Open Enrollment and ICD-10

Newsletter

December 11, 2014

Chiropractic Medicare

"Open Enrollment and ICD-10"

 

2015 Medicare Participation Enrollment period is open, running from mid-November through January 31, 2015. This Open Enrollment Period gives Medicare Providers the opportunity to change their participation status. You can also access your new 2015 Medicare Fee Schedule by going to your carrier’s website.

If you choose to change your Medicare Participation status, you can do so with a certified letter to your Medicare Carrier indicating your change in the Medicare Part B Program effective January 2015. (Those in possession of our Chiropractic Medicare DVD and booklet, see example letter page 42 in booklet.)

CMS has released their final ICD-10 rule, indicating implementation of ICD-10 will occur October 1, 2015 with no further delays.

The implementation of ICD-10 will require us to change the way we called patient data and document in our charts. The change that must occur deals with being more “specific” to the highest degree. The more specific the data collecting and documentation the easier it will be to find the correct ICD-10 code. If you are using a certified software with all of its parts, when your data collecting is complete, your software should be able to do the conversion automatically from ICD-9 to ICD-10. Please make sure to communicate with your certified software company about getting the new ICD-10 codes and training for correct use.

Insurance companies are determining, with clarification from CMS, which specific codes are to be used and acceptable by providers. The key will be specific data collecting on all preliminary forms so that your software can either do the conversion or prompt you for more specificity to choose the correct ICD-10 code. DO NOT WAIT to review your data collecting for “specific” information. If you wait until October 2015 you could have a long spell of no commercial insurance or Medicare reimbursement.

Remember, while preparing for ICD-10 implementation, we must still be doing Medicare correctly. Also, doing Electronic Health Records or “EHR” (being paperless) is only one part of the seven steps necessary to become Medicare Compliant. You can either write your own Medicare Compliance Policy Book activating the requirements in your office, or you may purchase a Medicare Compliance book like you did with HIPAA.

November 2014 Seminars

November seminar dates. 4 CE credits available.

Date: Saturday, November 15, 2014
Time: 8:30 AM - 12:30 PM
Location: Portland, Oregon
Location address:
 Holiday Inn-Portland/Airport
 8439 NE Columbia Blvd.
Portland, OR 97220
Hotel phone: (503) 256-5000 for direction purposes only
To register or for questions please call: (618) 395-3162

Date: Thursday, November 13, 2014
Time: 6:00 PM - 10:00 PM
Location: Mukilteo, Washington
Location address:
 Staybridge Suites
9600 Harbour Place
Mukilteo, WA 98275
Hotel phone: (425) 493-9500 for direction purposes only
To register or for questions please call: (618) 395-3162

Date: Thursday, November 13, 2014
Time: 8:30 AM - 12:30 PM
Location: Pacific, Washington
Location address:
 Quality Inn & Suites
 415 Ellingson Road
Pacific,  WA 98047
Hotel phone: (253) 288-1916 for direction purposes only
To register or for questions please call: (618) 395-3162

You Must Meet the Requirements for Core Measure #15

I need a Security Risk Analysis? What is that? I get calls from Chiropractors or their staff with this question every week. Here is the information and links to help you better understand Core Measure 15.

But first, from: http://www.healthit.gov/providers-professionals/certification-process-ehr-technologies

“The Office of the National Coordinator for Health Information Technology (ONC) Certification Program provides a defined process to ensure that Electronic Health Record (EHR) technologies meet the adopted standards and certification criteria to help providers and hospitals achieve Meaningful Use (MU) objectives and measures established by the Centers for Medicare and Medicaid Services (CMS).

Eligible professionals and eligible hospitals who seek to qualify for incentive payments under the Medicare and Medicaid EHR Incentive Programs are required to use certified EHR technology.”

Translation: The Certified Software you purchased is required to meet certain criteria in order to be a Certified Technology by the ONC. The job of the software is to help you meet all of the requirements. They are all set up basically the same and have training requirements, video tutorials, how-to documents, and support staff available to you. It is important and necessary to use not only the software but to use the training and support available to your office.

The Core Measure #15, also referred to as “Protect Electronic Heath Information”, or “Security and Risk Analysis”

This Core Measure has been wreaking havoc on Chiropractors. It isn’t a number to report found on your Dashboard. It’s a report or template that should be provided by your software company and completed in your office during the reporting period. A security risk analysis comprises the following parts: Risk Analysis, Risk Management, Sanction Policy, and Information Systems Activity Review. Think of it as an audit of your software and how you and your staff are protecting the fragile information contained therein. It should be easy to get these 4 templates or forms, run the audit, complete the forms, and file them in a safe place. The problem is most offices skip this step, and attest “YES” anyway. Later, when asked by CMS to provide their Risk Analysis they fail to provide and have to pay their incentive back.

The Measure states: “Conduct or review a security risk analysis in accordance with the requirements under 45 CFR 164.308(a)(1) and implement security updates as necessary and correct identified security deficiencies as part of its risk management process.”

Going further, below you will find better description of the 4 things you need:

(From: http://www.gpo.gov/fdsys/pkg/CFR-2003-title45-vol1/pdf/CFR-2003-title45-vol1-sec164-308.pdf)

164.308(a)(1)(i) Standard: Security Management Process. Implement policies and procedures to prevent, detect, contain, and correct security violations.
(ii) Implementation specifications:
(A) Risk analysis (Required) - Conduct an accurate and thorough assessment of the potential risks and vulnerabilities to the confidentiality, integrity, and availability of electronic protected health information held by the covered entity
(B) Risk management (Required) - Implement security measures sufficient to reduce risks and vulnerabilities to a reasonable and appropriate level to comply with 164.306(a). (Link found here: http://www.gpo.gov/fdsys/pkg/CFR-2010-title45-vol1/pdf/CFR-2010-title45-vol1-sec164-306.pdf)
(C) Sanction policy (Required) - Apply appropriate sanctions against workforce members who fail to comply with the security policies and procedures of the covered entity.
(D) Information system activity review (Required) - Implement procedures to regularly review records of information system activity, such as audit logs, access reports, and security incident tracking reports.

*****

More links regarding Core Measure #15. Some are full of long explanations, but still full of information.  

http://www.hitechanswers.net/meaningful-use-measure-and-hipaa/
http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/SecurityRiskAssessment_FactSheet_Updated20131122.pdf
http://www.healthit.gov/sites/default/files/pdf/privacy/privacy-and-security-guide.pdf
http://www.hhs.gov/ocr/privacy/hipaa/administrative/securityrule/rafinalguidancepdf.pdf
http://www.youtube.com/watch?v=ml4okcBxN6c
http://www.youtube.com/watch?v=1fDvzznChhg

Important “Little” Things in Chiropractic Medicare

Important “Little” Things in Chiropractic Medicare

• Item 14, date of current, must never be over 60 days old. When billing a covered service with an “AT” modifier (active treatment) and date of current is over 60 days old, this claim will be denied or flag an audit. 
• Treatment plan: Absence of a treatment plan is the greatest reason chiropractors lose their audits. A treatment plan may be one to 6 visits with an exacerbation as long as it is documented with a Federal Document.
• Maintenance care: For those chiropractors “treating” patient symptoms instead of correcting vertebral subluxations, think about this: Your patient is taking 9 prescription drugs, 5 being pain killers. They can’t feel anything from their waste down and you are going to call your adjustment “Maintenance care” because they have no pain? Need to rethink what your job really is.
• Medicare Replacement Plans: A Medicare replacement plan is a “cheaper” type of Medicare coverage that costs less with co-pays. The problem: Some Medicare replacement plans are IN Medicare and some replacement plans are OUT of Medicare. 
• IN Medicare plans, you must follow Medicare guidelines.
• OUT of Medicare plans, your patients are like any other patient out of Medicare and you do not have to follow Medicare guidelines UNLESS you bill the Medicare replacement company…. Now you have to follow Medicare guidelines. 

This is just a small example of the important Medicare information in our Seminars and/or in our Chiropractic Medicare DVD.

Seminars in Spring 2014

To register or for questions please call: (800) 692-4476

Date: Saturday, May 31, 2014
Time: 8:00 AM - 12:00 PM
Location: Mishawaka, Indiana
Location address:
 Holiday Inn Express

420 University Drive

Mishawaka, IN 46545

Hotel phone: 574-277-2520 for direction purposes only

CANCELLED
Date: Saturday, April 12, 2014
Time: 8:30 AM - 12:30 PM
Location: Reno, Nevada
Location address:
 Holiday Inn Express

2375 Market Street

Reno, NV 89502

Seminars in March 2014

New Seminar dates!!

Date: Saturday, March 29, 2014
Time: 8:30 AM - 12:30 PM
Location: Portland, Oregon
Location address:
 Holiday Inn-Portland/Airport
 8439 NE Columbia Blvd.
Portland, OR 97220
Hotel phone: (503) 256-5000 for direction purposes only
To register or for questions please call: (618) 395-3162

Date: Thursday, March 27, 2014
Time: 6:00 PM - 10:00 PM
Location: Mukilteo, Washington
Location address:
 Staybridge Suites
9600 Harbour Place
Mukilteo, WA 98275
Hotel phone: (425) 493-9500 for direction purposes only
To register or for questions please call: (618) 395-3162

Date: Thursday, March 27, 2014
Time: 8:30 AM - 12:30 PM
Location: Pacific, Washington
Location address:
 Quality Inn & Suites
 415 Ellingson Street
Pacific,  WA 98047
Hotel phone: (253) 288-1916 for direction purposes only
To register or for questions please call: (618) 395-3162