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The U.S. Senate recently gave final congressional approval on legislation extending Medicare’s Sustainable Growth Rate (SGR) payment formula. The SGR formula, which is designed to balance the target and actual expenses of Medicare, will be in effect for 12 months, expiring March 31, 2015. The bill is not a permanent repeal of the actual SGR formula.

Congress has voted 17 times in the past 11 years to approve a measure to avoid a steep drop-off in Medicare payments. Each vote resulted in a patch that served as a temporary solution to determine Medicare funding levels. This patch differentiates from those in the past because considerable political capital was spent to attempt to overhaul the funding formula and replace it with a model that will accurately predict Medicare’s funding.

Current provisions now include legislation to prevent a 24 percent cut in physician fee schedule payments from occurring. In addition to delaying the SGR’s previously planned cuts, the legislation also:

  • Delays the implementation of the new ICD-10 coding system until Oct. 1, 2015.
  • Extends the temporary two percent ambulance bonus payments until March 31, 2015.
  • Provides a 0.5 percent Medicare pay bump over the 12-month period.
  • Revalues certain physician payment codes.
  • Implements requirements for providers to consult physician-developed appropriateness criteria when prescribing advanced imaging procedures for Medicare patients.
  • Postpones a requirement for hospitals to comply with the "two-midnight" rule for inpatient reimbursement.
  • Delays recovery audits of allegedly unnecessary claims until March 2015.
  • Starting in 2017, total downward relative value unit adjustments (cuts) promulgated by the Centers for Medicare and Medicaid Services (CMS) for a service of 20 percent or more (as compared to the previous year) will be phased in over a two-year period.

The legislation awaits President Barack Obama’s signature in order to become effective. The President has indicated that he will sign the legislation once it reaches his desk.

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Since 2011 the U.S. government has distributed more than $17 billion in federal subsidies to hospitals, doctors’ offices and other providers to adopt adequate electronic medical record keeping protocols. While the use of technology is encouraged and promoted by the government and by the health care industry as a whole, it must be approached with caution. As patient care becomes more intertwined with technology, an emerging concern is the inappropriate use of federally subsidized electronic patient record systems by providers in order to increase reimbursement. One of the primary inappropriate uses is the simple act of copying and pasting information.

Copying and pasting potentially out-of-date information into patients’ electronic medical records can impact patient care, create miscommunication and cause medical records to become indecipherable. Copying progress notes rather than creating new, original notes can perpetuate inaccurate and outdated information. Ultimately, copying and pasting has the potential to create serious clinical consequences. Consequences that may ensue due to copying and pasting include:

  • The propagation of erroneous information
  • Difficulty in finding relevant information
  • Unnecessarily long progress notes due to the inclusion of irrelevant information
  • Patients or insurance companies possibly being billed incorrectly, which can lead to payer audits and fraud allegations.

All of these potential consequences can compromise patient safety and make it more difficult for other medical providers to interpret prior notes and decipher what the patient’s current condition is and what medical issues have already been resolved.

Copying information from prior information and notes may be appropriate in certain instances when, for example, the information is based on external sources such as basic demographic information, the information is clearly distinguished from the original data entry, or the information will not become part of the medical record until after undergoing a re-authentication process.

In order to combat the issue of copying and pasting, it is important that the following steps are adhered to by medical providers and their teams:

  • Define Electronic Medical Records’ content standards. Once defined, the content standards are to be developed and implemented to ensure consistent application and the inclusion of current medical records.
  • Promote proper clinical documentation practices, carefully monitor compliance, conduct internal audits and require source attribution for all copied text.
  • Explain the risks of duplicating an error multiple times due to copying and pasting and adopt a zero-tolerance policy for unethical documentation practices.
  • Craft effective policies and implement a data entry workflow that does not require that the same information be entered in multiple places, which often causes the urge to copy and paste.

Shortcuts such as copying and pasting patient information and copying progress notes must be eliminated in order to ensure patient safety, as well prevent improper billing and violations of patient privacy rights pursuant to HIPAA rules and regulations. Taking time to learn your electronic recordkeeping system is imperative and will alleviate the need to resort to shortcuts.

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When disasters hit, chaos tends to follow. Emergency managers have successfully utilized social media at the core of their preparedness efforts in order to effectively communicate during disastrous events. Social media has made it possible to make smart decisions and spread information instantaneously that can in turn save lives. The use of social media to aid emergency management includes steps to broadcast important safety information, correct misinformation and build situational awareness. Recently, social media served as a means of conversing and engaging with communities around the world in the wake of the devastation wrought by Typhoon Haiyan in the Philippines. Twitter, Facebook and Instagram posts aided in informing the world about Haiyan and its effects, and encouraged individuals to support relief efforts. Volunteers around the world used social media to provide aid workers in the Philippines with pertinent information such as real-time maps of who needed help and where. With a lack of telephone capabilities, social media provided a connection between families seeking news about their loved ones’ status. Emergency management was improved in speed and effectiveness of relief efforts, and social media served as a two-way information flow that helped with tactical decisions. The benefits of using social media for emergency management are very clear, and emergency managers can strategically start to incorporate social media into their communication plans by integrating the following suggestions to disseminate information and provide critical information for resource deployment.

Start by Asking the Right Questions

Many emergency management communication plans include tried and true methods of reporting such as television and radio. As a result, diving into new media can be intimidating. Before opting to use social media as an official means of communication, it is important for your team to analyze and question what kind of information will be shared, define your targeted audience and plan how you will keep the information up-to-date. To get started, make sure to ask yourself the following questions:

  • Why are we using social media during emergencies?
  • What are the benefits of social media?
  • How could past emergencies have benefited from social media?
  • What are the procedures during an event?
  • Who will respond to and monitor our social media?
  • What are the pros and cons between social media and our traditional media

Figure Out What to Say

After answering the right questions, it is important to begin to compile the types of posts you want to share with your audience to effectively utilize your social media accounts. When a disaster occurs, the content you post should inform the largest number of individuals in the least amount of time about the most pertinent information that they need to know. Here are some examples of information that can be provided through social media outlets when a disaster occurs:

  • Power outage updates and estimated restoration times
  • Emergency shelter locations
  • Disaster assistance definitions and updates
  • Transit information and roadway status
  • Significant weather alerts and warnings
  • Boil water advisories
  • Dry ice distribution locations and times
  • Health Department safety recommendations
  • Federal Emergency Management Agency (FEMA) assistance availability and contact information

In the past few years, social networks have played a growing role in successful communication during disasters. From locating missing loved ones to coordinating on-the-ground operations, social media serves as a hub for sharing important information with the public. There is no question that the convergence of social media and new technology is now an important part of preparedness planning. The steps laid out above are key to ensuring your agency’s successful adoption of social media.

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As an alumna of the Tepper School of Business at Carnegie Mellon University, I was recently invited to participate in a panel discussion along with other alumni leaders in the health care and bio-pharmaceutics industries. The audience included second year MBA students and distinguished graduates.

We talked about the impact of the Affordable Care Act on job prospects and how opportunities are plentiful for people with strong analytical skills in today’s world of big data and a passion for making a difference. Additionally, we discussed the importance of innovation to address the present inefficiencies and to improve the inter-connectivity of patients, care providers and payers.

As the evening progressed, I had the opportunity to engage in dialog regarding the critical role that revenue cycle and practice management companies can play in the changing health care landscape when it comes to supporting physicians and funding America’s health and safety net. Physicians continue to be a scarce resource and, as a result, need to focus their time and attention on clinical care in order to improve health care delivery. Partnering with trusted third parties that provide practice management services enables physicians to focus on patient care instead of worrying about the business needs of their practice. It was interesting to see the audience come to the realization that revenue cycle management services are a key component to the future our health care system. Without sophisticated technology-driven processes, it’s going to be increasingly difficult to collect fees from patients and payers that can be reinvested to improve patient care.

The health care panel discussion certainly shed light on the promising next generation of leaders who have the passion and drive to make an innovative impact on the health care challenges that we face. Ultimately, they will build upon the successes that current leaders have achieved. The Affordable Care Act has and will continue to drastically change the operating environment for health care providers, patients and payers.

Taking it to the Next Level – Enhanced Practice Management

This discussion reinforced to me that my company’s investment in enhanced practice management capabilities has come at the right time. Now, more than ever, physicians need broader support from partners in order to ensure financial success while focusing on clinical care. Intermedix has broadened its focus to not only provide physicians with the revenue cycle management services it has provided for years, but also to take a more holistic approach by providing the full spectrum of business management services. By merging both revenue cycle and business services management into one enhanced practice management umbrella, physician practices will be able to continue to adapt to the ever-changing health care landscape.

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Late Wednesday evening, the House and Senate approved and sent to the President legislation ending the government shut-down that has been in effect since Oct. 1. The President signed the law late Wednesday night.

All federal employees who had been furloughed have been directed to return to work as of Oct. 17. The legislation authorizes back pay for all furloughed federal employees retroactive to Oct. 1. As a result, all federal employees will be made financially whole for the lost time. If a federal employee applied for and received unemployment benefits during the period of their furlough, they will have to pay back any unemployment compensation received.

The legislation extends the current FY 2013 spending levels through Jan. 15, 2014. In addition, the legislation extends the authority of the federal government to borrow money sufficient to cover expenses in excess of revenue through Feb. 7, 2014. The legislation also grants the Treasury Department additional “special” authority that could delay the need to raise the Debt Ceiling until approximately mid-March.

Because this is only a temporary extension of the spending authority, the Congress and the President must again resolve their differences with regard to discretionary spending between now and mid-January. If Congress and the President fail to reach an agreement on appropriations, we could be looking at another government shutdown in early 2014.

There are two other aspects of this “resolution” that cannot be overlooked:

Sequester

By law, if federal discretionary spending approved by Congress exceeds the $967 Billion cap, across the board cuts in discretionary spending sufficient to lower total spending to the authorized level must commence. This means that prior to Jan. 15, Congress and the President will have to agree on new spending levels consistent with the $967 Billion cap OR there will have to be a sequestration of approximately $20 Billion between non-defense discretionary spending and defense discretionary spending. However, unlike the 2013 sequestration (i.e. ½ from non-defense domestic and ½ from defense), the amount would not be equally divided.

For a variety of reasons, the additional money being spent in Fiscal Year 2014 is largely due to higher defense spending. Consequently, the vast majority of any sequester related spending cuts that might occur in 2014 should come from defense spending, not domestic discretionary spending.

Budget Negotiations

As part of the agreement to end the budget/spending stalemate, the House and Senate have agreed to convene a formal budget Conference with an expectation that the Conference will yield recommendations by Mid-December. The hope is that the Conferees will come up with bi-partisan recommendations for changing or modifying the existing sequestration process mandated by the Budget Control Act. However, there is no requirement that the Conferees reach an agreement nor is there any consequence (other than maintenance of current sequester law) for failure to reach an agreement.

It is highly likely that if there is a bi-partisan agreement to change the defense or non-defense discretionary caps, this will be done in a way that would not result in a higher deficit. In other words, the Conferees could restore some of the mandatory cuts in discretionary spending with additional cuts in entitled spending (i.e. Medicare and/or Medicaid) or through higher taxes.

So while the budget negotiations may create a ray of hope for those who want to see defense and non-defense spending restored, these same budget negotiations create a vulnerability for health care providers who could see additional cuts in Medicare spending as a way to offset the restoration of already approved cuts in discretionary spending.

Conclusion

After shutting down the federal government in an attempt to defund or delay Obamacare, the Republicans ultimately did not win any substantial changes to the health care reform law as part of the agreement to reopen the government and raise the debt ceiling. The reopening of the government will allow normal functions to resume in the coming days (as backlogs are dealt with). However, this is only a temporary resolution of the budget problems and the proverbial “can has just been kicked down the road.”

 

A version of this post was originally published by the Healthcare Billing and Management Association (HBMA). Bill Finerfrock is Senior Vice President of Health Policy with Capitol Associates and has been working with the HBMA for more than 10 years.

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The federal Fiscal Year runs from Oct. 1 through Sept. 30.  This means that Fiscal Year 2014 begins on Tuesday, Oct. 1.  In order for the government to operate, the Congress must pass and the President must sign appropriations bills that release the money necessary to fund the operation of the federal government. 

To date, not a single one of the 12 appropriations bills required to fund the government have been signed into law.  Among other things, this means that as of midnight tonight, there is technically no money available to pay the salaries of federal employees (including Members of Congress and their staff), pay the utility bills for government buildings or fund grants made by the federal government.

In lieu of enacting 12 separate appropriations bills, the Congress is debating the approval of what is called a “Continuing Resolution” or CR.  This is legislation that effectively extends the 2013 Fiscal Year for whatever amount of time the Congress and President agree to “continue” operations.  A CR can be anywhere from a single day to a full year. 

As you have no doubt been hearing, there is a distinct possibility that the Congress and President will fail to reach agreement on adoption of the Continuing Resolution by midnight, tonight.  Should that occur, the effect of this will be that all “non-essential” federal employees will be told that they don’t need to show up for work tomorrow, Oct. 1.     

This has raised questions about the ability of the Medicare program to process Medicare claims after Oct. 1, 2013 in the event the impasse persists and a government shut-down occurs.

Because the money used to pay Medicare benefits is not subject to the appropriations process (it is an entitlement program not a discretionary program) and the processing of Medicare claims is deemed “essential,” the Centers for Medicaid and Medicaid (CMS) has announced that there should be no disruption in the processing and payment of Medicare claims.  In fact, most CMS activities of will continue despite the appropriations impasse.

According to a recent announcement by the Department of Health and Human Services (HHS), the parent agency for CMS, the only CMS activities adversely affected by a government shutdown would be: 

  • CMS would be temporarily suspend funding for the health care fraud and abuse strike force teams; and,
  • CMS would conduct fewer recertifications and initial certifications for providers subject to Medicare survey and certification.

Finally, it should be noted that this appropriations impasse is unrelated to the upcoming Debt Limit debate that will ensue in a few weeks.  Like the Appropriations problem, the failure of the Congress and the President to agree on legislation raising the Debt Limit could also result in a government shut down.

A version of this post was originally published by the Healthcare Billing and Management Association (HBMA). Bill Finerfrock is Senior Vice President of Health Policy with Capitol Associates and has been working with the HBMA for more than 10 years.

Tagged in: Healthcare
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Oct. 1 marks a major Affordable Care Act, or "Obamacare" milestone. It's the first day that those who are currently uninsured can use the Healthcare Insurance Marketplace to find health care coverage options available to them. The Healthcare Insurance Marketplace is designed to help Americans obtain affordable health care through subsidized national plans. Depending on the state the person is in, he or she can both apply for and enroll in coverage on the Healthcare Insurance Marketplace page or visit a state-specific page.

The government hopes to enroll more than 7 million people who are currently uninsured for coverage in 2014. For those of us working to collect unpaid patient balances, this seems to mean we would receive more reimbursements from the current “self-pay” population. But, while Republican criticism and Democratic optimism has taken control of the news for quite a while now, neither party can predict what the real enrollment results are going to be.

In order to evaluate the likelihood of our clients’ reimbursements increasing as a result of the implementation of the Healthcare Insurance Marketplace, we did what any sensible person would do we created a pro/con list.

Pros

  • Americans can evaluate their options in one place. Government programs such as Medicare, Medicaid and Tricare are all listed and considered in one central location.
  • The Healthcare Insurance Marketplace plans have a standard level of coverage that includes emergency healthcare and cannot exclude people with pre-existing conditions.
  • The Healthcare Insurance Marketplace plans are subsidized for those whose income is currently between 100 and 400 percent of the national poverty level.
  • Options are customized based on an individual’s needs and location.

Cons

  • The Navigators assisting individuals with the options may not receive comprehensive training; several have not even been hired yet.
  • The current, tax-based penalty for not obtaining health insurance is often less than the annual premiums.
  • Employers may currently offer "affordable" care that would disqualify an employee from a subsidy available on the marketplace.
  • The premiums are not subsidized for people earning less than 100 percent of the national poverty level. There are 20 states that are currently not offering Medicaid to this group, leaving a gap of people who likely still can't afford health care.


It's not easy to predict how exactly the marketplaces will affect enrollment. The good news is that we don’t need to wait much longer to find out. In the meantime, we can certainly hope for the best and suggest to patients who are currently a part of the uninsured population to check out what the Healthcare Insurance Marketplace has to offer. Want to see the marketplace for yourself? Go to www.healthcare.gov.

 

 

Tagged in: Billing Healthcare
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We criticize reality shows because they seem to over dramatize reality. As we watch these shows, we truly believe there is no way that is how things really happen in that person’s life. While it may seem peculiar to compare reality shows to disaster exercises, I have participated in or conducted numerous exercises over the past 20 years and have heard similar criticism, such as “That just couldn’t happen HERE,” or “Come on, things don’t happen like that in real life.”

Have you ever questioned whether an exercise needs to be more realistic to test your organization’s “real” response capabilities? I understand those who believe the exercises need to be more realistic, but what should we do when the most unrealistic scenarios become reality? Let’s look at a few real world examples.

The Examples

July 19, 1989: Sioux City, Iowa

In 1987, the Sioux Gateway Airport personnel held a disaster drill in which they pretended a wide-body aircraft crashed on a closed runway with 150 survivors, even though the airport didn’t serve wide-body jets. The drill’s After Action Report identified short-comings including the fact that, if there were 150 survivors, the airport would not have enough support equipment. Following the exercise, the airport directors reached out to the surrounding community to make sure the airport would have enough support in case a scenario like the one they prepared for ever took place.

Two years later, at approximately 3:15 p.m. on July 19, UA Flight 232’s tail-mounted engine fan disk disintegrated and the pieces penetrated the Douglas Aircraft DC 10’s tail section rupturing the hydraulic lines supporting the control systems of the aircraft. Without any of the systems normally used to control a plane, the flight crew not only managed to keep the plane airborne for 45 minutes, but somehow maneuvered it into a final approach at the Sioux Gateway Airport. Unfortunately, with no way to control its rate of descent, the plane slammed onto the field, broke apart, and the entire hulk slid down the runway into a neighboring a corn field. Miraculously, 184 of the 296 individuals on board survived the crash.

March 1-2, 2007: Americus & Atlanta, Ga.

b2ap3_thumbnail_bus.jpg

At approximately 9:25 p.m. on March 1, 2007 an EF-3 tornado erupted out of the clouds and struck the City of Americus causing $100 million in damages to Sumter Regional Hospital. The 143-bed, acute-care hospital was completely destroyed. At the time the tornado struck, the hospital had 70 inpatients.

The Georgia Division of Public Health’s Hospital Preparedness program was notified of the situation by 9:45 p.m. and immediately started working with other hospitals in southwest Georgia to find beds for each patient. By 1:30 a.m. the evacuation of Sumter Regional Hospital was complete.

At 5:38 a.m. on March 2, 2007, a chartered motor coach carrying 33 members of the Bluffton University baseball team was traveling southbound in a left-hand HOV lane of I-75 in the Atlanta metropolitan area. The driver mistakenly entered a left HOV-only exit ramp that led upward to a T-junction marked by a stop sign. The bus, traveling at highway speed, was unable to stop or turn, sliding sideways into a concrete bridge wall and chain-link security fence. The bus fell 19 feet, landing on the Interstate highway below.

Even though the Georgia Division of Public Health’s Emergency Operations Center was fully open and still very actively engaged in supporting response efforts in Americus, it now had to respond to a mass casualty incident 150 miles distant, coordinating with a different set of responders and hospitals.

The division’s EOC is located within the headquarter building in the heart of downtown Atlanta, a relatively quiet area at 6:30 a.m. However, as personnel arrived at the EOC that day to work the day shift, the street in front of the headquarters was blocked by police and fire emergency vehicles. In an unrelated incident, a passerby suffered a heart attack and collapsed almost in front of the main doors to the building. This delay was a significant hindrance to the continual response to both incidents.

Moral of the Story

How unlikely are the scenarios just described? The answer is extremely unlikely, but the reality is that they both happened.

Drills and exercises are designed to evaluate our plans, to identify weaknesses and to generate improvements in our overall readiness. Sometimes the scenarios may seem a bit contrived or unrealistic, but disaster can’t be predicted with certainty and being prepared for those scenarios can save lives. So next time you are going through an unrealistic exercise, remember that it never hurts to be prepared.

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Today we close our series on HIPAA’s Final Rule and its most significant changes that may impact your organization. We already explored the changes to breach notification requirements and business associate agreements, and in this post we will be talking about the most straightforward changes in the Final Rule surrounding the Notice of Privacy Practices.

The Notice of Privacy Practices, or NPP, is a list of permissible uses and disclosures that is given to a patient by his or her healthcare provider explaining the use of the patient’s protected health information, or PHI. While this document has been provided to patients since 2003, the Final Rule requires additions that further limit the use of PHI. Overall, these changes are about empowering patients to be in control of their PHI, and limiting entities’ disclosure and use of such information.

What are the NPP Changes?

Breach Notification. The NPP now needs to include a clause that states that the patient has the right to be notified of a breach of PHI regardless of the covered entity’s or business associate’s ability to demonstrate a low probability that PHI has been compromised. An individual can request an accounting of entities that accessed his/her PHI.

Uses and Disclosures. The patient must now give specific, written authorization for the release of certain documents, such as psychotherapy notes and information to be used for marketing purposes. Additionally, the sale of PHI is strictly prohibited unless the patient has given the appropriate authorization.

Health Plan Disclosure. The Final Rule allows patients to restrict disclosures to health plans concerning treatments for which the individual has paid out of pocket, in full, for the healthcare item or service.

Fundraising Rules. If a covered entity will be engaging in fundraising efforts, the NPP must include language regarding an individual’s right to opt-out of such communication.

Genetic Information. The Final Rule prohibits a healthcare plan from using or disclosing genetic PHI for underwriting purposes. Healthcare plans cannot use genetic dispositions to determine if an insurance policy or prorated policy is given to an individual.

State-Specific Regulations

Something to keep in mind is that, although NPPs are governed by federal law, your organization needs to make sure that your state doesn’t have specific laws regarding privacy rules. A common pitfall many make is abiding by HIPAA and following federal guidelines but not addressing state-specific laws. States such as Florida, for example, have special statutes related to other privacy rights such as social security disclosure protection.

These NPP additions, like the business associate agreement changes, must be implemented by Sept. 23.

Tagged in: Compliance PHI
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Last month, FEMA released its Hurricane Sandy After-Action Report, which highlights strengths and areas for improvement in responding to the natural disaster. This post is an excerpt from the report that focuses on two strengths in the response: the President's expedited Federal disaster declarations and the use of WebEOC. WebEOC is Intermedix's web-based crisis management system.

Ensuring Unity of Effort across the Federal Response

In response to Sandy, FEMA coordinated a large-scale mobilization of Federal teams, supplies, and other assets, both before and immediately after the storm’s landfall. The President emphasized that the full resources of the Federal Government were available to support response and recovery operations and directed Federal departments/agencies to lean forward and cut red tape to speed assistance to survivors. FEMA coordinated expedited disaster declarations for the affected states, helped to establish a task force to restore power and fuel, and accelerated rental assistance for eligible survivors. However, the magnitude of the disaster revealed several areas for improvement related to integrating and coordinating Federal operations—such as better coordinating emergency support functions and refining the mission assignment process. Addressing these areas for improvement will ensure that FEMA and its Federal partners efficiently deliver Federal support.

Strength: The President expedited Federal disaster declarations

The President issued emergency declarations for 11 states before Sandy made landfall on the evening of October 29. The President quickly issued major disaster declarations for New York, New Jersey, and Connecticut the day after the storm’s landfall. Due to the magnitude of the storm, the Governors of these three states made their major disaster declaration requests verbally to the President. While such verbal requests are rare, waiving the written request requirement demonstrated the President’s commitment to ensuring that the Federal Government supported response and recovery operations quickly and cut through red tape.

Strength: Using an online crisis management system to coordinate Federal response operations

During Sandy, FEMA employed WebEOC, an online crisis management system, to coordinate and support response operations at the NRCC. FEMA and its Federal partners used the system for multiple activities, including supporting resource requests from the field, coordinating Energy Restoration Task Force activities, maintaining situational awareness, monitoring and tracking national hurricane plan tasks, and tracking assistance delivered to survivors. Using a single online platform facilitated information sharing and ensured that each section of the NRCC and ESFs shared a common operating picture, contributing to a unified Federal response. In addition, WebEOC facilitated a common operating picture on the status of all orders through a live resource tracking board which consolidated information on all resources shipped to support Hurricane Sandy. Despite Sandy being one of the first implementations of the WebEOC system, more than 60 percent of NRCC personnel rated the system as “effective” or “very effective.”

Sandy also showed areas where the platform can expand to provide a clearer Federal Common Operating Picture, including enhancements of real-time feeds, integration with other Situational Awareness products, and linking to the information of other Whole Community partners. FEMA plans to expand the scope of activities and processes conducted through the crisis management system and continue expanding its use in RRCCs and field locations. Additionally, FEMA is exploring ways to broaden the use of the system across the Federal Government.

This text was originally published in FEMA's Hurricane Sandy After-Action Report. For more information on FEMA please visit www.fema.gov.

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As Chair of the Government Relations Committee for Healthcare Billing and Management Association, an organization that is recognized as the most influential healthcare revenue and management services association, I was able to participate in meaningful discussions with key members of the Centers for Medicare and Medicaid Services, or CMS, during a recent trip to Washington D.C. I was honored to be accompanied by HBMA’s lobbyist, Bill Finerfrock, and association staff members Brad Lund and Sherri Dumford who have diligently worked alongside the government relations committee members to solidify the relationship between HBMA and key CMS leaders. 

When HBMA was first granted the opportunity to meet with CMS officials several years ago the meeting was a few hours long. As the relationship continued to prove beneficial to both CMS and HBMA members, these meetings expanded and this year we were at the CMS office for eight hours! We were privileged to be able to meet with several key CMS leaders, including Jon Blum, CMS’s Principle Deputy Administrator and Director for the Center of Medicare.  

Advocating for End-to-End Testing

A week prior to our meeting CMS had announced that it would not be providing end-to-end testing before going live with ICD-10. CMS is not planning on testing directly with trading partners, vendors, billing services or clearinghouses prior to the full implementation on Oct. 1, 2014. We spent a considerable amount of time discussing the value of ICD-10 end-to-end testing and the significant financial adverse consequences to providers for failure to adequately test.

Combating Fraud

Deputy Director for Policy Ted Doolittle addressed CMS’ Approach to Combating Fraud, Waste and Abuse. The scale of program integrity encompasses a wide range of activities to target the causes of improper and fraudulent payments, including incorrect coding, medically unnecessary service, improper billing practices, such as coding for a level of service greater than what was rendered or documented, and billing for services or supplies that were not provided. Through predictive analytics and provider enrollment and screening, the CMS remains committed to taking prompt action to remove bad actors from Medicare. We shared our concerns regarding assuring that in an attempt to catch the “bad guys” that the “good guys” weren’t adversely affected through actions such as unnecessary or unwarranted audits.

Collaborating for Best Results

During this meeting we also discussed challenges surrounding ICD-10, RACs, Quality Initiatives, Revalidation and MAC’s from a clinical and administrative perspective. Throughout our lively discussions, I was most impressed by the fact that each of the key leaders we had the opportunity to meet with was committed to understanding the needs of the providers and the areas that can be improved so that Medicare beneficiaries continue to receive quality care and providers are paid fairly for the services rendered. These leaders understand that the majority of providers and billing companies are honest and work diligently to provide quality services to patients.  

I hope you take time to read the HBMA CMS/Washington publication, it includes many more details about what we discussed during our trip to D.C.

At Intermedix, we are very fortunate to work for a company that promotes our involvement and leadership in industry associations. I have always received support and encouragement from Doug Shamon, Intermedix CEO, to participate in these organizations. As a company, we realize such involvement enables Intermedix to give back to our industry and bring value to our clients, and we will continue to exert our efforts on issues that directly affect our clients.

Jackie Willett is a Senior Vice President at Intermedix.

Tagged in: Billing ICD-10
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In our first HIPAA series post, we explored HIPAA’s Final Rule and its new Breach Notification Requirements. Today, we’ll explain the Final Rule’s effect on business associates and business associate agreements, known as BAAs.

Under the interim rule, the Department of Health and Human Services could only hold the covered entity liable for a breach, even if this breach had taken place at the business associate level. However, the federal government conducted a study that showed that the overwhelming majority of Protected Health Information, or PHI, breaches took place at the business associate level. According to HHS, a business associate is “a person or entity that performs certain functions or activities that involve the use or disclosure of protected health information on behalf of, or provides services to, a covered entity.”

Overview of Changes

As a result, many changes have been made in the Final Rule to better protect PHI, and to allow for liability to attach downstream to business associates and subcontractors. In these cases, the Final Rule allows the government to investigate the business associate and directly attach liability to it, instead of the covered entity.

  1. Direct Liability. As previously mentioned, business associates are now directly liable for their lack of compliance with HIPAA’s Privacy and Security Rule requirements.
  2. Request Obligations. The business associate must provide the Office of Civil Rights with PHI upon request. In addition, patients now have the right to request electronic copies of their health information.
  3. Minimum Necessity. Business associates and covered entities are obligated to ensure that PHI is released according to the Minimal Necessary standard, meaning that only the minimum amount of information necessary to perform a task can be accessed.
  4. Downstream Liability. The Final Rule has also expanded the scope of the definition of business associates to include subcontractors of business associates. Therefore, business associates must now enter into BAAs with any subcontractor that uses, stores, maintains or transmits PHI and require such party to abide by HIPAA.
  5. Limited Use. The Final Rule places more limitations on the use or disclosure of PHI for marketing and fundraising purposes and prohibits the sale of PHI without individual authorization.

Time is of the Essence

The changes mentioned above must be made by the Sept. 23 compliance deadline. An exception to this deadline is found if an organization had an existing BAA as of Jan. 25, in which case the organization has until Sept. 23, 2014 to comply. It is important to note that, if any amendments are made to the agreement after Jan. 25, the exception is revoked and the organization is required to ensure the agreement is compliant by Sept. 23.

Keep in mind that many organizations are run by a board of governors or county commission that must review the BAA before it is enacted. These organizations will only meet once a month or quarterly, and it may take some time to receive a response. Therefore, it is important to send out agreements as soon as possible.

In our next post, we’ll review the Final Rule’s effect on Notice of Privacy Practices.

Tagged in: Compliance PHI
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Most of you readers, like me, work in businesses dealing with emergencies both large and small every day. So I come to you, a little over a month away from September, to challenge you to take the opportunity of National Preparedness Month to be better prepared at home and at the workplace.

I recently had a friend tell me he heard something about “National Preparedness Month,” that left him with many questions: What is National Preparedness Month? Does it mean people like me are supposed to be doing something to get prepared?

I set out to answer his questions as best I could, telling him that National Preparedness Month is about getting our communities better prepared by encouraging each citizen to learn about preparedness and take personal responsibility to act. According to the Centers for Disease Control and Prevention preparedness is the ability communities have to prepare for, withstand and recover, in both short and long terms, from incidents. Following the 9/11 tragedies, the U.S. Department of Homeland Security has designated the month of September as National Preparedness Month for the past five years to remind and encourage each of us to prepare for emergencies.

So I ask each reader, are you better prepared than you were on Sept. 11, 2001? Are your family, friends and community prepared? From Hurricane Katrina to Superstorm Sandy to the Oklahoma City tornadoes, we have seen enough disasters in the past few years to know that they can hit anywhere at any time.

How can I prepare?

The Be Red Cross Ready website created by the American Red Cross is a great resource, which outlines three ways we should prepare: Get a kit. Make a plan. Be informed. I personally ask myself the five questions below:

  1. What disasters are most likely to strike my hometown?
  2. Does my family have an emergency plan?
  3. Do I have a "Go Kit?"
  4. Does someone in my household have first aid training?
  5. Have I helped my community get better prepared?

Join the Movement

What can you do to join the National Preparedness Month movement? Last year, 1,800 National Preparedness Month coalition members worked to create a culture of emergency preparedness in the United States by hosting at least 1,000 events and initiatives during and around September. You can join the coalition or learn about activities by visiting FEMA’s National Preparedness Community page. Organizations in your community are already getting ready and all you need to do is to get involved.

If you already are an active participant of National Preparedness Month, please share your experience with our community. Tell us about your National Preparedness Month activities from previous years and the ones you are busy planning this year. There is really only one appropriate way to celebrate National Preparedness Month—by doing all we can to be just a little better prepared!

Dennis L. Jones, RN, is a Vice President of Business Development at Intermedix.

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The Department of Health and Human Services released its Final Rule modifying HIPAA’s privacy, security, breach notification and enforcement rules earlier this year. There are three major changes you should be aware of: Breach Notification Requirements, Business Associate Agreement and Notices of Privacy Practice additional terms.

You can find and read the full Federal Register publication, or if you’re looking for a brief explanation of the more significant modifications, simply continue to read this and future posts. Today, we’ll review how the Breach Notification Requirements have changed, and we’ll share details on the BAA and NPP changes in upcoming posts.

What’s a breach?

A breach is defined as the acquisition, access, use or disclosure of protected health information, or PHI, in a manner not permitted by the Privacy Rule, which compromises the security or privacy of the PHI.

The former version of the HIPAA regulations required covered entities and business associates to notify patients of a breach of their PHI, only after the breaching party had made the determination that such breach posed a significant risk of harm to the patient’s finances, reputation or otherwise. Organizations were permitted to perform their own risk assessments to determine if the breach posed such a risk of harm. However, this form of self-assessment has been deemed to be too subjective, thus permitting many breaching parties to avoid their notification obligations.

The Final Rule has removed this risk of harm standard and created the presumption that any impermissible use or disclosure of PHI is a breach requiring patient notification, unless the covered entity or business associate can demonstrate that there is a low probability that the PHI has been compromised.

Now what?

Given these changes, there are two important action items you should immediately implement:

  1. Update your risk assessment processes. Unless already modified, your current risk assessment process probably still evaluates whether the breach resulted in a significant risk of harm to the patient. Now that any impermissible use or disclosure creates the presumption of a noticeable breach, the covered entity or business associate must notify the affected patient, unless it can demonstrate a low probability that the PHI has been compromised.
  2. Change your internal policies for breach notification. Depending on the scope of the breach, in addition to the affected patient, the covered entity or business associate may be required to notify HHS and the media. Your breach notification policy must be written in a way that outlines the various individuals and entities to be notified, and the best method for doing so in accordance with applicable law.

Implementing the HIPAA compliance changes doesn’t have to be a daunting task, and it’s important to address it before it’s too late. Please feel free to contact us if you have any questions or would like further information regarding how these changes may impact your organization.

Tagged in: Compliance PHI
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Posted by on in ICD-10

It’s hard to believe that ICD-10 will truly take effect in October 2014 since the deadline has been moved twice already, but it’s still important to start preparing. Our new blog series, The ICD-10 Countdown, will provide insight into the many questions our clients ask about the process. We kick things off today by focusing on the ambulance industry.

The Centers for Medicare & Medicaid Services (CMS) Website is a good place to start gathering information; however, it doesn’t explain how ICD-10 will affect your ambulance operations. As of right now, we see two primary areas of impact: condition codes and training.

Condition Codes
We use ICD-9 codes on claims to describe what is wrong with patients to insurance companies, including Medicare and Medicaid. The ICD-9 codes are often determined based on the chief complaint from the patient care report. Some payers determine if ambulance claims are payable using just a short list of approved ICD-9 codes called a Condition Code list, while others use a Local Coverage Determination (LCD) policy. CMS has not yet clarified if or when the Condition Code list will be updated to ICD-10 codes. CMS has also not yet given any deadlines for payers to publish new LCD policies. If the lists aren’t updated, we could have a “wait and see” situation, meaning we’ll just have to wait and see how each payer individually decides to pay ambulance claims using ICD-10.

Training
ICD-10 codes are exponentially more specific than ICD-9 codes, and coders are required use the most specific code available. Therefore, it’s likely your clinical crews and quality control teams will require training to properly document patient conditions using the appropriate level of specificity.

The need for clarification from payers and additional training for crews is likely to cause delays in revenue cycle and cash flow. Intermedix is working proactively to avoid these delays by asking payers how they intend to pay ambulance claims after the transition and whether they intend to update the LCD policies they have in place. Additionally, we will offer updated documentation training for our TripTix and billing clients. Even with this proactive approach, it will be critical for you to prepare financially. Watch for upcoming posts surrounding the impacts of of ICD-10 on technology and the process of budgeting for the transition.

Has your organization started to prepare for the ICD-10 changes? Would you like to share some tips on the best ways to prepare? Let us know—we’d love to have you as a guest expert on our blog.

Rachael Waldinger is a healthcare consultant with Intermedix and has more than 15 years of experience in ambulance billing.

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Posted by on in Product News

Throughout the winter of 2006 and spring of 2007, six members of our team spent endless hours being interviewed by a patent attorney and reviewing countless schematics and documents. Finally, on April 27, 2007 we formally submitted a patent request to the United States Patent Office entitled, “Method and system for data aggregation for real-time emergency resource management.” 

The patent was for our EMResource solution, which we developed to assist emergency room physicians who could not find a suitable situational awareness solution in the market place. We realized that no other company was providing this functionality and so it became clear to us that we had a patentable invention. We were all very excited when the paperwork was finally submitted, but were cautioned that patent approvals can take a long time…a very long time…

So we waited and heard nothing for almost six years. Then finally, Patent Number 8428961 was awarded on April 23, 2013. The abstract provides a high-level summary of what our solution does:

A system and method for providing information about resource availability, especially during an emergency such as a natural disaster, is herein proposed. The system stores resource information about multiple facilities, across cities, counties, states and even countries. Such information can be provided to designated users based on specified access levels for the user and the resource information. Further, the system is able to exchange the resource availability information with external systems and databases. The resource information is also automatically updated to reflect the most current information. The system is useful in directing resources to participate in an emergency. Further the system aggregates resource information based on one or more attributes, such as region, hospital, city, state, etcetera, that is associated with the resource information.

If you read the patent text, you will gain some insight into why the process took so long. The text cites well over 100 references, including domestic and foreign patents, as well as government, academic and private sector documentation and articles. I have tried very hard to read and comprehend each of the 5,649 words included in the patent text, but I cannot for the life of me get through all the “whereins.” If you would like to get a more detailed account of our patent, I would suggest skipping to the “Detailed Description of the Preferred Embodiments,” which addresses system functionality, accessibility, interoperability, data storage and standards compliance.

Of the six inventors on the patent, two of us remain at Intermedix: myself and Dave Colwell, a software architect. This is symbolic of the origin of EMResource, a collaboration between healthcare and IT professionals, and it embodies our approach to development at Intermedix. The combination of experts in the field and experts in technology yields innovative solutions that solve real-world problems. EMResource has grown to be an important part of the country's emergency management infrastructure, and we take pride in working with our community to continue to shape its future.

 

Elaine Schweitzer is Intermedix's EMResource Client Services Manager

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This past week, I had the opportunity to participate in the Oklahoma tornado response at FEMA’s National Response Coordination Center. During my time there, I witnessed firsthand the dedication, hard work and seriousness of our federal emergency management agencies. This includes not only the Federal Emergency Management Agency (FEMA), but also the National Response Framework Emergency Support Functions Annexes of more than 15 federal agencies. The cooperation I witnessed among these agencies showed true boundless collaboration.

I was initially brought to the response center to provide onsite support for the National Level Exercise Ardent Sentry, an emergency preparedness exercise that equips the military in preparation for defense support to civil authorities. As I arrived, I planned and prepared to test new business processes and WebEOC boards relating to the exercise, but things drastically changed within 24 hours.

As we gained knowledge about the tornadoes, the exercise was canceled and FEMA went into a level II activation. FEMA Region VI Watch and FEMA’s National Watch Center immediately began creating incidents in WebEOC and we were fully operational within minutes.

I was impressed by the level of coordination and information sharing among FEMA Headquarters, FEMA Region VI, Oklahoma State Emergency Operation Center and other federal agencies, as well as the volunteer organizations. It truly was a commendable level of inter-agency cooperation. One of the most gratifying parts of supporting these agencies is knowing the importance of WebEOC in aiding the rapid and successful response to the incidents. Some of the WebEOC features used included the Sign-In/Out Roster, Activity Log, Significant Events, Requests for Information, Ops Tempo, National Situation Report, National Support Plan Tracker and Resource Tracking.

Since I have been deployed to many major tragic events, such as Superstorm Sandy, the Haiti earthquakes, Hurricane Katrina, the 9/11 attacks and Hurricane Isaac, I truly believed I had seen it all. However, witnessing the devastation and loss of life that occurred after one of the most powerful tornadoes that ripped through the Oklahoma area was just as heart-wrenching. My heart and prayers continue to go out to the families and communities impacted.

Jerome DuVal, Intermedix Vice President of Federal Services, provides assistance to over 50 federal agencies.
Tagged in: Featured Client WebEOC
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Posted by on in Intermedix News

We held our annual WebEOC User and Training conference just over a month ago, and it's been inspiring to see the ongoing engagement from our clients in defining product direction and best practices. One of the highlights of the conference was our awards ceremony, in which we honor those clients who have gone above and beyond in their leadership in the community during the last year. I would like to introduce our 2013 award winners:

Beyond Award - Pat VanHunnik (South Dakota Department of Health)

Pat went above and beyond a traditional Hospital-ICS by driving a solution for a major multistate hospital system. He also facilitated incident management driven by area dispatch centers instead of hospital-based incident command teams.

Boundless Collaborator Award - Dave Kayea (US Senate)

This award is the highest honor within our client community and is given for outstanding support to the community as a whole. Dave initiated collaboration among federal agencies to better connect the legislative branch of government.

Creative Ideas Award - Kelly Dixon, Michele Robinson, Stephen Sellers (California Office of Emergency Services)

Kelly, Michele, and Stephen won this award for the many new ideas they brought to the table during their development of processes for monitoring cyber security events throughout the state of California.

End User Engagement Award - Aubrey Kukral (Colorado Department of Health and Environmental Services)

Aubrey promotes rigorous drilling opportunities for Colorado hospital, EMS, dispatch, and emergency management personnel. These efforts resulted in immediate responses to hospital resource availability queries during mass casualty incidents and natural disasters.

Innovation Award - Jaclyn Barcroft, Brianna Currin (Michigan Emergency Management Agency)

Jaclyn and Brianna spearheaded a statewide WebEOC implementation in record time. They set the standard for system-wide standardization and implemented radiological status maps, email notifications, and other ground-breaking capabilities.

Rookie of the Year Award - Fred Rion (Monroe County, NY)

This award honors our most ambitious new customer. Fred facilitated a comprehensive implementation in Monroe County as well as information sharing with surrounding agencies.

Technology Award - Jeanie Clerico (Kansas Hospital Association)

Jeanie identified a lack of technology solutions in the marketplace to support the management of grant-driven inventory purchases, prompting the development of an inventory management product. She also participated in driving a user-centered solution to the problem.

Volunteer Management Award - Anne Kyle (Missouri Department of Health and Senior Services)

Anne demonstrated leadership in best practices for volunteer management. She learned from her experience during the Joplin Tornadoes and takes pride in a large community of active volunteers with an unprecedented percentage of up-to-date credentials.

It is an honor for us to introduce these distinguished clients to our community, and we hope you'll stay tuned as these and other clients begin to share more about their best practices and leadership.

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Posted by on in Intermedix News

The Intermedix Community is our way of asking you to participate in our vision for healthcare, public health, and emergency management. We believe that our customers can help us build better solutions and define a better path to our vision. In return, we want to help our customers by:

  • Sharing the enormous wealth of knowledge that exists within our company
  • Connecting our customers so they can capitalize on each others’ expertise
  • Being more active in our customers’ lives so we can more quickly respond to their needs

What might you find on the Intermedix Community? Well, we'll use it to keep you up-to-date on the latest industry news and information about healthcare reform and compliance. We'll use it to share our own thoughts on best practices as well as showcasing our customers who are using our solutions in great ways. We'll use it to provide more frequent updates about our products and services such as new features and technology improvements. We'll cover events in the community and important insights surrounding response to those events. And, we'll use it to get more personal by letting you meet the experts behind the scenes as well as other members of the community.

We're starting our community with a blog, but it's going to be much, much more. We hope you'll stay tuned and come along for the adventure!

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