NARHC-News: p ublished quarterly             Your RHC News Source                              Winter 2017 Edition
Rural Health Clinics
Are Provider-Based RHCs Subject to
Site Neutral Policies?
An important bi-partisan goal of healthcare policy in this country is to shift payment from volume to value across all payers. The concept involves paying providers proactively for keeping their patients healthy, rather than paying providers every time their patients get sick, which will ideally lead to a healthier population and lower healthcare costs.
As more and more policies are created with this "value-based" approach in mind, we have seen a shift in reimbursement dollars available from inpatient and emergency services towards outpatient services. Hospitals have recognized this shift and as a result are purchasing more and more Hospital Outpatient Departments (HOPDs) because reimbursement policy continues to push more money to the outpatient side of the ledger.  read more  
RHCs & Medicare Incentive Payments (MIPS)
Medicare Incentive Payments have always been a confusing issue for Rural Health Clinics.  Since the Physician Quality Reporting System, Meaningful Use, and Shared Savings programs were introduced, RHC veterans and newbies alike have been trying to figure out how and if they apply to us.  We now have the Medicare Incentive-based Payment System to decipher. 
In my last visit here with you all, we discussed our new acronyms MACRA and MIPS.  As a refresher: The Medicare Access and CHIPS Reauthorization Act (MACRA) is the legislation passed by Congress in April 2015.  MACRA created the Medicare Incentive-based Payment System.  The question for today is, what do we do now?   read more
NARHC 2017 Spring Institute
MAR. 20-22 (M-W) -- Hyatt Regency Riverwalk -- San Antonio, TX
Conference --   20 Sessions, 10 Breakouts
Pre-Conference for RHC Beginners: Overview of RHC Basics; Cost Reports 101; Compliance Basics.
Regular Conference:  New Regulations, Civil Rights, & Emergency Preparedness; Balance Quality Measures in the RHC; Survey & Certification; Legislative Update; RHC Billing & Coding Hot Topics; RHC Adv. Billing; RHC Adv. Cost Reporting; Practice Mgm Strategies & Best Practices for Provider Based RHCs;  Practice Mgm Strategies & Best Practices for Provider Based RHCs;  Mastering HR Admin in the RHC; Strategic Planning & Making Your Goals Align; Become a Persuasive Manager & Affect Positive Change;  MAC Discussions: Novitas; Quality HIT: Don't Value It by Assets;  Policy & Procedure Manual; Medicare Incentive Payment Reform (MACRA, MIPS, APM); The Social Security Number Removal Initiative (SSNRI).  

HURRY -  Early Bird Price ends Jan 31 (registration received by date)   read more
RHCs Cannot Bill Advanced CCM

In 2017, CMS added two new "advanced" Chronic Care Management (CCM) codes to cover additional CCM services. These codes are:
-----99487 Complex Chronic Care Management (60 minutes of care management services per calendar month)
-----99489 Complex Chronic Care Management (reimbursement for each additional 30 minutes of care management services beyond 60 minutes per month)
However, the CCM benefit does NOT allow RHCs to bill for these new codes. RHCs are only eligible to bill for the original CCM code 99490.   read more
Letter from the NARHC President

Happy New Year and we hope your holiday was wonderful and filled with peace. As we start the New Year at NARHC, I would like to share with you some of our goals for 2017. First and foremost, we will continue to bring you the most current, relevant and professional conferences in the RHC community. You will not be disappointed in your attendance to the Spring or Fall Institute; our attendees' satisfaction remains very positive. I look forward to seeing you there.
Secondly, federal policy and health insurance will change! NARHC and Capitol Associates will be leading the efforts to ensure the RHC community is at the table and your issues and concerns are not only addressed but understood and considered. We will collaborate with other associations when the issues represent common concerns. If you have specific issues of concern, please let us know.   read more  
RHC Guide to the MACRA Final Rule

Q.   Is it still true that Rural Health Clinics are not required to take part in the Medicare Quality Payment Program?
A.    Rural Health Clinic payments are not affected by the new Medicare Quality Payment Program (MQPP)  This program is - at this time - exclusive to the traditional fee-for-service (claims using the 1500 claim form) part of Medicare.  RHCs are authorized to voluntarily report on the new MQPP but such reporting will have no impact on RHC payments.  CMS has not issued any guidance on how an RHC - wishing to voluntarily report - will do that.
Q:   Will my RHC All-Inclusive Rate be affected by MACRA?   read more
NARHC 2017 Membership

Now is the time to renew or purchase NARHC membership if you haven't done so already.  RHCs are the members and benefits flow to anyone who works for the RHC or has authority over, such as the hospital CEO or CFO.  Non-RHCs such as Associations, Consultants and Governmental entities are also welcome to join.

Make 2017 the year you stay informed! For rates see the Membership Application. If unsure of member status, email or call 866-306-1961 for a quick lookup.

NARHC also offers a group discount (first RHC joins for $450, each additional RHC after the first joins for $130.  We also offer discounted Joint Memberships with 3 State Assns (CA, MO, TX)!  
Renewal Memberships for existing NARHC members were billed in Dec. If we missed you -- call us!   read more
Recruiting to Rural & Underserved Areas Can be a Challenge! is a nonprofit job board specifically geared to candidates interested in rural and underserved America. 
By posting jobs on 3RNet, facilities gain access to:

* Over 53,000 actively registered candidates (we don't make cold calls - every candidate has chosen to sign up with us)
* Hundreds of new candidate registrations each month
* Over 4,000 active job opportunities across the country     read more
Fake News is a Problem for the Medical Community

The problems related to fake news and the viral spread of information online are as urgent in medicine as they are in politics, according to Robert Glatter, M.D.

Glatter  warns in a column for Forbes that even a poorly crafted headline on a legitimate story can cause trouble, since many people fail to read beyond the headline of a viral story that shows up in their social media feeds. With fake or overstated medical news, the stakes can be very high.

"Such fake news-particularly if related to a communicable disease-may have negative effects on patients' emotional and physical well being, and could even lead to suicidal ideation or suicide," says Glatter.   read more
Billing & The CG Modifier
The CG modifier became effective for all claims submitted after 10/1/16, this includes prior Date-Of-Service claims from 4/1/16 and after. The CG modifier is added to the 0521 and/or the 0900 revenue codes with the qualifying visit code, thus telling Medicare that you are submitting a qualified claim for RHC payment.  Many claims are still not paid due to the claims already being processed through the Medicare system due to the CG modifier not being on the claim. These claims that have shown on a remittance advice & not been paid & all charges adjusted off, must be adjusted & not just resubmitted. 
These claims will have to be sent as a 717 bill type & a condition code added for the reason you are adjusting the claim & the remittance document control number in FL 64 of the UB. Some condition codes require a remark in the remarks section & others do not.  The CG is the modifier that is attached to the Qualifying visit code that is also shows the "bundled' charges for the date-of-service. The subsequent lines on the claim are a detail of what is included in the "bundled" line item. If any preventive services are part of the claim, these charges are not "bundled" as there is no coinsurance applied to these services.
  read more
Animals in the Clinic

I recently provided an Annual Evaluation Report for a RHC client in a very rural area, with a lot of farmers as patients.  While there I noted a lap dog with a patient in the waiting room and asked them about their policy.  The discussion was very enlightening.
Do you ask the patient to leave?  Remove the dog?  What if the dog has mange, parasites, or doesn't have all its vaccinations and poses a risk to staff and patients?  Is the dog on a leash?  If not, how do you respond to any dog behavior problem?  Does your policy cover "service animals" that might include a pig or rooster?   read more
Looking to Reduce Your Phone & Internet Costs?

The Federal Communications Commission (FCC) created the Rural Health Care Program to provide reduced rates for telecommunications, broadband, and internet services to eligible healthcare providers across the country. This program was updated several times by the FCC to encourage greater participation by hospitals, clinics, and community mental health centers in rural areas. Currently administered by the Universal Service Administrative Company (USAC), the program requires rural healthcare providers to submit an annual application to receive funding, and the program has a cap of $400 million each fund year.   read more  
Is Your Business Associate an Agent?

There is always a lot of discussion regarding business associates and their relationships to the covered entity.  Should you conduct a pre-contract survey or questionnaire? Should you conduct a risk analysis on them or accept theirs?  Should you allow them access to our EHR/EMR to execute the duties you hired them for?  

While there are many questions, one that does get overlooked is whether the business associate (BA) is an "agent" of the covered entity.  This is an important distinction and worth looking at the definition of an agent and how it impacts your relationship with your business associate.   read more  
Rural Health Clinic Program Changes

Here are just a few suggestions to stay abreast of the ever-changing RHC rules, regulations & interpretations:
  • Become a NARHC member! RHCs & Non-RHCs may join. CLICK HERE
  • Sign up to receive NARHC Newsletters (4x a year) such as the one you are reading (if this newsletter has been forwarded to you).
  • Join one or both List Serves. The NARHC-News List Serve is our blog where anyone can post and anyone can answer. Our administration monitors & jumps in if we see wrong answers going out. You may get up to 6 emails a day if the topic is a hot one. Prefer not to get that many emails?  Still want to know about Free Trainings & Announcements? Join the Technical Assistance List Serve.  
  • Visit the NARHC website frequently: News and Legislative Updates.
  • Like us on FaceBook!    
In This Issue
Quick Links
Upcoming Events
NARHC 2017 Spr Institute
Mar. 20-22, 2017 (M-W)
Hyatt Regency Riverwalk
San Antonio, TX
Click here for  more info .
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