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

Free Webinar "EHR Stimulus - Why Moving Now Matters"

Free Webinar "EHR Stimulus - Why Moving Now Matters"
Newsletter
July 10, 2013

The EHR Stimulus payout amount will soon drop! Simply participate in our free webinar to learn how easy it really is to get your EHR stimulus check in the full amount*.
Join ChiroTouch and Dr. Gary Street “Medicare Guru” to learn about this government program. We will also have a Q&A with other practices that have gone through the process in 2012 and have received their checks.
Don’t lose out! Join our free webinar and:
• Learn what steps you can take to qualify for your EHR Stimulus funds
• Learn what your EHR system needs to provide
• Hear from chiropractors who have already attested and received their funds
• Get the latest developments on the EHR Stimulus Program
Thousands of chiropractors have received their five-figure checks from the EHR Stimulus Program - And more chiropractors have received their funds using ChiroTouch than any other software solution in chiropractic!
*Maximum payouts based on current ARRA EHR Stimulus Program

Thursday, July 11th, 10:00 AM Pacific/11:00 AM Mountain/12:00 PM Central/1:00 PM Eastern Time
Registration, follow this link: https://www2.gotomeeting.com/register/223233354

NOW IS THE TIME – DO IT TODAY!

Questions – If you have questions, or simply need information, give me a call and I will do my best to help you. This is probably the most important decision of your Chiropractic career!
Plan to attend our future Seminars:
Thursday, July 25th 1:00 to 5:00 pm
St. Louis, MO at the Hampton Inn, Westport
Call our office (618) 395-3800 to register

Going Paperless

Newsletter
May 22, 2013
Chiropractic Medicare
"Going Paperless Made Simple!"

If you have not become paperless yet, please consider making that move quickly. The final window of opportunity closes the last day of September, so you have 90 days of "meaningful use" prior to 2014. That means you need to be moving on this NOW. To make the whole thing simple, you must purchase or have a certified software.

A certified software will lead you though the process step by step. We have been using ChiroTouch for 18 months. It’s an excellent software written by Chiropractors for Chiropractors. After 44 years of S.O.A.P note writing...it’s wonderful.

We "attested" last year, have received our first incentive payment in January....NO more paper. To make the whole thing simple...The Software. There are several out there for sale. I just know about ChiroTouch. If you have questions in regard to attesting or ChiroTouch, give me a call.
More info on the CMS (Centers for Medicare and Medicaid Services) Medicare EHR Incentive Program:
https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/downloads/Beginners_Guide.pdf

(EHR) DO IT NOW!!!

Newsletter
March 19, 2013
Chiropractic Medicare
(EHR) DO IT NOW!!!

The Medicare Electronic Health Record (EHR) Incentive Program is still alive and well. Incentive direct deposits are taking place across the country in the amount of up to $18,000.00 for those who have successfully attested for 2012.

The amount of your incentive payment depends on when you began participating in the program. The incentive payment is 75% of your Medicare allowed charges up to a maximum annual cap.
"The total maximum incentive amount that you can be paid under the Medicare EHR Incentive Program is $44,000 over five consecutive years of program participation. As you can see, you receive the maximum incentive by starting in 2011 or 2012 . If you don’t start by 2014, you are not eligible to receive any incentive payment under the Medicare EHR Incentive Program." -Page 15 of "An Introduction to the Medicare EHR Incentive Program for Eligible Professionals" found here: (https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/downloads/Beginners_Guide.pdf)

Example: If you attested before the end of 2012, you have received up to $18,000.00 incentive money in your checking account. If you continue Electronic Health Records in 2013, you will receive another deposit in your checking account in the amount of up to $12,000.00. When you continue for 2014, you will receive another deposit of up to $4,000.00 and if you continue in 2015, you will receive up to a final $2,000.00 deposit.

If you start now and attest in a timely manner this year, you will receive up to $12,000.00, next year for 2013, and up to $8,000.00 in 2015 form 2014. If you wait to attest in 2014, you have waited to long, and then in 2016 you will begin receiving cuts in your Medicare fees and probably other health insurance fees for the rest of your practicing years. Those that are doing Electronic Health Records presently will continue receiving increases in the fee structure instead of cuts.

How do you begin? First, is your office software certified? If it is, then call your software company and get it going. DO IT NOW! It's later than you think! If your office software is not certified look for one that is and get going. We have used Chirotouch for over one year and love it. If you have an interest in Chirotouch give me a call and I can save you some bucks.

***NEW***

D.D. Palmer wrote "The Chiropractor" booklets each month, 1904 thru 1908. Those are what B. J. Palmer used to create the first Chiropractic Book in 1906. We now have those "The Chiropractor" booklets in two (2) large books. If you like history, these are a must! Call me or send an email for more information.

ABN Electronic

Newsletter
March 11, 2013
Chiropractic Medicare
ABN Electronic

ABN: Electronic retention of the signed paper document is acceptable. Notifiers may scan the signed paper version of the ABN for electronic medical record retention and, if desired, give the paper copy to the beneficiary (patient) at time of visit.

Centers of Medicare and Medicare Services (CMS) currently does not have a written policy on the electronic issuance of ABN’s. However, it is not prohibited. These are the CMS recommendations offered to provider/suppliers at this time:

a. If an electronic issuance system is used, the beneficiary (patient) must be given the option of requesting paper issuance over electronic, if that is what he/she prefers.

b. ABN’s can be printed for issuance, the paper copy signed by the beneficiary then scanned for electronic health record (EHR) retention, and the original paper copy can be given to the beneficiary.

IMPORTANT: Electronic issuance system can not be located and used at the front desk. The doctor must see the patient, make an assessment, then the patient may sign the ABN prior to any services today.

The ABN or Advanced Beneficiary Notice of Noncoverage link to the form
http://www.cms.gov/BNI/02_ABN.asp

The ABN or Advanced Beneficiary Notice of Noncoverage information
http://www.cms.gov/MLNProducts/downloads/ABN_Booklet_ICN006266.pdf

EHR, CBR, CAQH

Newsletter
February 25, 2013
Chiropractic Medicare
1. EHR-Registration and Attestation System.
( How much will YOU get paid?)
2. CMS A+ Government Solutions – “Comparative Billing Report, CBR Desseminator.
3. CAQH Update Reminder.
1. Meaningful Use:
We can go through the 15 core operatives, the computerized provider order entry (CPOE), drug-drug and drug-allergy checks, up to date problem list of diagnosis, E-Prescripting (eRx), or maintaining active medication list or allergy list....
Wait....it’s better than this!
First impression is that it is very difficult. Not true. It’s much easier than you think. First, you must have a certified “software”. We use “ChiroTouch”. Your certified software will walk you right through the process so you can register and attest. Don’t wait. If you have not moved on this, you are presently in the final window. You are still able to attest and receive $15,000 incentive dollars for 2013.
2. A+ Government Solutions on contract from CMS has faxed again around 5000 Medicare Comparative Billing reports. If you received by fax, this report, then you are now aware you are above your peers in either the number of visits you are seeing your Medicare patients or the CPT Codes used when billing for your Medicare patients. The report is an effort by CMS to educate providers on their billing patterns, this being helpful as an educational tool which may assist you in identifying opportunities for improvement.
Since the Office of Inspector General believes that billing Medicare with the AT modifier over 12 visits per year is medically unnecessary, and that the likelihood of a service being medically unnecessary increases even more significantly after 24 “treatments”, this report should spark your interest.
I recommend reviewing this report very carefully, compare with your in-house records for the report accuracy. If you find the CMS Comparative Billing Report statistics are incorrect, call them for corrections.
3. CAQH – Just a reminder.....the Universal Provider Data Source must be kept up-to-date. If you need to update the CAQH Universal Provider Data Source https://Upd.caqh.org/oas or Provider help desk at (888) 599-1771. Have your CAQH provider ID available.

Learn, Compliance, Paperless & Attestation

Newsletter
October 22, 2012
Chiropractic Medicare
Learn, Compliance, Paperless & Attestation
Now is not the time to procrastinate!  If you plan on being in Chiropractic practice in 2015....listen up!  You have a choice.  Either get with it or get ready to retire!

Now that I have your attention, here are the steps necessary to wade through this Medicare process.  The process is not as extreme as first impression. 

1. Learn the correct way to do Chiropractic Medicare.  If you do not do Medicare correctly, all else will not be effective.  If you have attended our presentation or have our Chiropractic Medicare DVD & booklet, review the DVD and start doing Medicare correctly.
2. The Federal law says we must become Medicare Compliant. Follow this link: http://www.cms.gov/Medicare/Medicare-Contracting/MedicareContractingReform/Downloads/compliance.pdf  They provide seven (7) categories we must respond to by creating a Medicare Compliance Program and procedures in your practice.
3. Electronic Billing and Going Paperless
1. Nearly all Chiropractic offices are billing Medicare electronically. If you are not, you are going to be left behind and soon will be cut in Medicare reimbursement. Call your Medicare carrier, ask the carrier to help you bill electronically and follow their guidelines. Do not put it it off another day.
2. Going paperless is fabulous as long as you have a good Chiropractic software in your practice. I use Chirotouch software. This software leads you through the process of becoming paperless. I have to say, after doing written notes for forty-four (44) years, it is absolutely great to make a few clicks on the computer and not only have S.O.A.P. notes completed, but also produce "Documentation" by Federal Standards for Medicare, PI, etc.
4. Attestation: Once you have used and learned the software and follow the specific programs in the software, you will be ready to "attest" as to following the guidelines of a paperless practice. The government will now pay you an incentive dollar amount in direct proportion as to the number of Medicare visits you have. Learn more about the EHR Incentive Program. Remember....only the use of Certified EHR (those that meet specific federal standards for Meaningful Use) can qualify for incentive payment.  Do you know if your software is qualified? Follow this link: http://oncchpl.force.com/ehrcert

Have questions?
Give Dr. Street a call today at (618) 395-3800.

      

Federal Incentive Payments for Implementing Electronic Health Records (EHR)

*****

Newsletter

September 10, 2012

Chiropractic Medicare INCENTIVE

Federal Incentive Payments for Implementing Electronic Health Records (EHR)

Did you know Chiropractors are eligible for up to $44,000.00 each from Medicare? So far $16.5 million has been paid to Chiropractors.  Well over 2000 Chiropractors have been paid, some even the last installment.

You must Attest Meaningful Use in a continuous 90 day period within that calendar year.  In subsequent years, after a providers first year, the reporting period is the entire calendar year. For more information follow this link: https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/downloads/Beginners_Guide.pdf

In other words, you must register this month, so you have October thru December of this year for EHR Meaningful Use.  You can still be eligible to receive the full $44,000.00 incentive by implementing EHR in your practice no later than October 3, 2012 and performing meaningful use for just 90 days in your first year.

It makes no difference as to Participating or Non-participating Provider.  If you submit claims for Part B covered services, you are eligible.  If you successfully register and demonstrate meaningful use of a certified Electronic Health Record, your incentive payment will be based on all services allowed under Part B, regardless of your participation status or whether you have accepted assignment on those claims.

Remember....only the use of Certified EHR (those that meet specific federal standards for Meaningful Use) can qualify for incentive payment.  Do you know if your software is qualified? Follow this link: http://oncchpl.force.com/ehrcert

I am so fortunate to be using ChiroTouch software that has it together.  
Questions?  Give me a call (618) 395-3800.

The Federal Incentive Payments Program is helpful, but remember you must know the correct way to do Chiropractic Medicare and also become Medicare Compliant. Once the correct way to do Medicare is understood, you are half the way. 

REMEMBER....
You are required to become Medicare Compliant prior to 2013.        
December is coming quickly.  

4010-to-5010 ~ My Filing Nightmares ~ Rejected Claims, Unreadable Reports, and Error Messages, Oh My!

4010-to-5010 My Filing Nightmares
Rejected Claims, Unreadable Reports, and Error Messages, Oh My!

Has the 4010 to 5010 transition confused you or your office staff with rejected claims, unreadable reports, and/or error messages? The following are some helpful websites and information my staff gathered while making the fun transition.

http://www.ama-assn.org/resources/doc/washington/4010-to-5010-claim-data-reporting-comparison.pdf

If you upload your claims using a clearinghouse your should get a human readable electronic report. (If you are getting a human readable report, count yourself lucky!) However, if you upload your claims directly to the Medicare Carrier you might only get a 999 file and a 277CA file. Acknowledgement for Health Care Insurance (999) and Claims Acknowledgements (277CA) will open in Notepad and contain a couple lines of code in your report because they no longer require themselves to send human readable reports. Talk to your software company and ask if they can provide the translation software. There HIPAA EDI Viewer software companies out there. More info about this topic:
http://www.wpsic.com/edi/5010-Readiness.shtml
https://www.cms.gov/Versions5010andD0/Downloads/2nd_National_Provider_Education_Call_HIPAA_Versions_5010_and_D0.pdf

If you have any questions, or suggestions please feel free to post them below. We are always looking for more information to share.

~Dr. Street

Compliance 2012

Chiropractic Medicare
"Compliance 2012"

Dear Doctors and Staff,

2012 should be an exciting year, especially for those taking the step forward, becoming compliant in Medicare and going paperless.  Big step....however, if you plan on being in practice in 2015, this is the year to get into action.

Three areas are critical for Chiropractors who wish to stay in practice after 2015.

1.  We must know and follow the Medicare guidelines.  We have all signed a contract with CMS that we know and will follow all the rules in Medicare.  With Chiropractors across the USA having a 67% Error Rate, even just filing a Medicare claim, it's pretty obvious most Chiropractors think they know how to do Medicare, but they don't.  They usually find that out after a failed audit and a donation of money back to the Medicare carrier.

2.  We must be protecting personal health information that we have collected on our patients in our office.  Specific guidelines and procedures must be followed by the doctor and all staff at all times.  Those procedures and policies of how your are protecting personal health information must be made available to your patients.

3.  We now have 11 1/2 months to become Medicare Compliant.  There are seven areas specifically presented by the government that we are required to address.  We are required to take specific action steps, develop policies and procedures, appoint Compliance Officers, etc.  It's no little job, but it is required by the government.....only if you plan on being in practice in 2015.

We do offer a Compliance Guide Book and CD.  Policies and procedures are completed, ready to be reviewed, and can be used as your Medicare Compliance Program.  It took me 2 1/2 months to develop.

Do you know the importance of learning the correct way to do Medicare by federal standards and becoming Medicare Compliant?
Have questions? Give me a call today 618-395-3800.

~Dr. Gary R. Street

Are YOU Knowing the Correct Way to Chiropractic Medicare Compliance? ~Newsletter 11/25/11

Newsletter
November 25, 2011
Chiropractic Medicare Compliance, HIPAA and
Knowing the Correct way to do Medicare

Dear Doctors and Staff,

Having spent hours, this and last month, working on documents, forms, data, office policies,and reports necessary to become Medicare Compliant in 2012, it should be completed and ready to go by November 30th.

Two points of interest:
   1.  After going through ALL the "stuff" required by federal law - I can't imagine very   many offices will prepare this themselves.
   2.  The fee we have set to sell this program is worth every dime!

The manpower, critical thinking and production of the Chiropractic Compliance Program material is staggering, let alone, understanding and producing all the different office policies for all the different categories each office must produce.  If done correctly, the implementation of the Medicare Compliance Program, with self-audits and all the policies, will have a positive effect on the Chiropractic Error Medicare Rate.

Those Chiropractors that do not go through or implement this program will stand out like a sore thumb and I am sure will be in prime position for audits from their specific Medicare carriers.

There are three (3) specific areas we chiropractors must understand and implement in our practices:
1. Learning the correct way to do Chiropractic Medicare ("The Basics" Chiropractic Medicare DVD and Booklet)
2. Protecting patient Personal Health Information (Chiropractic HIPAA book and CD)
3. Chiropractic Medicare compliance with written policies to prevent fraud and abuse in the Medicare program (Chiropractic Compliance Program book and CD)

The most profound problem we Chiropractors face is the lack of knowledge of how the Chiropractic Medicare actually functions and what is specifically  needed to "document" the Chiropractic necessity of care. (Not S.O.A.P. notes)  If you become Medicare compliant, as mandated by 2012, and still make errors in "documentation"....you have gained nothing.

Recommendation: 
For those D. C's and staff that have attended our seminars, or have purchased our Chiropractic Medicare DVD, consider ordering our NEW Chiropractic Compliant CD & book. You are on the safe road for Chiropractic Medicare Compliance!

For those D.C.'s that do not have, or know about "The Basics" Chiropractic Medicare DVD or our Seminars, we have put together a bundle so you can get all the important information at a very good cost. Please call me for more information 618-395-3162 or 800-MY-CHIRO.

Regards,
Dr. Street

Electronic Billing Electronic Health Records (EHR) ~ Newsletter October 31, 2011

Newsletter
October 31, 2011
Chiropractic Medicare
Electronic Billing
Electronic Health Records(EHR)

Dear Doctors and Staff,

Electronic Billing and Electronic Health Records (EHR) are here to stay.  If you have procrastinated and presently still doing paper claims...Listen up!

We are in a window right now that requires an ACTION STEP.  You have ONLY 60 days to call an Electronic Billing Company (contact your Medicare Carrier for references and/or fellow Chiropractors already on billing software), get the program up and running in your practice.  Make sure the software is the certified X12 version 5010 software that can handle ICD-10 Codes.

Those that are using electronic billing, your software company should be preparing to upgrade from 4010 A1 software to x12-5010 software.  They should contact you with the new downloads, do testing to be sure all is functioning like it should, PRIOR to January 1, 2012.  If they have not called or contacted you with a time for update, YOU call them.  Do NOT put it off....Call today!

Electronic Health Records (EHR) is going to take place.....with or without you.  The time is quickly getting here where we must know and follow the Medicare guidelines....Perfectly.  Every Chiropractor will be audited in 2012 and by 2015, audits will be part of the regular Medicare program built into your Electronic Health Records and overseen by your own in house monitoring.  Everything is on a time line.  If your interested in the CMS incentive of up to $44,000.00 and if you plan on being in practice in 2015......you need to get going TODAY!

FIRST....Learn the mandatory rules in Chiropractic Medicare.  You can review our "The Basics" Medicare DVD and booklet or order it today.

SECOND....If you are electronic billing presently, call your company asking about the 5010 upgrade.  If your not doing electronic billing....make it happen QUICK!

If you have questions...give me a call!  I will soon have a "Chiropractic Compliance Handbook" ready to help my fellow chiropractors and staff with becoming compliant in Medicare and Electronic Health Records transition.

Audits and Compliance ~Newsletter October 10, 2011

Newsletter
October 10, 2011
Chiropractic Medicare
Audits and Compliance
Dear Doctors and Staff,

The agreement among most Medicare educators is "nearly every Chiropractic office and Chiropractor seeing Medicare patients will be audited prior to 2014."

The audit will either be by C.E.R.T., or a company hired by your Medicare Carrier to audit for money recover (post payment review), or pre-payment review by your carrier.  The pre-payment reviews will soon make up the large majority of audits.  (That way they will have no monies out to collect back.  They simply will not pay future claims.)  Pre-payment reviews will be equal for both participating and non-participating providers.

The Patient Protection and Affordable Care Act (PPACA), signed into law on March 23, 2010, is aimed at curbing fraud, waste, and abuse in the Medicare program.  By January 1, 2012 you MUST be ready to submit claims electronically using the X12 version 5010 to Medicare and other payers.

The ICD-10 diagnosis coding will become effective.  ICD-10 will change the diagnosis codes up to eight (8) digits.  The testing period for ICD-10 diagnosis codes will be from January 1, 2012 to October 1, 2013 when it becomes mandatory.

The Health Information Technology for Economic and Clinical Health Act (HIECH Act) established programs under Medicare and Medicaid to provide incentive payments for the "meaningful use" of Certified Electronic Health Record Technology.  That will be the subject of next weeks Chiropractic Medicare Newsletter.

Since the majority of Chiropractors do not know how to document by federal standards, and all Chiropractors will be audited, a great number of Chiropractors will have to refund money back to the carrier or will be denied future Medicare payments. Our program can help you understand what must be done to prevent this problem. Please contact me with your questions.

~Dr. Street