Yesterday was Groundhog's Day and Punxsutawney Phil certainly made the good people of Gobbler's Knob happy by predicting an early spring. However, much like in the movie Groundhog's Day were Bill Murray relives the same day over and over again, CMS had a little surprise for rural health clinics on this Groundhog's day. CMS has over the years provided RHCs with a number of surprising, illogical, and non-nonsensical interpretations of Medicare regulations. Here is a list of just a few of the interpretations:
1. Chronic care management must be provided under physician supervision in a rural health clinic instead of general supervision as required in fee for service physician offices.
2. Drawing blood by a lab technician in a lab using lab supplies is not a lab service but a rural health clinic service and HCPCS Code 36415 can not be billed to Medicare Part B.
3. Provider-based rural health clinics may not have visiting specialists in rural areas due to the exclusive use standard which limits access to healthcare in struggling rural communities.
4. Home care plan oversight can not billed in RHCs even if the required face to face visit for home care plan oversight is conducted.
5. RHCs are expected to know if a surgery patient's surgeon billed a global procedure even if that surgeon has nothing to do with the RHC.
It sounds like our friends from CMS need to go on a road trip with me. Eight out of the last ten days, I have spent my nights in rural America, talking to a large group at the Georgia Rural Health Association, and visiting RHCs in South Carolina, Georgia, New Mexico, and Arkansas. This is where you learn the issues and problems of rural healthcare in America and the fight that goes on to save healthcare in small, undeserved areas. Now that I have built up the bad news, here it is.
CMS now thinks that RHCs should perform surgeries for free. It was bad enough Medicare paid you $63 for complicated, time consuming, and very skilled procedures, but that is exactly what CMS is saying. I first heard this at the Open Door session a month ago and thought to myself "Mark, your old, your hearing is bad, you don't understand things like you used to", however I understood it exactly the way CMS presented it. If a physician diagnoses a patient as needing surgery or a procedure and that patient comes back to the clinic on another day and that procedure is performed, the procedure is incident to and not payable as a rural health clinic visit. The only way to get any payment for that procedure is to perform an Evaluation and Management service on that visit as well as the procedure. But, you can not just perform the procedure and get paid. That was reflected in the Medlearn Matters on the implementation of the HCPCS codes which was released on Tuesday. Here is the link for this extremely important document that all RHCs need to read carefully and get this document to your billing software company, outside billing vendor, clearinghouse, or anyone involved in the formatting of the UB-04s as these changes will be implemented effective April 1st. We will schedule a webinar or two on this matter in the coming weeks.
I mentioned the RHC Conference in Georgia. Here are the handouts and presentations from this excellent conference. If you need to know how to access your P S and R, Julie Quinn's presentation has links to help you. I am still working on getting my cost report letters and notebooks up to date and they should go out as soon as I get back in the office. I have hired a couple of Accounting Interns to help me get my backlog of work out the door. I just can't seem to get off the road here lately. Again, here are the links and pay special attention to Kathy Whitmire's presentation. They have $31 million dollars to help your practice bill chronic care management and become a Patient Centered Medical Home and the money is not just for Georgia.
Thank You for a Great Rural Health Clinic Conference!
Jan. 27, 2016
A special thank you to our Sponsors and Presenters!
DIRRT - Doing It Right The First Time
Business & Healthcare Consulting
Association for Rural Health Professional Coding
Important Meaningful Use Hardship Waivers Due
I always get in trouble when I mention information like this but here goes, CMS has simplified the meaningful use waiver process. The waiver applications must be submitted by March 15, 2016 for professionals and April 1, 2016 for hospitals and CAHS. Here are the links that will explain the process if this is something you need to accomplish. Remember that in theory RHCs should not face a payment reduction from not achieving meaningful use; however, we thought the same thing about PQRS and there may be unintended consequences of MIPS resulting from the MACRA laws passed in 2015 (see link below)
Meaningful Use Hardship Websites
Merit Based Incentive Based Payment Website
National Association of Rural Health Clinics
Of course there is the National Association of Rural Health Clinics which is the voice of RHCs in Washington, DC. The NARHC offers two institutes each year in the spring and fall which provide invaluable updates and in-depth information for rural health clinic administrators and providers. Here is a list of upcoming eventshttp://narhc.org/events/ with the next one occurring in San Antonio, Texas on March 14th to the 16th. Here is the link to information on the conference including an agenda and the costs: NARHC Spring Institute - March 14-16, 2016.
If you cannot make the conferences, there is the List Serve that provides timely information and updates as well as an opportunity to ask questions and submit feedback to other RHCs throughout the country. If you are not familiar with what a list serve is it is a mail list which allows its members to communicate through email posts. To post a question on list serve, you must first be signed up on the list serve. To sign up for list serve, click here. The list serve is free to join.
However, remember RHCS need representation on a national level. The numbers bear out that RHCs/FQHCs are the most cost effective way to provide healthcare to vulnerable populations. That story needs to be told and your membership in the NARHC will help tell that story.
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