 HIPAA standard for the electronic transmission of healthcare claims and other administrative communications such as claims, remittance, eligibility, claims status requests and responses.

November 21, 2011

Several readers have asked how to plan for the next few years now that the United States Supreme Court has announced that it will review the constitutionality of the Affordable Care Act (the “ACA”) next year.  The answer depends on whether the Supreme Court’s decision, which is expected by early summer, upholds the ACA, invalidates it in part, or decides that the entire statute must fail.

November 14, 2011

More than 750 companies offering some form of electronic health record solution have entered the market within the last few years, according to a report entitled "US Markets for Electronic Medical Records in 2012" by the Millennium Research Group.

November 7, 2011

Every November, the Centers for Medicare and Medicaid Services (CMS) issues a final version of the regulation updating the Physician Fee Schedule – and for the past eleven years, the update announced by CMS has been a decrease in payment rates, thanks to the Sustainable Growth Rate (SGR) formula. This year is no exception.

October 31, 2011

Two recent court decisions combine to offer anesthesiologists an important warning about expressing their opinions regarding colleagues.

October 24, 2011

The finalized regulations on Accountable Care Organizations (ACOs) are here.  CMS will begin accepting applications from potential ACOs on January 1, 2012, for April 1 or July 1 start dates

October 17, 2011

For over a decade, anesthesia software vendors have worked to provide health information technologies for the perioperative process.  To this day, hospital adoption of an anesthesia Electronic Medical Record (EMR) remains low for non-academic facilities.  Many people and companies have expressed an opinion on the subject and the most common reason offered is the failure to make an anesthesia EMR a hospital purchasing priority. 

October 10, 2011

Thriving or even surviving as an independent anesthesia group is more challenging all the time.  Medicare payment rates are dropping, fee negotiations with private health plans are painful and hospitals are seeking ways to stop paying stipends to their anesthesiology groups.  CMS and TJC regulations and standards are more complex and ever-changing — let alone increasingly difficult to implement.