June 14, 2016

Welcome to the Wesgram Online!  


This Wesgram contains valuable information for you and your practice, including Payor Updates, Medical License Renewal information, New Overtime Rules, a brief introduction to MACRA and registration information for the upcoming Certified Medical Insurance Specialist course that will be held in August.      

story1ICD-10 Latest News
Documentation is always important, but is especially crucial with ICD-10.  When coding, always remember these golden rules:
All information about services performed must be documented
If it isn't documented, then it wasn't performed. Reviewers do not know the services provided if there is no documentation.
You are paid for what you document, not what you did
Document, Document, Document
More is always better when it comes to documentation

Palmetto GBA News
(information from Palmetto GBA)

Respond to ADRs via eServices
Palmetto has announced that physicians who are eServices users now have the advantage of submitting medical records via their free eServices. This will eliminate mailing time and costs. You will also receive a confirmation receipt letting you know when the records are received.
CMS Contractors Verify Compliance
CMS employs several review contractors to measure, prevent and identify improper payments. These review contractors manually review claims against the submitted medical documentation to verify the providers compliance with Medicare rules and regulations. These review contractors include: Palmetto GBA; Comprehensive Error Rate Testing Contractors (CERT), Recovery Auditor Contractor (RA) and Zone Program Integrity Contractors (ZPIC). With so many 'eyes' watching, you should ensure documentation is complete prior to submitting.
E/M Tip: Ancillary Staff
Ancillary staff may only document: Review of systems (ROS), Past, family and social history (PFSH), and Vital signs. These three areas must be reviewed by the physician or non-physician practitioner (NPP) who must write a statement that it is reviewed and correct or add to it.
E/M Tip: Diagnosis/Management Options-Definition of 'Additional Work-Up'
'Additional Work-up' consists of any diagnostic testing, laboratory testing, etc. and may be performed at the time of the visit.
E/M Tip: Laboratory, Radiology and/or Other Diagnostic Test Findings
The review of laboratory, radiology and/or other diagnostic tests should be documented. A simple notation such as 'WBC elevated' or 'chest X-ray unremarkable' is acceptable. Alternatively, the review may be documented by initialing and dating the report that contains the test results.
Do You Know Who Is Using Your NPI?
Coming soon to eServices, eReview will give physicians the ability to access their personal Medicare data. Palmetto plans to offer this data as part of the new eServices On Demand features. The first two features that will be available are eUtilize and eCBR.
MM9603 - JW Modifier: Drug Amount Discarded/Not Administered to any Patient
The Centers for Medicare & Medicaid Services (CMS) issued CR 9603 to alert MACs and providers of the change in policy regarding the use of the JW modifier for discarded Part B drugs and biologicals.

Effective July 1, 2016, providers are required to:
Use the JW modifier for claims with unused drugs or biologicals from single use
vials or single use packages that are appropriately discarded (except those provided
under the Competitive Acquisition Program (CAP) for Part B drugs and biologicals)
Document the discarded drug or biological in the patient's medical record when
submitting claims with unused Part B drugs or biologicals from single use vials or
single use packages that are appropriately discarded.
Find Answers to Your Medicare Questions!
If you need a quick answer to your Medicare question, Palmetto GBA offers several options.
Patient (beneficiary) eligibility and status of pending claims :
           Palmetto GBA website: eServices tool external link . This tool is free. Providers that have Electronic Submitter Agreements on file with Palmetto GBA are eligible to register. Clearinghouses and billing services: check with your provider before registering on their behalf.
Use the IVR: 855-696-0705
More information about denied claims:
   Palmetto GBA website: 'Denial Resolution' tool. This tool contains tips, links and resources for tackling the most common claim denials. Browse the tool, using a description of the procedure, explanation of the denial or remark code.

   Call the CSR line to speak with an experienced representative--855-696-0705
Rules for using modifiers:
   Palmetto GBA website: 'Modifier Lookup' tool. Find tips for documenting and submitting modifiers on your Medicare Part B claims. The modifiers are listed in alpha-numeric order, or type your modifier in the 'search' box to learn more.

   Call the CSR line to speak with an experienced representative: 855-696-0705.  
Reaching the correct department at Palmetto GBA:
   From any page on the Palmetto GBA website, click Contact Us at the top of the page, then select your state or contract to view a listing of telephone numbers, addresses and email contact information
Ask a question about something else:
   Palmetto GBA website: FAQs. Tip: you can narrow your FAQ by category using the drop-down box, or enter a key word in the Search field.

   Call the CSR line to speak with an experienced representative-- 855-696-0705
Provider administrators may recertify the provider users on their account.
Once you have been notified that your account is in the recertification period, you may recertify access for all users, including additional provider administrators, from your Admin tab. Simply click the 'Recertify Users' button to be directed to the recertification screen. Failure to recertify access for at least one provider administrator will result in termination of the entire account.
OCR Launches Phase 2 of HIPAA Audit Program
(info from HHS)
As a part of its continued efforts to assess compliance with the HIPAA Privacy, Security and Breach Notification Rules, the HHS Office for Civil Rights (OCR) has begun its next phase of audits of covered entities and their business associates. Audits are an important compliance tool for OCR that supplements OCR's other enforcement tools, such as complaint investigations and compliance reviews. These tools enable OCR to identify best practices and proactively uncover and address risks and vulnerabilities to protected health information (PHI).
In its 2016 Phase 2 HIPAA Audit Program, OCR will review the policies and procedures adopted and employed by covered entities and their business associates to meet selected standards and implementation specifications of the Privacy, Security, and Breach Notification Rules. These audits will primarily be desk audits, although some on-site audits will be conducted.
The 2016 audit process begins with verification of an entity's address and contact information. An email is being sent to covered entities and business associates requesting that contact information be provided to OCR in a timely manner.   OCR will then transmit a pre-audit questionnaire to gather data about the size, type, and operations of potential auditees; this data will be used with other information to create potential audit subject pools.
If an entity does not respond to OCR's request to verify its contact information or pre-audit questionnaire, OCR will use publically available information about the entity to create its audit subject pool. Therefore an entity that does not respond to OCR may still be selected for an audit or subject to a compliance review. Communications from OCR will be sent via email and may be incorrectly classified as spam. If your entity's spam filtering and virus protection are automatically enabled, we expect entities to check their junk or spam email folder for emails from OCR.
The audit program is developing on pace and OCR is committed to transparency about the process. OCR will post updated audit protocols on its website closer to conducting the 2016 audits. The audit protocol will be updated to reflect the HIPAA Omnibus Rulemaking and can be used as a tool by organizations to conduct their own internal self-audits as part of their HIPAA compliance activities.
OCR's audits will enhance industry awareness of compliance obligations and enable OCR to better target technical assistance regarding problems identified through the audits. Through the information gleaned from the audits, OCR will develop tools and guidance to assist the industry in compliance self-evaluation and in preventing breaches.   We will evaluate the results and procedures used in our phase 2 audits to develop our permanent audit program.
The WVSMA wants physicians to know that the audit inquiry to those lucky enough to be selected is being done by email and OCR has indicated that these emails may get caught in providers email spam folders. OCR is pulling providers by random based on NPI numbers.  We have heard hat providers are now getting the email inquiries. The OCR notification asks the provider to verify their email/contact information for the audit. Reportedly, physicians have been receiving these emails and will continue to throughout June. The email would be sent from  OSOCRAudit@hhs.gov. The WVSMA recommends that physicians check their spam filter or search to see if they have received an inquiry from OCR.

(This information is courtesy of Robert L. Coffield of Flaherty, Sensabaugh, Bonasso, LLC.
To learn more about OCR's Phase 2 Audit program, please visit the HHS website at http://www.hhs.gov
MACRA Update
(info from CMS and AMA)
The WVSMA is working to provide information about MACRA as it becomes available. Many of you participated in the MACRA physician survey during January/February, where it was determined that there is a need to provide more information in order for practices to have a much clearer understanding of the new physician payment rules. Below is some information from the AMA that may help you as you begin to prepare for these new payment methods.
First off, MACRA is going to change many Medicare program requirements. There will be two main pathways for physician payment under MACRA---one is the modified fee for service model, called MIPS (Merit-based Incentive Payment System) and the other is an advanced payment model (APM). With the APM, physicians participating in specific CMS approved models may receive an annual bonus payment.
Whether you ultimately participate in an APM or the MIPS, taking action in the following areas can position your practice for success in the future. Below are some ways you can being to prepare your practice.
General considerations:
Determine whether you have $10,000 or less in Medicare charges and 100 or fewer Medicare patients annually. If so, you are exempt from MIPS participation.
If you are not already participating in a patient clinical data registry, contact your specialty society about participating in their registry.  Data registries can streamline reporting and assist with MIPS performance scoring.
Physicians in a practice of more than one eligible clinician should decide whether to report individually or as a group.
Determine whether your practice meets the requirements for small, rural or non- patient facing physician accommodations.
MIPS: Quality measurement and Reporting
Check your Medicare Physician Quality Reporting System (PQRS) feedback reports. Make sure that you understand your current quality metrics reporting requirements and how you are scoring across both PQRS and private payers. While it is anticipated that the general PQRS requirements will stay the same under MIPS, there are some proposed changes to MIPS quality requirements and quality measures. Determine which quality measures you plan to report on; there are individual measures and specialty-specific measure sets.
Access and review the 2014 annual PQRS feedback reports to see where improvements can be made. Authorized representatives of group and solo practitioners can view the reports on the CMS Enterprise Portal using an Enterprise Identity Data Management account with the correct role.
Consider whether you plan to report through claims, electronic health record (EHR), clinical registry, qualified clinical data registry (QCDR) or group practice reporting o (GPRO) Web-interface. The GPRO Web-interface is only available for physicians in practices of 25 or more eligible clinicians.
Seek out local support for your quality improvement activities. Many local organizations such as Practice Transformation Networks provide resources and technical support, often free of charge, to help small physician practices succeed.
MIPS: Resource Use
Check your Medicare quality and resource use reports (QRURs) to see where improvement can potentially be made.
Review CMS's proposed list of episode groups at www.cms.gov.
Identify your most costly patient population conditions and diagnoses.
Identify targeted care delivery plans for these conditions.
Identify any internal workflow changes that can be made to support care delivery plans. Identify potential partners outside of your practice to advance a coordinated care plan (e.g., other specialists to whom you refer patients).
MIPS: Clinical Practice Improvement Activities
Review the proposed rule's list of clinical practice improvement activities (CPIAs) to evaluate what activities your practice is already doing and what adjustments it should make to complete additional activities in 2017.
The reporting period for CPIAs is 90 days. Consider which 90 days in 2017 would work best for your practice's selected CPIAs.
If you participate in a nationally recognized, accredited patient-centered medical home (PCMH), a Medicaid medical home model, a medical home model, or are recognized by the National Committee for Quality Assurance as a patient-centered specialty model, ensure that your certifications and accreditations (as applicable) are current. Physicians participating in these medical homes earn full CPIA credit.
MIPS: Advancing Care Information
If you have an EHR, make sure it is certified EHR technology, which is often referred to as CEHRT. Determine whether it is 2014- or 2015-edition certified health information technology;the version will determine the measures on which you report in 2017.
Speak with your vendor about how their product supports new payment model adoption. For example: How does their product support Medicare quality reporting? Document these conversations.
Consider how to ensure that you can report at least one unique patient (or answer "yes," as applicable) for each measure of the base score's six objectives. Ideas include:
Reach out to existing patients to encourage their use of patient portals to view, download and transmit their health information in 2017.
Your EHR may allow you to send a secure message through the patient portal to all of your patients at once.  If so, and doing so is appropriate for your practice, consider sending.
Conduct a careful security risk analysis in early 2017. Failure to properly do so will result in a score of zero for this category. Your risk analysis should comply with the HIPAA Security Rule requirements. 
Determine whether there is an additional public health registry to which you can report to receive an additional point towards your total Advancing Care Information score.
Alternative Payment Models
Confirm whether you are a participant in any of the advanced APMs. If not, contact your specialty society or state medical society to find out if there are APM opportunities for your practice.
Evaluate whether you are likely to meet the threshold for significant participation in an advanced APM, which would qualify you for incentive payments.
Determine whether 50 percent of your clinicians use certified EHR technology todocument and communicate clinical care information.
Payor News and Other News 
Renew Your Medical License Today!
The renewal application process for licenses for Medical Doctors (A-L) will end on June 30, 2016, at 4:30 PM EST. Renewal information may be found on the WV Board of Medicine website, https://wvbom.wv.gov.
WVSMA to Offer CMIS Certification in August

The WVSMA will offer the CMIS (Certified Medical Insurance Specialist) course beginning on Thursday, August 4, 2016. This PMI (Practice Management Institute) nationally recognized certification class explores the current landscape of third party reimbursement. Detailed lectures, course materials and examples will teach participants how to effectively expedite claims, secure timely, correct reimbursement, and protect the financial interest of the practice.
This class has not been offered in West Virginia since 2014 and will not be offered again in 2016.  Click here to register for this great class!   
New Overtime Rules
The Department of Labor has modified its proposed rule updating the salary basis, or minimum necessary salary, that employers are required to pay in order to treat employees as exempt from overtime. Under the final rule, which will go into effect December 1, 2016, an employee must be paid a minimum salary of $913 per week (or $47,476 per year) in order to qualify as exempt from overtime under most of the traditional white collar exemptions. The Department of Labor expects the new rule to extend the right to overtime protections to approximately 4.2 million more employees.

The basic rule for overtime is that workers must be paid time-and-a-half for any hours worked over 40 hours in a week. In general, all hourly employees must be paid overtime. The same overtime rules will now apply to salaried employees unless they do one of the following earn more than the salary base ($47, 476) or perform primarily executive, administrative or professional duties.

The Department of Labor last updated the regulations in 2004, 12 years ago, when it set the weekly salary level at $455 ($23,660 annually). The new "cap" will begin on December 1, 2016.
Employees who were formerly not eligible for overtime may now be eligible, so physicians and administrators may want to look to their attorney or accountant for assistance with the new employee salary issues.

SAMHSA Has New Mobile App for Suicide Prevention
(information from SAMHSA)
The Substance Abuse and Mental Health Services Administration (SAMHSA) is the agency within the U.S. Department of Health and Human Services that leads public health efforts to advance the behavioral health of the nation. SAMHSA's mission is to reduce the impact of substance abuse and mental illness on America's communities.
SAMHSA's Suicide Safe mobile app recently won the FedHealthIT Innovation Award in the Mobile Category. This award recognizes an agency's efforts to solve some of the most pressing issues through innovative ideas and solutions.
The Centers for Disease Control and Prevention recently reported that suicide rates went up in almost every demographic category between 1999 and 2014. Overall, the age-adjusted suicide rate in the United States was 24 percent higher in 2014 than in 1999.

Suicide Safe App Screen medical professionals can play a critical role in connecting individuals to care if they are at risk of suicide. About 45 percent of people who die by suicide have visited a primary care provider in the month before their death, and 20 percent have had contact with mental health services.
Suicide Safe puts SAMHSA's suicide prevention resources at health care providers' fingertips through a free mobile app for mobile devices and optimized for tablets. The app helps medical professionals identify suicide risk factors in their patients and connect them with mental health care.
Suicide Safe , SAMHSA's free suicide prevention app, is available for iOS® and Android mobile devices.

story6Other News
Register Today for the 2016 Healthcare Summit at the Greenbrier on August 26-28th!  Click here to register!

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WESGRAM is solely intended for members of the West Virginia State Medical Association (WVSMA) and PMI certified professionals.To join WVSMA, go to our website.