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HOOSIER TIMES
INDIANA PRESSLER MEMORIAL CHAPTER - HFMA
z
Bidding A Fond Farewell
z
After seventeen Chapter Presidents, Sarah Killion reflects on an
HFMA journey only she can share.
THANK YOU SARAH
There are still a few “old-timers”
who remember an Indiana Pressler
Memorial Chapter without Sarah
Killion. For me, she has always
been there at the registration desk
every institute with a smile on her
face. There was always something
comforting about that. No matter
how hectic your work day was, no
matter how many fires you put out
on the way to a meeting, you could
always count on Sarah to be there.
“oh yeah, why?” Well, it didn’t
take long to answer that question.
Because Sarah was the heart and
sole of the Chapter. Everyone
knew this and it didn’t take long to
figure it out.
She has been there for us through
thick and thin. Bringing her own
wisdom and experience to it all.
There is no doubt she is the oil
keeping this wheel turning!
It doesn’t seem like “thank you” is
enough for someone who has been
so much to so many but we do say
thank you to Sarah for all the hard
work, dedication and guidance.
Shelly
As a new member in 1998, one of
the first things I was told was
“you’ll want to get to know
Sarah.” Now, when someone tells
you this, at first you think,
Please read Sarah’s story, in her
words, on page 5. (Photos there are
from our polaroid archives and may
not be the best reproduced quality)
In This Issue
Physician
Revenue Cycle &
Compliance
Compliant or
Confused?
3 Reasons to
Automate
UPCOMING
EVENTS
In This Issue:
Page
12
You and Your 340 B
Program - Compliant?
Page
13
Physician Revenue
Cycle Compliance
Page
15
3 Reasons to Automate
Scheduling & Staffing
Editor’s Note .......................3
ICD 10 - When do we Start
Back Up Again?...................4
Seventeen Years of
Indiana HFMA......................5
Fall Institute.........................7
2014 Golf Event...................8
Committee Updates.............9
HFMA Certification - I’m
Already Certifiable-Should
I be Certified as Well?........10
You and Your 340 B
Program..............................12
Physician Revenue Cycle
Compliance........................13
Utilization of Health
Care Services.....................14
Waves of Compliance.........15
3 Reasons to Automate
Scheduling & Staffing.........16
President’s Message..........16
Sponsors............................17
JANUARY 29-30,
2015
Winter Institute
Renaissance North,
Carmel
APRIL 15-27, 2015
Spring Institute &
Vendor Show
Sheraton Keystone
Crossing, Indianapolis
Now Is The Time!!
If you haven’t already, make sure your contact information is current on the
National HFMA website - www.hfma.org. Our local chapter information comes
directly from this source so if we don’t have it right, that means it may not be
right at the top!!
Need to contact the Indiana HFMA office?
Via Phone: (317) 643-2520
Via Fax:
(317) 300-7059
Via Email: [email protected]
Via Post Mail:Indiana HFMA - Shelly Haggard, Administrator
2106 Remington Drive
Indianapolis, IN 46227
HT - 2
Editor’s
Note
Happy Fall! I
can’t believe the summer is gone
already. With the elections upon us
and the changes this can bring, we
have taken this issue to recognize a
change within the chapter. Our long
time administrator and friend Sarah
Killion has retired from the chapter.
You will see a special section about
Sarah in this issue. Sarah we wish
you all the best!
Like the leaves changing, we
appreciate all of the work that Sarah
has done over the years and now we
welcome Shelly Haggard as the new
administrator. Shelly has been
involved and helped our chapter grow
over many years. As Shelly takes
over for Sarah, we are here to support
and encourage her in this roll.
The holidays are soon upon us. On
behalf of the HFMA Communications
Committee:
Happy Thanksgiving, Merry Ch!"mas and Happy New Year!!! Farrah Mahoney
Please be aware that some photos are
actual re-prints from archived paper
prints and not always the best quality.
We produce the HoosierTimes under
“best” quality conditions but on the
other end a print-out may not be set to
default to the highest quality so some
items may not be a clear as they appear
to us when we’re in production.
HT - 3
COMMUNICATIONS COMMITTEE
Chair & Editor
Farrah Mahoney
Healthcare Insights,
LLC
[email protected]
Vice Chair
Sally Hardgrove
BKD< LLP
[email protected]
Angela Chanley
Adult+Child
[email protected]
Shelly Haggard
The Harrison
[email protected]
Dustin McKinley
Bradley & Associates
[email protected]
Mary Minier
IU Health-White
County Hospital
[email protected]
Jerry Smith
CBCS
[email protected]
Angie Wells
IMC Credit Services
[email protected]
Meagen Windler
Eskanazi Health
[email protected]
g. Conduct systems audit.
ICD 10 – When Do
We Start Back Up
Again?
All of us got to “take a breather” with
the delay of ICD-10 to 10/1/15. The
big question on many providers’
minds is when do I start up again?
The answer to that question is Now.
“Preparing for ICD-10: Now Is the
Time” is an online article by Joseph C.
Nichols, MD, which outlines some
basic ICD-10 principles and
suggestions. (A one-time free sign-up
onto the Medscape CMS-supported
system is required to view this article.)
To view the article go to: http://
www.medscape.org/viewarticle/
830147 .
CMS has not updated the sample time
lines on its website to show the new
go live date of October 1, 2015. But
below is a sample timetable for the
ICD-10 project phases shared by a
central Indiana provider. Are you on
schedule?
Sample Project Phases:
1. October 2014 – November 2014:
Analysis.
a. Assemble steering
committee and core
project team.
b. Establish organizational
awareness
c. Develop budget
d. Develop a project plan
e. Develop assessment
questionnaires.
f. Complete readiness
assessment (systems and
people).
HT - 4
h. Conduct documentation
assessment.
2. December 2014 – March 2015:
Implementation (Design).
a. Review and address
documentation practices.
b. Implement educational/
training plan.
3. April 2015 – September 2015: GoLive Preparation (Development and
Testing).
a. Implement IT changes
b. Final transaction testing.
c. Educational/training
activities.
d. October 1, 2015: GoLive.
e. Code charts.
f. Transmit data.
g. Verify correct data
transmission.
Editorial Policy &
Publication Deadline
The statements and opinions expressed
in articles or features are those of the
author(s) and do not necessarily reflect
the view of the Indiana Pressler
Memorial Chapter, the Healthcare
Financial Management Association, or
the Editor. The Editorial Board reserves
the right to edit material and to accept or
reject contributions whether solicited or
not. All correspondence is assumed to be
released for publication unless otherwise
indicated. All rights reserved.
Questions regarding articles or features
should be addressed directly to the
author(s). All articles submissions must
be typed and sent via email or provided
on a disc.
All submissions must be received by the
following dates. Materials received after
the deadline are not guaranteed to be
published.
DEADLINES
July 20, 2014.............for Summer, 2014
October 20, 2014..............for Fall, 2014
January 20, 2015..........for Winter, 2015
April 20, 2015..............for Spring, 2015
4. October 2015 – March 2016: Post
Go-Live.
All submissions/correspondence/
advertising/comments, should be sent to:
a. Monitor coding accuracy
Farrah Mahoney, Editor - Hoosier Times
email: [email protected]
and productivity.
b. Monitor reimbursement
activity.
c. Continue on-going coder
education.
d. Transition off ICD-9.
e. Ongoing
documentation
assessment.
Hoosier Times
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Seventeen Years of Indiana HFMA
by Sarah Killion
The old adage about how time flies when you’re having fun
or getting older certainly seems to apply to me this year! I’ve
definitely had a lot of fun over the past 17 years and it seems
like just yesterday that I was interviewed by Ed Abel at the
Blue & Co. offices in Carmel to provide administrative
services for the chapter.
My first “full” presidential year was with Paul Usher, a friend
and colleague for more than 34 years! I well remember sitting
in one of their first board/committee
meetings as they talked about planning
an institute and thinking “I believe I can
help!” At that time, responsibilities for
all activities transferred from one person
to another each year which made
consistency a challenge. And, that was
also the time when the Chapter had one
institute per month! I’d forgotten
about that until gathering all the
materials together to be scanned or
transitioned to Shelly. You have it easy,
Jack, you only have to plan four!
Those were the days of overheads
(anyone under 40 probably has no idea
what these are!), flip charts, and bulky
microphones. Some of the long-time
members will probably also remember
the bugs walking across the food tables
at institutes in Nashville, murder
mysteries, mock trials, limbo dances,
“Have you seen…” milk carton, Cuban
restaurant owners in Florida, horseback
rides, and so many other memories.
The Chapter has been fortunate to have
such a diverse group of leaders over the
years, each bringing their own stamp to
the presidency.
HT - 5
There was the “Short, but Mighty” triad of Trudy Struck,
Nancy Winkle and Carol Naffziger. They must have really
got-ten tired of saying, “But I AM standing!” They ruled with
a velvet hammer and these ladies had an energy and
enthusiasm that far exceeded their heights.
Connie Bishop – so reluctant
at first to take on the responsibilities
of moving up the chairs. Fortunately,
after an evening of networking at
the Four Seasons, she agreed to take
on this opportunity and proved to be
a dynamic, take charge, and very
effective leader. Her leadership was
recognized by National as she became
a Region 7 Regional Executive.
Keith Jewell, aka “Superman” – talk
about organized! His financial reports
were detailed and bound! His
presidency saw the change to
incorporation in Illinois which was not
a small task to oversee.
Jim Struck (“Trudy’s Other Half”) –
obviously great minds “see” alike. Jim
was always a voice of calm and “Don’t
worry – all will be o.k.!” His clarity
and leader-ship, during and after his
presidency, often eased difficult
situations.
seriously and is one of the nicest ladies you’ll ever meet.
Dave Cholger – the Karate King! Who else
would have thought to break boards to show
their strength of purpose at the Mini-LTC?
He is a gentle giant!
Jim Miller - race fan,
politically savvy, and amazingly well
informed! How does one brain hold all
that information?! His affiliation with
the IN Rural Hospital Association has
been a huge asset to this
Chapter.
Bob Brandenburg – were you REALLY old
enough to be president?! Always dressed in a
coat & tie, it was fun to see him relax with a
good shot of bourbon during our social events.
He may have come from Kentucky, but is now
an adopted Hoosier and we’re glad to have
him. He led the Chapter to achieving several goals and
awards during his term.
Brad Willkie – has the Chapter
ever had a more enthusiastic and
involved president?! His energy
and commitment to HFMA
Indiana has been evidenced over
and over again – as chair
of sponsorship, National LINC
committee chair, newly elected
Regional Executive, and more!
This is how he looked when
he first started! The years may
have turned the black hair
gray, but his enthusiasm
never wanes.
There have been so many others over
the years – Pam Burns, a kinder
person I haven’t met; Bill Lammers,
one of my earliest officers; Deb
Hickman, the “fashionista;” Kyle
Bennett, steadfast and who rocks the
professor look with the bow tie &
glasses; Sherry Ribble (“Pretty in
Pink”), took her responsibilities so
HT - 6
Although I was never able to work
with Wayne Hutson when he was
president, I did get to experience his
quirky side over the years. As this
picture shows, he was always up for
anything! Thanks, Wayne, for
providing so many laughs over the
years
Shawn Williams – he has had the
responsibility of overseeing the
transition of the chapter from one
administrator to another and accepted
the challenge as he always does – by just
doing it! During Shawn’s progression
through the officer chairs, he worked
very hard to spread the HFMA word to
other organizations by collaborating on meetings, to
students by implementing a student information program,
and by being an excellent ambassador for this chapter. And,
he still manages to have fun as anyone who was at this
year’s Mini-LTC can tell you. He can belt out karaoke with
the best of them and just maybe Michelle Trowell will share
some videos with you. I am fortunate to end my tenure with
HFMA with a person I’m so glad to call a friend.
Fall Institute
by Michelle Trowell -
vote on. Congratulations
to Shelly Haggard on
winning first place for
the best painting!
was honored for her
years of service. Several
BLOOMINGTON, IN past chapter presidents
At our Fall Institute, we
came back to join us in
tried some new ideas to
saying our “goodbyes”
add Networking oppor- We also held an opening and “thank you’s” for
tunities. Although small reception at the Wonder- Sarah’s dedication to the
in numbers, the group
Lab where everyone had chapter.
who participated in the an opportunity to play
Wine & Canvas event
with the interactive
On Thursday evening,
had lots of fun. We had displays. During the
we held an Oktoberfest
the final paintings on
reception, Sarah Killion
display for attendees to
Above: Past-President’s (LtoR) Carol Naffzinger, Sherry Ribble, Jim
Struck, current President - Shawn Williams, Trudy Struck, Jim Miller,
Connie Bishop, Brad Willkie and Bob Brandenberg all attended the
WonderLab Reception in honor of Sarah Killion (center). Right: Top The
sessions were very well attended in Bloomington. Right Bottom: Darren
Cook enjoys the great food at the evening reception.
Top Left to Right: Consultants On Call. Sarah Killion and Mary Minier
enjoying the WonderLab. The Winter Institute was full of great speakers.
Tom Hicks and Jeff davis.
HT - 7
event where a local
brewery and a local
winery were present to
offer samples for tasting
while we networked
with our colleagues.
Thanks to all who
participated and we look
forward to seeing
everyone at the Winter
Institute!
2014 Fall HFMA Pressler
Memorial Golf Event
Some of the individual skill event winners were; Holly
Bishop, Ann Branham, Phil Ellis, Bob Brandenburg, Shawn
Williams, J Hopkins, Dave McCullough, Brian Siebers, Trae
Christian and Brad Willkie.
The event organizers wanted to try a new course this year.
Believe it or not, one of our own HFMA members, Julie
Carmichael, CSO of St Vincent and her Dad (Sam
Carmichael) own Martinsville GC. We reached out to
them and they were gracious enough to host our event.
The chapter would like to thank the Golf Committee;
Richard Altman, GLA, Steve Cooper, ClaimAid, Phil
Ellis, CIPROMS and Brad Willkie, ClaimAid for helping
organize another successful day of fun and fantastic
networking.
While setting up at 7:45 AM was a bit chilly, by 10 AM the
weather turned out fantastic and we ended up with 12 very
happy teams.
For years now we have continued with our Bankers
Handicap, offering even the least experienced golf teams the
opportunity to WIN!
However, because of the luck of the draw on the right holes
and by virtue of winning a tie breaker with Bob
Brandenburg’s team… Dave McCullough’s team pulled out
the victory.
Left to Right: Phil Ellis, Ann Branham, Cassandra Graham
and Richard Altman
• David McCullough, Professional Medical Services
• Greg Wiles, Director of PFS Community Health Network
• Nick McLaughlin, AmeriCollect
• Bryan Gordon, Cleverly and Associates
While we don’t have a picture of the Winners on the
course… we do have a most COMMITED PUTTING
TEAM photo. I think Phil Ellis got a cramp during the
photo shoot… or he just saw a pheasant!
Left to Right: Bryan Gordon and Nick McLaughlin collect the
winners trophies from Brad Willkie.
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COMMITTEE UPDATES
We will be sponsoring a community service project to
collect blankets and warm clothing for the homeless. Please
bring donations of blankets, hats, coats, scarves, gloves and
mittens which will be distributed to those who need warmth
and comfort throughout the cold winter months...
Sponsorship Committee
Frequently we list the committee accomplishments, but fail
to list the committee members that made it all possible.
Thank you to:
Co-Chairs:Steve Cooper and Brad Willkie, Vice-Chairs, Jeff
Moffatt and Nick Kuzera, Richard Altman, AJ Beck, Jim
Christie, Jim Miller, Jennifer Wiggins and Rick Zimmerman
KPI Committee
Our committee has been actively seeking input from
previous survey respondents in order to determine how we
can make the survey as valuable as possible to our
membership. We have had the opportunity to sit with a
couple providers to gather their insight and
recommendations for not only the survey, but the Spring
presentation as well. If anyone has ideas or concerns they
wish to share, please contact me. Our team looks forward to
hearing your input!
In addition, we are investigating an alternative database for
the survey responses. Our goal is to find a low cost
alternative that will be the property of the Chapter. More to
come on this topic in the coming months...
Networking Committee
Networking opportunities at the Winter Institute
We will be hosting a networking social hour on Thursday,
January 29th immediately following the final session of the
day. Hors d’oeuvres and drinks will be served while we
have time to network with our vendors.
This year’s goals were as follows:
1. To secure $96,500 in sponsorship monies
2. Add 4 new Sponsors to our chapter
3. Retain 90 % of our Sponsors from 2013-2014
4. Have a total of 50 Sponsors, between renewals and
new sponsors...
Website Committee
On our last website committee meeting we discussed what
we should make the focus of the front page of the website as
the time between the Fall and Winter Institute is one of the
longest stretches of the chapter year without an educational
event to promote. We are starting out with information for
the chapter survey with an article written by our chapter
President Shawn Williams. After that we are turning our
attention to the accomplishments and activities of other
chapter committees. As always, if you have any suggestions
of what you’d like to see in your chapter website please let
us know.
For Full Committee Updates,
Follow this Link -
http://www.hfma-indiana.org/uploads/
2/8/6/6/28663867/hoosiertimesfallissue2014links.pdf
HFMA Certification: I’m Already Certifiable—
Should I be Certified as Well? By Jerry Smith
Institute presentations regularly discuss HFMA Certification and
recognize Certified individuals. But what does it mean to be
Certified? Should you consider it? What will it do for you and
possibly your career? Indiana Certification Chair Shannon
Ebenkamp took a few minutes recently to discuss the ins and
outs of Certification. Shannon is currently the Finance
Supervisor at Memorial Hospital and Healthcare Center. She
earned her HFMA Certification in August 2011.
Jerry Smith: Can you describe what Certification is?
Shannon Ebenkamp: Certified Healthcare Financial
Professional (CHFP) is a Certification program designed to
recognize individuals who possess the knowledge and skills
identified as essential to financial professionals in the healthcare
field.
JS: Why should one become Certified?
SE: Becoming Certified distinguishes you as a leader and role
model in the healthcare finance community.
JS: Can you describe how the process works?
SE: Once a member has made the decision to become Certified,
a study plan must be determined. There are many options
available. Currently our chapter has joined 22 other chapters to
offer a series of five webinars, presented by Christoph Stauder.
JS: Can you describe how the process works?
SE: Once a member has made the decision to become Certified,
a study plan must be determined. There are many options
available. Currently our chapter has joined 22 other chapters to
offer a series of five webinars, presented by Christoph Stauder.
These webinars are designed to cover those topics most heavily
tested on the exam. In addition to the webinar series, HFMA
offers an online study course, which is available at hfma.org for
$249. There is also a free app called Quizlet which is available
at the App Store on your phone that can help members study
while on the go. We may not always have a computer with us
while sitting in stopped traffic or at a ballgame, but we do
usually have our smartphones.
JS: Who should consider becoming Certified?
SE: The HFMA Board of Examiners strongly recommends that
candidates have a minimum of 3-5 years of healthcare provider
management experience. This is not required to become a
CHFP, but management experience is the primary preparation
for the exam.
JS: How does the Indiana Chapter help individuals with
Certification?
SE: Our chapter is dedicated to helping members become
Certified. Currently, if you participate in the webinar
series
then sit for the exam, the chapter will reimburse you for
$300 of the $395 exam fee whether the exam is passed or
not.
If you are interested in Certification or have any questions
for Shannon, please reach out to her at
[email protected] or by telephone at (812) 996-2935.
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You and Your 340B Program:
Are You Compliant or Confused?
by Venson Wallin and Bill Bithoney, MD,
The BDO Center for Healthcare Excellence and Innovation
What is the 340B program?
The 340B program is a means through which providers,
known as “covered entities,” can offer pharmaceuticals to a
greater amount of eligible patients than they could at
traditional manufacturer pricing. This is because the
program requires that manufacturers sell the drugs to the
eligible providers at a discount, thereby enabling a larger
number of those in need to get the assistance they need with
purchasing their prescriptions. The 340B program is very
popular for this very reason; covered entities are able to
purchase drug supplies at the 340B discounted price, and
then bill the patient’s insurance company the traditional rate.
This “margin” generates much needed profit for some of the
more income-challenged providers, while having minimal
impact on the Medicare and Medicaid program costs. The
patient wins, the provider wins, and the government
programs win. Providers understand the upside, and annual
340B drug spending by covered entities exceeds six billion
dollars and approximately one-third of U.S. hospitals
participate in the program. The spending and number of
participating providers is forecast to increase significantly
during the coming years.
In 1992, Congress created the 340B program via Public Law
102-585, the Veterans Health Care Act of 1992, which is
otherwise known as Section 340B of the Public Health
Service Act. The law requires drug manufacturers that
participate in the Medicaid program to agree to provide
discounts on covered outpatient drugs purchased by
government-supported facilities, or “covered entities.”
Examples of “covered entities” include disproportionate
share hospitals, sole community hospitals, rural referral
centers, critical access hospitals, and children’s hospitals
and cancer hospitals exempt from the Medicare prospective
payment system. Enrollment periods for those providers
seeking to participate in the program are open on a quarterly
basis. Administration of the 340B program is performed by
the Office of Pharmacy Affairs (OPA) of the Health
Resources and Services Administration (HRSA), an agency
of the U.S. Department of Health and Human Services.
Achieving Compliance with 340B Program
Guidelines
Compliance pertaining to a 340B program is relative. A
provider may consider themselves in compliance with the
guidelines of the program based on their understanding of
these guidelines, whereas HRSA and the OPA may consider
the provider to be noncompliant based on their
interpretation of these same guidelines. These divergent
opinions are a result of a set of rules that are written in a
somewhat general manner, excluding the detailed
implementation regulations that are common to other HHS
programs. HRSA recognizes the need for more clarity on the
part of the covered entities and is actively working to close
the interpretation “gap” and to achieve more compliance
within the program.
HRSA has heard the rumblings from the industry and
Congress over the past several years regarding the 340B
program and the need for more detailed directions to
minimize both unintentional violations of the program as
well as intentional efforts to take advantage of the
interpretation “gap” to prosper to an extent not anticipated
by the authors of the program. Audits in recent years by
HRSA and the Office of the Inspector General (OIG) of
HHS have confirmed the fact that covered entities are
having challenges meeting full compliance with guidelines,
particularly in the areas of diversion and duplicate
discounts. Another key factor in meeting compliance
requirements identified through the audits is the degree to
which providers utilize contract pharmacies and their
oversight of such. The use of contract pharmacies, while
occurring in the minority of covered entities at this point, is
growing and there is a wide disparity in their treatment and
oversight. HRSA has strongly recommended the use of
independent audits of contract pharmacies to address
compliance.
Increased Focus on Integrity and
Compliance
So where does one go from here? Good question and one
that the HHS OIG and HRSA intend to address in the
immediate future. They are both being very active in
publishing clarifying documents and preparing to conduct
more extensive audits of 340B programs. The HHS OIG
2014 Work Plan contains initiatives pertaining to the 340B
program, including a focus on contract pharmacy
compliance by covered entities. In February, 2014, the OPA
issued a program update that addressed contract pharmacy
compliance and the continued focus on the program’s
integrity.
For Full Article,
Follow this Link http://www.hfma-indiana.org/uploads/
2/8/6/6/28663867/hoosiertimesfallissue2014-links.pdf
Physician Revenue Cycle
Compliance
Physicians and their practice
staff are increasingly being
tasked with meeting regulatory
compliance issues and ensuring
appropriate oversight of billing
and practice management
processes to avoid audits and
investigations.
The Office of Inspector General (OIG)
has issued a number of reports over
the past several years scrutinizing
documentation and claims information
of physicians, with a particular focus
on evaluation and management (E/M)
coding. Beginning with a report in
2006, the OIG found that 75 percent
of E/M consultations did not meet
Medicare coverage requirements. In
2012, the OIG reported that physicians
shifted their billing to higher level E/
M codes over a 10-year period in all
15 visit types. Most recently, the OIG
reviewed medical records from
physicians to determine whether the E/
M service documented in the medical
record for each sample claim was
correctly coded or sufficiently
documented. Their findings concluded
that 42 percent of claims for E/M
services were incorrectly coded, with
64 percent of those claims being
upcoded and 36 percent being
downcoded. The OIG also identified
high-coding physicians-- those whose
average code level was in the top one
percent of their primary specialty and
those that billed for the two highest
level codes for E/M services at least
95% of the time. These high-coding
HT - 13
physicians were more likely to
miscode claims, with 56% of claims
being incorrectly coded, nearly all
being upcoding errors. The OIG
projected these coding errors to total
$6.7 Billion in improper payments in
2010. While the Centers for Medicare
and Medicaid Services (CMS) did not
agree with all of the OIG
recommendations from this report,
CMS did agree with the need to
educate physicians on coding and
documentation requirements for E/M
Services.
So what can physician practices do to
ensure they are remaining compliant
with these and other areas targeted by
the OIG? First, physician practices can
look at their physicians’ coding
profiles to see how they compare with
other physicians in the same specialty
and how they compare with national
benchmarks. Doing so may help to
identify outliers, and even be an
opportunity to increase revenue from
those physicians who may be
downcoding. Next, physician
practices can review the steps in their
revenue cycle, from scheduling the
appointment through claims
adjudication, and identify any areas
that may create an opportunity for
non-compliance. For example, are
physicians using an EMR system to
document their care, and if so, do they
use the copy and paste function? If not
being used correctly, the copy and
paste function can lead to improper
documentation or improper coding.
The Affordable Care Act also put into
place a requirement that physician
offices establish a compliance
program. The OIG offers guidance on
developing a compliance program.
The following seven steps can be used
as a template for developing a
compliance program, or as a checklist
to ensure your existing compliance
program is comprehensive.
1.
Conducting internal
monitoring and auditing
through periodic audits:
The OIG recommends
reviewing both the medical
practice’s standards and
procedures, as well as
conducting a billing and
medical record audit.
2.
Implementing compliance
and practice standards
through the development of
written standards and
procedures: The OIG
recommends practices
develop a manual containing
all written standards and
procedures, and include any
regulations or documents
necessary to ensure
employees are up-to-date on
compliance issues.
3.
Designating a Compliance
Officer or contact(s): This
individual can oversee the
program, establish methods
for compliance, keep the
compliance program up-to-
date, develop training and be
responsible for checking the OIG
Exclusions Database.
4. Conducting appropriate
training and education on practice
standards and procedures: Training
in compliance, and coding and billing
should be offered to appropriate staff.
5. Responding to detected
violations through investigations of
allegations: The practice may want to
monitor for indicators of
noncompliance and take decisive
action should any indication of
noncompliance occur.
6. Developing open lines of
communication among staff
regarding fraudulent conduct:
Encourage open communication both
with internal staff as well as with
business associates involved in
revenue cycle management.
7. Enforcing disciplinary
standards through publicized
guidelines: Employees should
understand the consequences of not
following compliance guidelines, and
disciplinary standards should be in
place.
While busy physician practices are
experiencing more demands than ever
on time and resources, setting the
ground work for ensuring compliance
can prevent headaches and hassles in
the long run. Laying the foundation
with a comprehensive compliance
program, and reviewing the revenue
cycle steps with compliance in mind
can help make staying on top of
compliance manageable.
HT - 14
Utilization of Healthcare
Services
Special Report
from
M
ost healthcare leaders would agree that the industry is in
the midst of one of the most transformational changes in its history.
There is recognition from payors, providers, and government
officials that the current system is based on a perverse incentive
model that rewards the provision of “sick care” as opposed to “well
care.” Tolerance for the current model is rapidly declining. Today,
numerous healthcare organizations have started their
transformational journeys, and promising models have emerged
that are having early successes. While best practices will continue to
evolve, the care delivery models and incentive structures that need
to be developed for future success are becoming more defined.
Networks of providers will be accountable for managing the health
of defined populations, and provider reimbursement will be at risk
for providing high value care. It is our belief that to have success in
this new paradigm, organizations must remove significant amounts
of excess utilization and lower the medical cost of their attributed
lives. What is not clear is how much utilization will need to be
removed and how quickly it must happen. While these two factors
will certainly be market dependent, this report explores the
expectations of healthcare executives on how healthcare utilization
will change in the future and compares their expectations to where
we believe healthcare organizations will need to drive utilization
levels to be successful in the future.
For the full report,
follow this link:
]http://www.hfma-indiana.org/
uploads/2/8/6/6/28663867/
hoosiertimesfallissue2014-links.pdf
Waves of Compliance
by Ken Blickenstaff
Greetings to all the readers of the IHFMA
Waves of Compliance. We have two items that
we hope you find interesting.
At the end of August of this year, the Centers for Medicare &
Medicaid Services (CMS) proposed a partial payment
settlement offer to certain types of hospitals with qualifying
claims.2 A qualifying hospital, willing to withdraw its pending
appeals related to inpatient status claims, could expect a “…
timely partial payment (68% of the net allowable amount)”.3
The types of facilities eligible to submit a settlement request
included:
-
Acute Care Hospitals, including those paid via
Prospective Payment System (PPS), Periodic Interim
Payments (PIP), and Maryland waiver; and
-
Critical Access Hospitals.
Eligible claims included those denied by Medicare for
services that--while reasonable and necessary--did not require
inpatient treatment. CMS also specified that the claims needed
to be under appeal or within their administrative timeframe to
request an appeal review, have a date of admission before
October 1, 2013, and the patient could not be a Part C
enrollee. A caveat to the deal was that the hospital must take
an “all or nothing” approach to applicable claims—there was
not an option to settle some claims and continue to appeal
others. Additionally, a hospital could be excluded from the
settlement opportunity due to pending False Claims Act
litigation or investigations.
The settlement offer has not gone without criticism, however.
Texas representative Kevin Brady expressed concerns in
September—stating that it was unclear that CMS could utilize
the Federal Claims Collection Act and 42 CFR 405.376 to
establish the administrative agreements with hospitals.2
Additionally, Brady thought that the 68% amount was “too
generous”, because outpatient services typically have lower
payments.
While the October 31, 2014 deadline (unless an extension was
requested and granted) for hospitals to send their settlement
requests to CMS has likely passed by the time you are reading
this, CMS’s “68% deal” was surely making waves upon the
shores of many hospitals in Indiana.
HT - 16
On another front, the Department of Justice (DOJ”) may be
looking for more criminal charges against healthcare
entities and their executives for allegedly submitting
false claims to Medicare. To accomplish this, DOJ Criminal
Division will review all false claims cases (also called “Qui
tams” that are a vital part of the Criminal Division’s future
efforts) filed by whistleblowers. They will be “immediately”
reviewed by federal prosecutors in addition to the usual
review by civil division lawyers. This new level of scrutiny
may add another level of culpability for healthcare entities.
The government will call for immediate sharing of
information between the Civil and Criminal Divisions, and the
Fraud Section will be responsible for coordinating
enforcement activities. Other entities involved in the
enforcement efforts and investigations will include the FBI,
HHS Office of Inspector General, and Medicaid Fraud
Control Units (which have State jurisdiction and are
frequently involved in joint enforcement and compliance
efforts). This could also result in a new level of exposure
within the Executive Suite and Board members. Please put
this “new” enforcement activity on your watch list.3
1Source:
http://www.cms.gov/Research-Statistics-Data-andSystems/Monitoring-Programs/Medicare-FFS-CompliancePrograms/Medical-Review/Downloads/
HospitalParticipantSettlementInstructions_updated09092014.
pdf
2Source: http://cms.gov/Research-Statistics-Data-andSystems/Monitoring-Programs/Medicare-FFS-CompliancePrograms/Medical-Review/InpatientHospitalReviews.html
3Source: Report on Medicare Compliance (Volume 23,
Number 33, September 22, 2014) p. 8.
4Source: Report on Medicare Compliance (Volume 23,
Number 33, September 22, 2014) pp. 1, 7, and 8.
* We would also like to thank Sandy Wildermuth who brought
the “68% issue” to our attention.
Three Reasons to Automate Scheduling and Staffing
by API Healthcare (2014)
Healthcare’s most valued resource,
employees, who make up nearly 60%
of providers’ operating costs and how
these resources can be optimized,
namely by automated staffing and
scheduling. This article focuses on 3
reasons: optimal staffing based on
patient need, labor cost savings, and
increase in employee engagement.
For the full article,
follow this link:http://www.hfmaindiana.org/uploads/2/8/6/6/28663867/
hoosiertimesfallissue2014-links.pdf
President’s
Message
Shawn Williams
Indiana Pressler
Memorial Chapter
President - 2014-2015
As we are approaching the Winter season, where “experts” say we are going to have a repeat of last Winter’s weather accumulation,
the Indiana Pressler Memorial Chapter is having a blizzard of activity. Pardon the pun, but we are approximately 50% towards our
goal of education hours, an estimated 15 members have completed webinars and related studying for the certification exam, the
board is looking for a possible 7 board members between expiring terms and resignations, a possible new event in March located in
Warsaw, and finally the members are receiving a flurry of emails relating to the satisfaction survey that is currently being conducted.
If you haven’t completed the satisfaction survey, please take the time to help suggest new ideas or improvements to make your
experience better. If you’re not extremely satisfied with the volunteer effort, please contact any officer or board member.
Our next event is the Winter (Legislative) Institute scheduled for January 29th-30th Renaissance Indianapolis North in Carmel. The
political and legislative impact on healthcare reform and expansion will be interesting given that the open State and National
political seats have continued or became Republican after the November 4th elections.
Lastly, have a great Thanksgiving! I am thankful for a dedicated board and officer slate, valued membership desirous of making a
difference, and a family and employer that understands my current responsibilities.
Sincerely,
Shawn Williams
President
HT - 15
Sponsors
We thank these sponsors for their support of the
Indiana Pressler Memorial Chapter HFMA
President
BKD, LLP
Rev(1) Companies
Gold
Bronze
CIPROMS, Inc.
ClaimAid
Cleverley+Associates
Commerce Bank
Hall Render
McGladrey
Plante Moran
Rycan
Vaughan Holland Consulting
Avadyne Health
Bradley & Associates
Cain Brothers
CarePayment
Cirius Group
Claim Aid Self-Pay Solutions
Collection Associates
Converys
Crowe Horwath
Elite Print Services
Hardamon & Associates
HCFS
Key Bank
Key Bridge
Medical Business Bureau (MBB)
MedShield
MSCB
ProAssurance
Professional Medical Services
Spend Bridge
UCB
Silver
Allied Business Services
Americollect
Blue & Co., LLC
Capio Partners
Enable Comp, LLC
GLA Collection Co.
Healthcare Insights, LLC
IMC Credit Services
MedAssist
Medical Protective
MMIC
Net Revenue
Performance Services
PNC Healthcare
Receivable Recovery Partners
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