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Today's Practice Issues - Recent Developments....Be Aware....Be Informed....


  • Anesthesia Practice Today - The CRNA of The Future
  • CRNA Anesthesia Practice Expansion Issues and Considerations
  • National Provider Identifier Database Accessible and Operational
  • Critical Access Hospital Criteria
  • Payment for Anesthesia Services by CMS/Medicare National Coverage Policy
  • Doctors Collaborate to Find a Less Costly Way To Add Electronic Medical Records - Jayna Broadston
  • Non-HIPAA Compliant Claims Denied after October 1, 2005
  • Medicare Deadline Non-HIPAA Compliant Claims No Longer Accepted After October 1, 2005 (AFEHCT)
  • Critical Access Hospital Billing Option 2 Criteria Update of Critical Access Hospital Instructions
     
  • Timeline for Medicare's Transition to the National Provider Identifier (NPI)
  • States that have Opted Out of the MD Supervision Rule with the Centers for Medicare and Medicaid
  • MC MD Scarcity Docs - Automatic 5% Medicare Bonus Paymeny to MDs in Designated Scarcity Zip Codes Effective With Dates of Service 01-01-2005 and beyond.
  • Anesthesiology News - Propofol Use Unsafe When Administered by non-Anesthesia Providers
  • CERT Alert - Comprehensive Error Rate Testing-Post Payment Audits
  • CPT 99231 vs. 01996 - Effective 10-2003
  • HIPAA Security Rules - Health Insurance Portability and Accountability Act-Security
  • CMS Issue - CRNAs and CPT-4 36489 Replacement Codes - Central Lines
  • NPI - National Provider Number Information

     Medicare 855I, 855B, and 855R Documents 

       The Medicare 855I document -the application process to receive a Medicare Individual Provider number- is a very detailed and lengthy process as well. This multiple paged application 855B- The name of the Medicare provider application for a group of providers, or the 855I- The name of the Medicare provider application for an individual provider, or the 855R- The name of the Medicare application to reassign payable benefits of a Medicare provider to another group or entity and their related documents are quite time consuming to complete. If even a minor appearing item is not completed or answered correctly, the entire application will be returned to the provider for correction or attachment of additional items. Once the documents are returned to the individual or entity that submitted the application, the documents can NOT be returned to Medicare without the proper re-certification statement attached as well. Once returned, the application is then accepted in the order it was received. It is not uncommon for the 855I, 855B, or the 855R to take up to 8-12 weeks to be processed by the Medicare carrier once the payer has received the Medicare Provider Application. The 855I requires numerous attachments that include provider's license, certification, and diplomas. Also remember that certain business structure documents must accompany the 855B and related documents when requested. Documents such as Tax Identification assignment documents from the IRS, partnership agreements, billing services agreements, as well as Articles of Incorporation for corporate entities to name a few. The next challenge on the Medicare providership horizon becomes reality in May 2005. All providers will be required to enroll for an unique national provider number, the applications above will soon be a thing of the past and be replaced by a universal application. Once the universal application is processed with a unique number or PIN# it is anticipated that this unique provider ID will be then adopted by all payers to identify each provider. At the present time, the unique provider ID applications are not scheduled to be available until shortly before May 2005.

    As a part of the Practice Management Services clientele, BCS takes the majority of the "pain" out of these processes by preparing these documents in part for you and your group. BCS is the only complete alternative. This is why we say, ...BCS truly does it all!

     Credentialing / Re-Credentialing / Contracting with Non-Medicare Payers 

       Since BCS is the only complete and totally comprehensive Practice Management Firm of its kind... the phrase credentialing and re-credentialing of providers is more than likely a part of every day's discussion at BCS. These terms refer to the lengthy pre-application/application/contracting functions required to become a participating provider with a government or non-government sponsored managed care plan. Participation with a particular payer's managed care product lines is extremely important to the financial survival of your practice. When considering a participation status with those non-government sponsored plans, you need to identify the overall fee schedule proposed, evaluate that schedule's impact on your practice, negotiate with the payer regarding that fee schedule, and the move to implement the participation status if in fact you select to do so. The entire pre-application/application/contracting process can easily take 120 days or more to complete after the documents have been received by the managed care entity. BCS is an expert at working through these major details and has specific Credentialing Team Specialists assigned to perform and carry out these important responsibilities daily. Furthermore, in today's every changing healthcare marketplace, the need to constantly evaluate, re-evaluate, and consider new manage care participation opportunities never appears to end. Keep in mind that during this often times very lengthy application process, your group will NOT be a recognized participating provider and more than likely will not be so in a retroactive fashion as well. This important factor increases the complexity and urgency of evaluating all managed care opportunities entirely.

     Medicare Changes Definition of Anesthesia Time
    Allowing Blocks of Time to be combined

       Yes it is true, Medicare has issued a modified definition of anesthesia time which allows the provider to add or combine blocks of treatment time. This modification has come about as Medicare recognizes that certain types of treatment or procedures require "set up" time. These blocks of time can now be combined and billed as total anesthesia minutes. Below is the actual modified definition of anesthesia time for your review.

     How are we certain we are maximizing CRNA reimbursement within our facility? 
    BCS, Incorporated Waconia, Minnesota

       This is an excellent 'opener' at a meeting with facility administration for any department head of an anesthesia department when the topic of anesthesia revenue comes up. Professional services in the anesthesia department may well be the only department within the facility that potentially has untapped revenue available for today's educated and 'street smart' healthcare administrator. I say 'street smart' because today's effective healthcare administrator needs to think entirely 'out of the box' to develop methods of efficiency and revenue enhancement and identification that have not been previously tried and tested within today's healthcare marketplace. Professional services revenue is available to anyone that employs or contracts with anesthesia providers whether physician or CRNA. Another 'out of the box' theory is to grasp professional services revenue and own it, manage it, measure it, and control it so that the employer or contractor of the anesthesia group is in control of the economic drivers that are present within the marketplace for anesthesia. Only then will the 'street smart' healthcare executive maintain the ability to state that they are maximizing their CRNA reimbursement.

    In order to determine if your facility can answer this question in the affirmative, you will need to essentially dismantle the anesthesia professional fees within your facility and analyze the current methodology that is in place. The duration or total anesthesia time is only one element of this puzzle and if time is the only element utilized within your institution then financial losses are imminent. BCS has designed our Anesthesia Practice Impact Study process to do just this identify current revenue generators, breakdown their methodology, compare and contrast to industry standards, and layout the changes that are needed to make certain you can affirmatively answer the question, "How are we certain we are maximizing CRNA reimbursement."

     Payment for Performance (P4P) In Today's Healthcare Marketplace 
    BCS, Incorporated Waconia, Minnesota

       Inside the loop at the Centers for Medicare and Medicaid (CMS) the latest buzz phrase in DC these days is 'Payment for Performance.' Facing some extremely difficult budgetary dilemmas, the Washington crowd is considering revamping the payment mechanisms for physician services to reflect some aspect of performance. Taken from the leaders in the private healthcare payer community, the concept of payment for performance, or reward for better than average performance is being touted as one possible savior to the budgetary woes of CMS. The greatest concern amongst physician and non-physician providers that are reimbursed by CMS's Part B Program and would be impacted by any "revamping" of the Part B reimbursement system, is how will performance be evaluated and measured? Will performance in fact be based upon quality of care, comprehensiveness of care, or cost effectiveness of care? Irregardless of which of these aspects may be selected as the measuring stick of performance, what will be the benchmark of performance that CMS may use? Subtle commentary from CMS indicates that they would like to see providers be proactive in assisting in the design of such a system of measuring performance.

       Private managed care entities have been rewarding primary care providers for similar achievements in the past, but the measuring stick in those instances has almost always been costs, reduce the costs to provide care and a portion of the savings will be passed along to you. It appears that the current flavor of P4P is considering a much more sophisticated measuring stick. One that takes into consideration the sometimes intangible aspect of "quality." The measurement of quality is somewhat subjective. Yes there are ways to scientifically measure quality in healthcare, but to what extent is the level of quality simply expected verses the measurement of quality that goes beyond the norm. For example, certainly an expectation of a surgical procedure would be successful repair of a defect or damaged portion of the patient's anatomy, but someone else may simply measure success in the fact that the patient survived the procedure. A third may measure quality by the element of time. Measuring the amount of time, spent testing and / or researching the patient's presenting condition that was required to arrive at any given solution or diagnosis. All have positive outcomes to some degree, obviously the quality outcome would be the survival of the patient, the achievement of repairing the damaged or defective area, and doing so in the shortest period of time with the least interruption of the patient's daily life. But that is in a perfect world and that is only a potential measurement of the primary treating physician. What about all of the other medical service providers involved in a patient's care that would be subjected to a quality measure, all of which may be impacted by the success or failure of the primary care physician.

       As we move closer to determining the benchmark of quality in healthcare we find ourselves looking at outcomes and determining what a quality outcome really is, and then using that as a measuring stick up against the majority of healthcare services provided. The danger in this is that we may mis-identify quality, after all there are no guarantees in the field of medicine, there is always some risk. Furthermore, the field of healthcare is very interdependent on the exhaustive networks of many healthcare providers across any given delivery system. An exhaustive network that is only as efficient, or as able to provide or produce a quality outcome as the least member of the network. There are always extraordinary clinicians that will devote their lives to achieving the best possible outcomes for their patients but may in fact find that the outcome or quality may be as unique as the individual they are treating. Without the risks, risks defined as the potential of a less than quality outcome, associated with some treatments and research in healthcare we may have never achieve some of healthcare's greatest accomplishments. Therefore, we need to tread lightly on this extraordinary issue so that we do not trample or stifle the effervesces and desire of achievement held so close to the heart of our nation's healthcare providers in the light of identifying quality.

    Copyright 2008 BCS, Incorporated All Rights Reserved. All materials here not otherwise noted, are the sole property of BCS, Incorporated and Lee S. Broadston. Downloading is not permitted without written permission from BCS, Incorporated prior to publication.