Jul 11, 2013| Erica Cohen
Hopefully, yesterday’s post was a good HIPAA Final Omnibus Ruling jumping-off point and, as a result, your curiosity is piqued as to how these new rules apply to you and your clinic. Well, we won’t waste any more of your time in this introduction—after all, September 23, 2013, will be here before we all know it. So here you go:
The American Medical Association (AMA) published some great information to help physicians navigate this new ruling, which also applies to rehab therapists. According to the AMA, providers should focus most heavily on these three areas:
1. Privacy, Security, and Breach Notification Policies and Procedures
Department of Health and Human Services, HIPAA Omnibus Rule, HITECH, PHI, protected health information
- You now must notify affected patients if there is a protected health information (PHI) breach unless—after completing a risk analysis—you determine that there is a “low probability of PHI compromise.”
- If a patient has paid out-of-pocket, you must honor that patient’s request not to disclose information to a health plan about his or her care, unless it is to further treatment or is required by law (which is rare).
- You may only tell a patient about a third-party product or service if that patient provides you with written authorization, unless—generally speaking—the communication:
- doesn’t result in you receiving compensation;
- takes place face-to-face;
- involves medication the patient is currently prescribed (from which you’re not making a profit);
- involves general health promotion (rather than the promotion of a specific product or service); or
- involves government-sponsored programs.
Jul 10, 2013| Erica Cohen
Just when you thought you knew all there was to know about HIPAA, The Department of Health and Human Services (HHS) issued their final omnibus—which means it contains or includes many items—ruling. Although the ruling went into effect March 26, 2013, Covered Entities—that’s you—and Business Associates—that’s us—have until September 23, 2013, to comply. According to Carols Leyva, author of “HIPAA Omnibus Rule” on HIPAASurvivalGuide.com, these changes fall somewhere between a “tweak” and a “sweeping reform.”
According to the HHS executive summary, the final ruling consists—generally—of the following four items, which we’ve attempted to paraphrase below but strongly recommend you read straight from the horse’s—ahem HHS’s—mouth here.
1. Final changes (proposed on July 14, 2010) to:
a. Make Business Associates of Covered Entities directly liable for compliance with certain requirements of the HIPAA Privacy and Security Rules.
b. Strengthen limitations on the use and disclosure of protected health information (PHI) for marketing and fundraising, and prohibit the sale of PHI without authorization.
c. Expand individuals' rights to receive electronic copies of their health information and to restrict disclosures to a health plan concerning treatment for which the individual fully paid out of pocket.Department of Health and Human Services, HIPAA Omnibus Rule, HITECH, PHI, protected health information
Jul 9, 2013| Ben Fung
#BrandPT. If you're not part of this discussion, you should be—regardless of whether you’re a physical therapist, occupational therapist, another allied health rehab therapy professional, personal trainer, physician, dentist, or nurse. Why? Because the #BrandPT Twitter discussion revolves around empowering an important segment of the healthcare industry—physical therapists—and thus empowers the entire industry as a whole.
However, this post really isn't about #BrandPT specifically. It has to do with the overall mission to rebrand the physical therapy profession. Just as nurses, physicians, optometrists, and podiatrists have all evolved their identities, physical therapists also must rebrand themselves to the public.
Okay, it’s time for a Geek Moment: two points create a line. Add direction and magnitude, and now you have a force to deal with—now, you have a vector.
Jul 8, 2013| Stacey Abelman
With all of the updates in the therapy landscape today, it’s crucial to stay on top of the changes. Managing your accounts receivables is more important than ever. In June, I had the opportunity to speak at the APTA 2013 Conference in Salt Lake City, Utah. There, I shared my ten tips for better accounts receivables. Conference attendees were abuzz with all the upcoming regulatory changes: functional limitation reporting, HIPAA, PQRS, ICD-10. With these all looming, they were definitely interested in ways to maximize their AR.
So, how do you ensure your claims are clean? How do you make sure that you don’t waste time resubmitting claims? Check out my presentation from APTA 2013 to see my ten tips to help you stay on top of your payers, receive timely payments, and get prepared for ICD-10 and PQRS.A/R, accounts receivable, APTA, best practices, billing, FLR, functional limitation reporting, HIPAA, ICD-10, PQRS
Jul 5, 2013| Erica Cohen
Medicare and HIPAA regulations aside, there’s been a lot of recent legislation impacting rehab therapists across the country. Here, we provide a breakdown of four key bills given the green or red light in 2013:
1. AB 1000: Green Light
On May 29, 2013, in a vote of 72–0, the California Assembly passed California Physical Therapy Association (CPTA)-sponsored AB 1000, which allows patients direct access to physical therapy (for 45 days and 12 visits) without a physician diagnosis. As a compromise, elements of AB 1003—sponsored by the California Medical Association (CMA) and the California Orthopaedic Association (COA)—became part of AB 1000. Consequently, AB 1000 also allows any professional corporation listed in the Moscone Knox Act to employ all professions in the Business and Professions Code, including physical therapists. In other words, physician-owned physical therapy services (POPTS) are now legal in the state of California.
The response from the physical therapy community has been mixed and—well—heated might be an understatement. WebPT Co-Founder Heidi Jannenga published her stance against AB 1000 in an article—which we’re particularly fond of—on the WebPT blog last month. In part, she writes: “This bill essentially trades small gains in direct access for legalization of physician-owned physical therapy services (POPTS)...By legalizing POPTS, the California Assembly has essentially allowed physicians to, in a very literal sense, take ownership of rehab therapy.”
Allan Besselink posted an article on his blog titled, “California AB 1000: Do What is Right, Not What is Right Now.” In it, he sums up the “compromise” like this: “Quiz time: What happens when you add one bad bill to one good bill? Answer: California AB 1000.” In Besselink’s opinion, AB 1000 and AB 1003 shouldn’t have been combined because “they are two separate issues that have two significantly different incentives, goals, and results.” Namely, that providing a patient with direct access decreases the overall costs of care whereas allowing physicians to own physical therapy services increases the overall cost of care.
Physical therapist and active industry writer, Julie Whitman posted an article on the Evidence in Motion blog originally supporting the bill, but after learning that PTs were not in fact destined to lose the fight against POPTS, she changed her mind: “I admit that not only may my initial position be wrong, but that is is LIKELY WRONG [emphasis in original].” Scroll to that article’s comment section to read Julie’s full change of heart as well as the other responses—33 in total as of June 27—including one from CPTA President Dr. James Syms in support of the bill. There’s a lot of great information and some very strong opinions on both sides of the issue.
Jul 3, 2013| Erica Cohen
Last month, WebPT hosted another fantastic functional limitation reporting (FLR) webinar. If you missed it or simply want a refresher, this post is for you. Here were the most frequently asked questions and answers:
Q: How do I handle functional limitation reporting after July 1 for a current patient with no FLR data on record?
A: If you haven't submitted functional limitation reporting data on a patient prior to July 1, you should submit it (current and goal status G-codes plus severity and therapy modifiers) on the first claim with a date of service after July 1. WebPT strongly encourages you to begin functional limitation reporting on all qualifying visits immediately to ensure you continue to get paid following July 1.
Q: What G-code category does pelvic pain or incontinence fall within? How about pain or wound care?
A: Often, a patient seeking your services for wound care or pain of any sort also experiences a specific functional limitation as a result. For example, if the wound is on the leg, the patient may have limited mobility (Mobility: Walking and Moving Around). Or the pain could impair a patient’s ability to dress, bathe, or perform other activities necessary to caring for himself or herself (Self Care). Incontinence also falls within Self Care.
If this is not the case, and the patient is presenting with no functional limitation that falls within the predefined categories, you may use the “Other” category. Either way, be sure to clearly document the justification of your selection within your notes.
Jul 2, 2013| Heidi Jannenga PT
The current healthcare system is broken. That’s clear—regardless of your political point of view. To be honest, I’ve been a bit of a naysayer in the past about the government’s capacity to be the driving force in healthcare reform—to improve standardization, which ultimately is the key to providing and scaling quality health services. However, after listening to and speaking with several leaders in government healthcare IT, I feel differently. In fact, I now know that they get it, that there are both good ideas and good intentions behind these changes because they all add to something greater. ICD-10 is one of these changes.
In mid-June, I attended the HIMSS ICD-10 Conference in Washington, D.C. The US is the last country in the world with modern healthcare to adopt ICD-10 diagnosis codes—for perspective, Canada, the second-to-last adopter, implemented them in each province between 2001 and 2005. So why transition to ICD-10? Well, besides catching up with the rest of the world, ICD-10 will allow providers to be even more specific and exact in describing patient diagnoses, thus improving interoperability, data sharing and outcomes, evidence-based practice, and ultimately public health.
With so much to absorb in just three days, you can imagine that I may have felt a little overwhelmed. Nevertheless, I took copious notes, and here are the most important things I learned from such interesting speakers as Farzad Mostashari, Denise Buenning, and Mark Lott:
Jul 1, 2013| Brooke Andrus
Oops! You had your head in the proverbial sand regarding all of this functional limitation reporting mumbo jumbo, and now you need a crash-course—stat! Luckily for you, we’ve put together a quick study guide to help you cram for the big change. Think of it as your FLR CliffsNotes—a condensed summary of this new Centers for Medicare & Medicaid Services (CMS) requirement and what you need to do to stay compliant. So, let’s get to it. Here are the main things you need to know about functional limitation reporting (follow the links to learn more about each item):
- If you do not complete functional limitation reporting, CMS will not reimburse you for your services.
- Functional limitation reporting applies to all practice settings that provide outpatient therapy services.
- You must perform functional limitation reporting on all patients you bill under Medicare Part B.
- The functional limitation reporting mandate only applies to patients using Medicare proper as their primary or secondary insurance. It does not include patients with Medicare replacement or Medicare Advantage plans.
- If you have not already started completing functional limitation reporting for your Medicare patients, you must do so on a patient’s first claim with a date of service after July 1. (Tweet this!)
Jun 27, 2013| Tom Ambury
Wow, can July 1 really be right around the corner? Seems like yesterday we were only finding out about the requirement to document and report functional limitation G-codes and severity/complexity modifiers, and I think it really was only yesterday that CMS figured out how they would work.
Let me start by making sure you understand that functional limitation reporting (FLR) and PQRS are separate and distinct programs and that each program has its own set of codes to report. They are not the same. What I would like to do today is answer some common questions that I have received about FLR G-codes and modifiers. Let’s start with:
What’s important to know?
Participating in FLR is mandatory. Reporting the appropriate G-codes and modifiers is a condition of payment. Needless to say, anytime CMS modifies our condition of payment, we have to take it seriously. Fortunately, it is not that difficult to comply with these changes.
Jun 26, 2013| Ann Wendel
Due to all of the recent changes in Medicare documentation and billing requirements, I have had an increase in the number of questions from other physical therapists regarding cash-based services for Medicare patients.
In past articles, I have discussed the inability of physical therapists to “opt out” of Medicare (here and here). Today, though, I want to discuss the provision of wellness services on a cash-pay basis for Medicare-age clients.
I have not been able to find a detailed definition of what constitutes “wellness services” for Medicare patients; however, the general consensus among those of us who are cash-based providers is that we provide wellness services when we are not treating a specific injury, pain, or dysfunction and we are maintaining a level of fitness/strength and/or we are preventing falls or decline of health. Jarod Carter does a great job of explaining this here.