MIPS 2018

MIPS is rapidly approaching Year 2 of its existence and CMS just put out a fact sheet on the new rules for 2018. We strongly suggest you download the Final Rule fact sheet and go over all the changes on your own, but here are some highlights:

• The definition of  "small practice" will change.  Practices will be excluded from MIPS if they  have less than 200 Part B beneficiaries or have less than $90,000 in Part B allowed charges.
• Small practices will be automatically awarded 5 bonus points, as long as data is submitted for at least one performance category during a performance period.
• In 2018, you can use either 2014 or 2015 Edition Certified Electronic Health Record Technology (CEHRT). However, exclusive use of 2015 Edition CEHRT will result in a 10% bonus in the Advancing Care Information (ACI) category. 
• CMS will award up to 5 bonus points on the MIPS final score for treatment of complex patients.
• The performance threshold has been raised to 15 points in 2018 (up from 3 points in 2017). 
• There is a new hardship exception for the Advancing Care Information performance category for small practices. 

Some types of practices have extra challenges , and CMS has provided some helpful MIPS Specialty Guides:

• podiatry
• radiology

SSNRI is coming!

Since the beginning of time itself, Medicare cards have looked something like this:

But, beginning April 1, 2018, Medicare cards will look like this:

The big change is that the Medicare Claim Number will no longer be based on a Social Security Number, in order to help prevent identity theft.

The wage-earner's Social Security Number has always been the basis for the assignation of a Medicare Claim Number. The claim number is then used for routine Medicare business transactions and regularly appears on Medicare cards, explanation of benefits, annual notices, billing statements, insurance claims, etc. Occasionally, cards are lost or misplaced, or correspondence is accidentally mailed or delivered to the wrong address. When this happens, the Social Security Number is inadvertently revealed to someone who is not entitled to have that information.

Portal to the identity vault

Social Security numbers were never intended to be a form of identification, yet the reality is that the Social Security Number is as close to a national identity card as we get. A lost SSN, vis-á-vis a lost Medicare card, exposes the Medicare beneficiary to a very real possibility of identity theft. The SSN is the key to the identity bank vault and yup, there it is, printed right on front of the Medicare card for all the world to see.

I said PII, not PIE!

With ever increasingly sophisticated methods of perpetrating identity theft, it has become imperative more than ever that personal identifying information (referred to as PII) be protected as much as possible, as identity thieves really would like an extra helping of that PII, figuratively speaking. And that brings us around to today's topic: SSNRI.

Dr. Frankenstein is ready for SSNRI

Formally, SSNRI stands for Social Security Removal Initiative, part of a Medicare related law passed in 2015. In that law, it was mandated that, beginning April 2019, the Social Security Number can no longer be used as the primary basis for assigning a Medicare Claim Number. There will be a transitional phase-in period beginning April 1, 2018, a full year before the mandatory change.

Beginning April 2018, Medicare recipients will receive a new Medicare card that will have a randomly assigned 11-digit Medicare claim number. The process will be automated and recipients need not take any action other than making sure their address is current with the Social Security Administration. During the subsequent year-long transition period,  either the new Medicare claim number or the old Social-Security Number-based Medicare claim number can be used to process Medicare claims, appeals, requests for medical information, and the like.

However, the gig will be up in April 2019 . At that point, claims must be submitted with the new Medicare Claim Number or else. But have no fear, we are all over this and will have the new process fully implemented long before then. This blog posting is intended to be more of a heads-up informational treatise, rather than a how-to technical instruction. We will post further instructions as we implement changes to Rexpert.

MIPS Milestone

2017 is the first year of the Merit-based Incentive Payment System, hereafter referred to as MIPS. Basically, MIPS is the replacement for Meaningful Use and PQRS programs. In this transitional year of MIPS, you may be able to receive incentive payments if you participate in MIPS by:

• Submitting data for a full year, or
• Submitting data covering at least a consecutive 90-day period

Of course, participation in MIPS is voluntary but non-participation in MIPS can result in a downward payment adjustment of up to 4 %. However, participation in MIPS can result in an up to 4% incentive payment and all that is required is the submission of data. Minimal participation will result in neither penalty nor incentive payment being applied.

October 2nd is the last day to opt-in to participate in MIPS in 2017, as its only 90 days to go before we close out 2017 and start working on 2018.  If you submit data for at least 90 days, then you may be eligible for a positive payment adjustment and who wouldn't want one of those?

One of the requirements for MIPS reporting is that the reporting must be done through a certified EHR. Now, while we think our AuroraEHR service is the greatest EHR ever, there are many other competent and capable EHR services that provide a good product. However, for those of our clients who do not use AuroraEHR but would like to get 4% more Medicare money instead of a 4% Medicare reduction, there is some good news.

Since your patients, schedule, provider, locations, payors, and diagnoses are already set up in Rexpert, we can add the AuroraEHR functionality and make this quicker and easier for you than any other option.

If you are interested in setting up EHR or have questions about the process, please contact us via the Feedback button in Rexpert. Note we can also be contacted via our Facebook page, as well.

CMS Study

As we are all aware, Medicare uses data and statistics to determine a whole host of things, including payment rates - a subject very near and dear to our billing hearts. Naturally, it is incumbent upon us to provide accurate and meaningful data to CMS, and that brings us to today's topic:CMS's Global Surgery Data Collection initiative. 

How data gets processed

No, Global Surgery does not mean we all are going to get operated on. Although, given the state of the world today, a collective lobotomy might be a good thing. When a patient has a surgical procedure, there may be a global billing period associated with the procedure. If there is a global period, then all post-operative visits are, by definition, inclusive to the procedure and must be reported by billing the visit under CPT code 99024 ( “Postoperative follow-up visit, normally included in the surgical package, to indicate that an evaluation and management service was performed during a postoperative period for a reason(s) related to the original procedure.”).

While practices with less than 10 practitioners are not required to report, we encourage everyone to participate, in the interest of providing accurate data to CMS. Note the data collection for this study applies only to practices located in Florida, Kentucky, Louisiana, Nevada, New Jersey, North Dakota, Ohio, Oregon, or Rhode Island.

Hmm...this calls for  CPT code 99024

The reporting period began July 1st, 2017 and in our reading of the literature from CMS, we did not see an end date. At any rate, for more information on this particular data collection initiative, check out the CMS Global Surgery Data Collection website. A list of qualifying procedure codes for the use of CPT code 99024 can be downloaded from the CMS page and if you have any questions (and who doesn't?), there may be an answer for you on the FAQS sheet. If you need to ask Medicare a question about this particular topic, e-mail your question to:

MACRA_Global_Surgery@cms.hhs.gov

On a practical level, just make sure you are entering a charge for each office visit.  You can check this by using the Rexpert menu option Daily Activity -> Missing Charge Reports -> Scheduler.  This is actually a good idea for all practices in every state - just one missed charge a week can add up significantly by the end of the year.


Feel free to contact us with any questions. If you need assistance adding CPT code 99024 to your billing process, contact Client Services via the Feedback button in Rexpert.

Computer Security

There has been plenty written in the news lately about hacks and cyber-attacks, but relax, we are going to stay out of politics in relation to this topic. As keepers of personal identifying information, we, in the medical and health care professions, are often targets of Internet schemers and scammers. The hackers are extremely inventive and persistent, constantly coming up with new ways to get past our defenses. However, there are some things that we can do to limit exposure to cyber-attacks, which is more than can be said about our exposure to politics.

Hospitals and medical centers are perfect targets for Ransomware. Ransomware is a nasty little file that gets uploaded into a computer when the user clicks on a link or attachment. The infecting file goes into action, encrypting files and rendering them inaccessible. The Ransomware blackmailer then threatens to make hacked information public or offers (for a fee) to remove the encryption and restore access to the computer. Because of the critical nature of health care, hospitals tend to pony up the blackmail fee to get their computers back up and running as soon as possible. Having to pay money for restoring the use of your own computer is simply deplorable but, unfortunately, Ransomware, Malware, phishing, and other pernicious social engineering scams are here to stay.

The adage "If it looks too good to be true, then it probably is too good to be true" is certainly applicable to any e-mails you may receive. Use some common sense:  There are not millions of inheritance dollars in Nigeria, you did not just win a tricked-out Lamborghini, and your Facebook fiancé may not really be the drop-dead gorgeous lead singer of the Flaming Yams. Yet, despite the obvious, it is surprising that scammers still find people to scam. But it's really not a question of gullibility as scammers have increasingly become more and more sophisticated in their techniques.

Scammers replicate logos to make emails look as if they came from your bank, doctor, credit card company, or a website you commonly use such as Linkedin, Paypal, Google, or Facebook. The text message may refer to a problem with your account, an unauthorized intrusion, or some other ruse designed to get you to click on a link or otherwise furnish an ID, password, or bank account information. The sophistication involved is designed to get users to set aside his or her mistrust, and unwittingly let the scammer enter the computer system. 

Here at Rexpert, we  monitor our servers and update our security software regularly. However, we cannot monitor the individual PC's and laptops that log onto our system. So, here are a few things that you can do on your end, to help prevent a cyber intrusion:

• Make sure that the operating system of the PC or laptop you use to log into the Rexpert Windows server has all the needed security updates so as to minimize the likelihood of getting infected by malware. 
• Update and run your security software early and often. If you're not sure how to install security software or where to get it, please contact Client Services via the Feedback button.
• Use security software that scans all incoming e-mails and attachments before opening them.

If the above recommendations are not in your job description or qualifications, then work with your IT department to effect all of the above.

When it comes to attachments, follow the advice of that great computer security guru Elmer Fudd: "Be vewy, vewy careful":

• Be cautious of any e-mail attachments that you are not expecting. 
• Take time to contact the person sending an e-mail before opening anything. 
• Be very, very wary (vewy, vewy, wawy?) of any links contained in the body of an e-mail. 
• Learn to fear buttons, too. Pressing a button icon can cause malicious code to be uploaded.
• Check the validity of a link contained in an e-mail text by hovering over it (see explanation below)

You can check the link for a URL by hovering over it. For instance, if you hover (place your cursor) over:

 Read our awesome  blog!

You should see the URL, either in a pop-up display or as on our computers, at the bottom of the screen:

 https://gvt-rexpert.blogspot.in/

But if I wanted to take advantage of your trusting nature, I would send you this link which still looks like the link to our totally awesome blog:

Read our awesome blog!

But now, when you hover on it, you will see:

https://www.fbi.gov/scams-and-safety/common-fraud-schemes

Now, if I was really scamming you, the link would go to a malicious site instead of the FBI page on common fraud schemes (which is good reading, by the way, on what we have just skimmed the surface of on this topic). So, the point is, check the validity of  links before clicking on them. That's it for now and back to getting wascawy wabbits, and good luck avoiding the politics (or powitics, as Elmer Fudd would say). 

Online Eligibility

Beginning in April 2018, Medicare recipients will receive a new Medicare card that will have a randomly assigned 11-digit Medicare claim number (or policy number, to Rexpert users). This will replace the current policy number, which is based on the social security number. A year-long transitional period will follow, during which you can process Medicare claims using either the old or new Medicare number without any adverse effect on claim processing. However, beginning in April 2019, all claims will have to be processed using the new Medicare numbers.

CMS has put out out a list of things to do to get ready for the number change.  Rexpert will, of course, handle the new Medicare number format and will provide instructions for the April 2018 roll-out date.

One suggestion from CMS you can begin working on now is this:

Verify all of your Medicare patients’ addresses. If the addresses you have on file are different than the Medicare address you get on electronic eligibility transactions, ask your patients to contact Social Security and update their Medicare records.

As part Release 11.5, we are offering an Online Eligibility service which can be quite useful for checking addresses.  The report is fast and easy to use, and the patient's Medicare address shows up right on the summary:

Click on the image for full-size

You should compare the Online Eligibility address with the address in Account Registration. If the two addresses are different take one of these steps:

• If the Online Eligibility address is correct, update the address in Account Registration.
• If the Account Registration address is correct, advise the patient to contact Social Security to update his or her Medicare address. Otherwise, the patient may not receive his/her new Medicare card next year.

Well, that's it for now, and if you would like to know more about subscribing to the Online Eligibility service, please contact Client Services by using the feedback button in Rexpert.

MIPS Lookup

Hey everybody, we've got some more MIPS stuff for you because MIPS is the Thing That Won't Go Away.

But before we move on to the new elibility lookup tool, let's review briefly how MIPS works:

MIPS is designed to combine existing reporting programs and to incentivize better care by qualified clinicians. The list of qualified clinicians is as follows:

Physicians (includes MD/DO and DMD/DDS)
Physician Assistants (PAs)
Nurse Practitioners (NPs)
Clinical Nurse Specialists
Certified Registered Nurse Anesthetists

CMS has provided a handy-dandy interactive tool that will help you determine whether or not  you are eligible to participate in MIPS this year. You can follow the link below to access the tool:

MIPS Eligibility Tool

Once on the main screen, just enter the NPI number for you or your organization and click on the blue     Check Now      button:

The next screen will display results for clinicians as an individual and as a group member; you will now know if you or your practice is eligible or exempt from MIPS.

That's it for now and we'll see you at the next MIPS episode!

Opioids

There has been much made in the news lately about the opioid epidemic. And with reason too: the numbers are absolutely staggering and boggle the mind. According to the Centers for Disease Control and Prevention (CDC), opioid-related deaths have quadrupled in number since 1999. And between 2000 and 2015, more than half a million people have died of a drug overdose. These statistics include obvious villains like heroin and opium, but amazingly enough, sales of prescription opioids and deaths from prescribed opioids have both kept pace with the overall opioid overdose death rate, likewise quadrupling in number since 1999.
 

 
Naturally, an epidemic this dire has received government scrutiny and as of June 2016, 49 states have either implemented a Prescription Drug Monitoring Program (PDMP) or are in the process of implementing a PDMP. Generally defined, a PDMP is a statewide database which collects data on the dispensation of controlled substances within the state. The information is then provided to professionals, such as health care providers, to deter drug abuse and diversion, and to identify and treat individuals addicted to prescription drugs.

The means of reporting and sharing prescription drug data vary from state to state but today, we are going to talk about Pennsylvania's PDMP. In August of 2016, clinicians in Pennsylvania had to utilize the state PDMP database when prescribing a controlled substance to a patient for the first time or when there was reason to believe the patient was suffering from addiction or might be diverting a controlled substance. As of January 2017, clinicians were then given the added requirement to use the state PDMP database each and every time an opioid drug product or a benzodiazepine was prescribed, regardless of whether or not the medication was a first-time prescription.

Of course, none of this should be new to our customers in Pennsylvania, but what is new are some of the changes made in Rexpert in order to assist with the PDMP process in that state. There are a number of screens in Rexpert where prescription information is stored, such as Prescription Maintenance, Account Registration, and Medications/Prescriptions. New check boxes on these screens allow you to denote whether a prescribed medication is an opioid, a benzodiazepine, or some other controlled substance.

Also on the screen are a PDMP Query button which will take technicians directly to the Pennsylvania PDMP portal, and a Date/Time/User stamp to document that the PDMP database query and/or report was indeed performed. An example of the new PDMP-related features can be seen above. That should make compliance with the state requirements a bit easier for our customers; but frankly, we are just glad to do our little bit in the war against the devastating opioid epidemic.

And to our customers who are not in Pennsylvania: let us know (via the Customer Feedback button) if your state implements any new PDMP requirements so that we can assist you in complying with the new requirements. Likewise, let us know if we can assist with any existing PDMP protocols.

Taxonomy NJ

Greetings to all our customers in New Jersey. As you may already be aware, on April 1st, 2017, Horizon NJ Health is requiring all providers to include their taxonomy codes on claims for proper reimbursement. If you weren't already aware, you certainly will be when all your claims get cruelly rejected like your first screenplay. But that would be learning the hard way, now, wouldn't it? An easier way would be to read this post about how Rexpert can help you!

First, a little background explanation. All health care practices and providers must have a National Provider Identification number (NPI) assigned by the Center for Medicare and Medicaid Services (CMS). However, they also have a second number known as the Taxonomy Code which identifies the type and area of specialization. The change coming up in New Jersey is that both the NPI number and the Taxonomy Code must be included when submitting a claim to Horizon NJ Health.

If you are unsure about a Taxonomy Code, you can look it up on the CMS NPI registry website by using the practice or provider's NPI number. Scroll down, almost to the bottom of the screen, and when you see a section labeled "Taxonomy", there is your first clue that the epic quest for yon Taxonomy Code has been completed. 

You'll need to add taxonomy codes the practice and to each provider. Here are the steps:

Go to Settings > People and Places > Practice. Click on Billing Numbers on the upper right.

Click the new record icon (looks like a green plus-sign on the left task bar) to add a new number. Type in NPI#  for the Payor Group and select Special for the ID type. Type in your practice taxonomy code in Number/Code and check Electronic Claims and Participating. All other fields shall remain blank. Press the save button and exit.

 

Now, go to Settings > People and Places > Provider. Just like before, click on the Billing Numbers button located to the upper right and repeat the same steps as detailed in the preceding paragraph for each provider.

The last little step in this process is to activate the payor. Go to Settings > People and Places > Payor and find the payor needed for changes. Select Payor Options 1 tab, and press the Edit button. Check off the box on the left top corner labeled Taxonomy: Report all provider taxonomy EC boxes 24j, 33b. Save and exit and that's it, all finished!

MIPS, Part 2

"Today, we are going to talk about improvement activities", which sounds a lot like something my mother would have said back in my teenage years. I don't know what else she said after that opening line because that phrase was guaranteed to make me think of other things and generally tune her out. But we are all adults here, so I know I will have your full and undivided attention when I say "Today, we are going to talk about improvement activities" in the MIPS sense of the phrase.  And, just to add further interest, we'll cover Advancing Care Information as well.

Formally, Improvement Activities are designed to reward providers for care focused on care coordination, beneficiary engagement, and patient safety with your improvement activities score comprising 15% of your total MIPS score.

According to the MIPS website, there are only two things that need to be done. Access the  MIPS Improvement Activities page and select the activities that best fit your practice. Please note that activities are designated as high weight or medium weight. For practices consisting of less than 15 clinicians, 1 high weight or 2 medium weight activities need to be selected. Practices with 15 or more providers should select up to 4 activities equaling 40 points (medium weight is worth 10 points each and high weight is worth 20 points each). You will then attest to completion of the selected activities for a minimum of 90 days.

We recommend that you use

• Administration of the AHRQ Survey of Patient Safety Culture
• Collection and use of patient experience and satisfaction data on access

There are a grand total of  92 activities listed on the MIPS website from which you can make your selection.  Rather than read all 92, you can search by keyword, subcategory name, and activity weighing (medium and high weight are the two categories), See the picture below for an example of filter options.

In the above example, a search by keyword (Vitamin K), Subcategory Name (Population Management), and high Activity Weighing yields only one activity: Anticoagulant management improvements. Clicking on the activity will then display specific definitions and criteria for meeting the activity requirements.

And now, lets move on to Advancing Care Information. You will want to consult your EHR provider about this category. For our AuroraEHR users, you should be able to use Aurora just as you did for 2016.

The big change from years past is that the pass/fail scoring system no longer applies. Instead, a more rigorous grading system will be in effect; it's kind of like the difference between report cards from high school and kindergarten. For example, under the previous pass/fail system it was possible to pass with just 10% of patients getting Patient Education materials.  Now, if 11% of patients get the materials, you will get only 1out of 10 points, and if you hit 100%, you will get 10 out 10 points. We can foresee that this will cause some difficulties with certain measures, such as those involving the patient portal.  Fortunately, the scoring is set up so that many extra points are available.  So, the emphasis is now on complete usage, not merely getting a "pass" grade which again, sounds something like my mother used to say back when I was a teenager!

MIPS, part 1

MIPS came to stay with us January 1st,  which made the customarily cheery "Happy New Year" salutation ring a little hollow for our EHR clients.

However, not to worry. CMS has published a 962 page proposed rule with the rather unwieldy name "Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive under the Physician Fee Schedule, and Criteria for Physician-Focused Models" or MBIPSAPMIUPFSCPFM for short.

If reading 962 pages of government-speak (a guaranteed cure for insomnia, by the way) seems daunting, never fear, Practice Alternatives is here. We are the lucky sods that had to read all 962 pages of the proposed rule and accordingly, will make the required software changes.

MIPS has several areas in the program: Quality, Improvement Activities, Advancing Care (replacing Meaningful Use), and Cost (will not be implemented in 2017). Today, we are going to talk about the Quality aspects of MIPS.

Before we get into the Quality stuff, let's cover a few basics about MIPS. The level of participation in MIPS is up to each practice but there are consequences to the level of participation or lack thereof:

1. Do nothing and receive a negative 4% adjustment in 2019
2. Submit some data and receive a minimum or zero payment in 2019
3. Participate for 90+ days and receive a small positive payment adjustment in 2019
4. Participate for a full calendar year with high scores (>= 70 points) to qualify as an "exceptional performer"; doing so could result in a significant payment bonus

The Quality Measures are very similar to PQRS, so this part of MIPS shouldn't be too daunting. Each practice should visit the CMS Quality Measures web page (Click on this link to access the page) and review the Specialty Measure Set list. See below for the screenshot:

Select the specialty that pertains to your practice and the website will display a list of applicable measures:

 Click on a measure, and the criteria for the measurement will be displayed:

You need to pick six measures or qualify for exceptions.

If you are a practice which uses AuroraEHR, contact us and let us know which measures you are planning on using. We will then customize your screens and implement the data tracking as required by the measurement criteria.

That's it for now, and Happy MIPSing!