Wednesday, May 29, 2019

5 Tips to Help Speech, Occupational and Physical Therapists Get Paid

Ensuring accurate reimbursement is no small task for today’s speech, occupational, and physical therapists. Billing codes are updated annually, payer requirements change frequently, and out-of-pocket costs for patients continue to increase. It’s the perfect storm of challenges that can make or break your busy therapy practice.


The good news is that there are several ways in which therapists can protect the revenue they generate. Following are five tips to consider in 2019 and beyond.

1. Know whether you’re required to participate in the Merit-based Incentive Payment System (MIPS).


Starting in calendar year 2019, speech, occupational, and physical therapists became eligible clinician types. This means these therapists are now required to participate in MIPS if they see more than 200 unique patients with Medicare Part B and provide at least 200 Part B-covered professional services totaling more than $90,000 annually.

Therapists who are required to participate—but fail to do so—will see a seven percent payment reduction for Medicare Part B services starting in 2021. Alternatively, therapists could earn up to a seven percent bonus for favorable participation. Use this resource from the Centers for Medicare & Medicaid Services (CMS) to verify your participation status.

Nancy Rothenberg, vice president of PTPN, provides several tips to help speech, occupational, and physical therapists achieve success under MIPS:
Use an electronic health record (EHR) that will allow you to submit relevant quality measures to the registry or qualified clinical data registry (QCDR) if you intend to use either of these data submission methods. Note that any practice can use these methods, but large practices (i.e., those with more than 15 therapists) are required to use one or the other.

  • Retain documentation of improvement activities in the event of an audit.
  • When reporting quality measures, be sure to include the correct ICD-10-CM, CPT, and CPT II codes on the claim or when submitting data to the registry or QCDR. These codes are what trigger the quality measure and include or exclude that measure in the reporting process. If you outsource your billing, ensure that your billing company is aware of these codes and reports them appropriately.
  • Review any feedback that CMS or the vendor submitting data on your behalf provides, and make operational adjustments as necessary. This feedback is an important source of information that can help you achieve bonus payments and avoid penalties.

2. Know how changes to the Affordable Care Act could affect your practice.


Starting this year, individuals are no longer penalized for failing to obtain healthcare coverage, which means some of a therapist’s patients could move into a true ‘self-pay’ status, says Aimee Heckman, healthcare business consultant at Ease RCM Solutions. Best practice is to verify eligibility before each visit, and collect payment at the time of service, says Heckman. This is true for all patients—including those with insurance—and especially those with high deductible health plans.

Collecting at the point of service is always critical, but it’s especially important during the first few months of the year when deductibles reset, and most patients essentially become self-pay, she adds. Given the volume of services that therapists render, charges can add up quickly. Once a patient receives services and leaves without paying, the chances of collecting that money decreases significantly.

3. Don’t forget to monitor payer denials.


Nobody wants to spend time looking at denials; however, the reality is that denial management is an essential step in terms of mitigating future revenue loss, says Heckman. Look at the remark code for each denial. If possible, correct the error and resubmit the claim. Be sure to address the root cause of the denial so you don’t continue to lose revenue.

4. Review your fee schedules, renegotiate contracts.


Look at the fee schedule for the top five to 10 CPT codes you billed in the last 12 months. What’s the average charge vs. payment for each of these codes by payer? Doing this helps identify your lowest vs. highest paying payers. Leverage your value and what you bring to the table in terms of care quality and cost reduction, says Heckman. Don’t be afraid to walk away if the payer won’t budge, she adds. 
 

5. Provide patients with a variety of payment options.


The days of sending a bill in the mail and expecting to receive a check a few days later are long gone. Instead, patients expect the same bill pay conveniences they experience in other non-healthcare industries, says Heckman: Credit/debit card on file, online payment, and mobile app-based payments. The more options you provide, the more likely you will be to collect the revenue to which you’re entitled, she adds.

Helpful Resources


Centers for Medicare & Medicaid Services: https://qpp.cms.gov/
American Physical Therapy Association: http://www.apta.org/MIPS/
American Speech-Language-Hearing Association: https://www.asha.org/practice/reimbursement/medicare/the-medicare-quality-payment-program/
American Occupational Therapy Association, Inc.: https://www.aota.org/Practice/Manage/value.aspx
Support for small, underserved, and rural practices: https://qpp.cms.gov/about/small-underserved-rural-practices

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Friday, May 24, 2019

The Executive Suite: How to add more care to your treatment

The Executive Suite: How to add more care to your treatment: Physicians are by nature compassionate people. But sometimes life can get in the way of the ability to consistently exhibit care, cand...

Thursday, May 23, 2019

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Wednesday, May 22, 2019

Tuesday, May 21, 2019

Monday, May 20, 2019

The new Anti-Kickback Statute that most Medical practices don’t know about

Is your practice compliant with The Eliminating Kickbacks and Recovery Act of 2018 (EKRA)? If you are asking, “What is the EKRA?” you are not alone—and that is part of the problem.


EKRA is part of the Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities Act (SUPPORT for Patients and Communities Act) that President Donald Trump signed into law Oct. 24, 2018.

On the surface, EKRA may appear to be just a rehash of the federal Anti-Kickback Statute that applies to a subset of behavioral health service providers. However, EKRA’s broad definitions of a “healthcare benefit program” and “laboratory” makes the law potentially applicable to almost all physician practices and clinical laboratories.

As its name infers, the EKRA and SUPPORT for Patients and Communities Act was initially intended to be centered on behavioral health services, specifically the problem of “patient brokering” at certain treatment centers, usually in the area of addiction treatment. This means a third party enrolls a patient who needs addiction treatment into a private health insurance plan and then coordinates the patient’s entrance to a treatment facility in exchange for a payment, or kickback. Since commercial insurance is not subject to the federal Anti-Kickback Statute, and many states have little or no additional state level protections, patient brokering has become a widespread practice.

EKRA was drafted to combat this problem and protect a potentially vulnerable patient population. EKRA mirrors language in the Anti-Kickback Statute that specifically prohibits knowingly and willfully soliciting, offering, paying, or receiving anyremuneration in return for referring a patient or patronage to a recovery home, clinical treatment facility, or laboratory. (See 18 USC (a)(1) & (2)). Penalties for each occurrence of violating this law include fines up to $200,000, imprisonment for no more than 10 years, or both.

Most physicians who are not actively involved in behavioral health may not have much interaction with recovery homes or treatment facilities. Physician practices, however, inevitably have countless interactions with laboratories, which the statute defines as to have the same meaning as used in the Clinical Laboratory Improvement Amendments (CLIA). As such, the statute’s prohibition applies to any remuneration associated with any referral for such services, whether or not the laboratory test is related to addiction treatment or recovery.

Furthermore, EKRA is not limited to only federal healthcare programs, such as Anti-Kickback Statute and Stark Law. Rather, the statute applies to any “healthcare benefit program,” defined as any public or private medical benefit plan or contract, i.e., all commercial insurance plans. This is a significant expansion of federal law from what has historically only been subject to state level oversight.

Similar to the Anti-Kickback Statute, EKRA also grants some statutory exceptions to permit certain relationships. These exceptions mirror a number of Anti-Kickback Statute’s safe harbors, including discounts, personal services, and management contracts. However, there are some notable exceptions.

Most importantly, unlike the Anti-Kickback Statute that provides a safe harbor for any amount paid by an employer to an employee with whom there is a bona fide employment relationship, EKRA only exempts compensation when the employee’s and independent contractor’s reimbursement does not vary by the number of individuals referred, the number of tests or procedures performance, or the amount billed or received. (See 18 USC, 220 (b)(2)). As such, the limitations on compensation for independent contractors and employees are essentially the same.

This is dramatic shift from the precedence under the Anti-Kickback Statue that generally allows commissions or percentage-based compensation to employees but not independent contractors. Physician practices and clinical laboratories, as a result of this new ban, will need to re-evaluate their compensation methodology for employees and referring physicians to ensure such reimbursement complies with the EKRA’s more stringent requirements.

For example, physician practices who self-refer to their own laboratory will now, in addition to Stark Law, need to ensure their compensation to employed physicians will not vary based on the number of referrals. Similarly, clinical laboratories will be prohibited from paying their marketing employees on a commission basis. This applies even if physician practices and clinical laboratories have taken steps to ensure they are not treating patients covered by a federal healthcare program. EKRA expressly applies to all health plans.



We must wait and see whether this significant expansion of prohibited conduct, which is well beyond the targeted behavioral health industry, will be limited by Congress or whether future regulations promulgated under this law will provide additional safe harbors. In the meantime, since EKRA is now in effect, physician practices and clinical laboratories need to be attentive to and ensure their operations are in compliance with this new law.

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