The Department of Justice designated 12 federal prosecutors across the country as part of the Opioid Fraud and Abuse Detection Units. These Units are assigned to areas where the most opioid drug-related deaths have occurred: California, Nevada, Alabama, Central Florida, East Tennessee, West Virginia, North Carolina, Kentucky, Ohio, Pennsylvania, Michigan, and Maryland. Members of these Units also includes numerous federal, state, and local law enforcement and governing entities including the DEA, FBI, HHS, and other federal and state agencies (Medicaid Fraud Control Units, FDA, IRS, State Pharmacy Boards, etc.). These Units have a specific mandate to target physicians, pharmacists, and ancillary services (addiction treatment centers, etc.).
During my 30 years in healthcare consulting, I have seen several reform initiatives come and go.
In many cases, the initiatives have enhanced the ability of consumers to access insurance coverage and ultimately healthcare. In 1993, President Clinton proposed legislation that led to growth in Health Maintenance Organizations (HMOs) and also the HIPAA privacy standards which are still in place today. In the 2000s, President George Bush proposed changes to the Medicare program that led to the implementation of Medicare Part D coverage.
A look at the calendar tells us that we only have a short time left in 2018. That means many practices will be looking to complete their Security Risk Assessments in order to either qualify for the 2018 Merit-based Incentive Payment System (MIPS) or to simply fulfill their obligations to comply with the HIPAA Security Rule.
2017 was the first year for participation in the Merit-based Incentive Payment System (MIPS), a Quality Payment Program (QPP) implemented by CMS, to award or penalize participating clinicians with regard to future Medicare reimbursements based upon reporting under four categories:
A 2016 report from the Centers for Disease Control and Prevention (CDC) found that 20 percent of Medicare participants 65 or older don’t take their blood pressure medicine as directed.1 Additionally, 20-30 percent of prescriptions for chronic health conditions are never filled and roughly 50 percent are not taken as recommended.1
It’s been more than twenty years since the 1997 revisions to Evaluation and Management guidelines, which focus mainly on physical examination. The 2019 proposed changes provide practitioners a choice in the basis of documenting E/M visits; alleviate the burdens, and focus attention on alternatives that better reflect the current practice of medicine. The implementation of electronic medical records has allowed providers to document more information, yet repetitive templates, cloning, and other workflows have pushed the envelope on compliance in documenting the traditional elements of the visit.
Many Alabama providers participated in the Quality Payment Program in 2017, under MIPS (Merit Based Incentive Program). A handful participated in a MIPS APM (Alternative Payment Model), which is a baby step towards alternative payments, but still left the participants free from downside risks. As we pass the half-way point for the 2018 performance period, exploring risk bearing programs is on the rise.
"I believe it was divine intervention that I was sent to Aspire Physical Recovery Center at Cahaba River. The therapy team brought me back to myself."
As today’s healthcare drive pushes practices even further down the path of pay for performance versus the older models of pay for volume, administrators and executives throughout healthcare are researching and implementing ideas to provide an overall better experience for patients.
There is a lot of confusion about SSDI and SSI, the two types of disability benefits that can be received from Social Security. The definition of disability is the same under both programs, but that is where the similarity ends. The following is a very basic description of the disability programs provided under the Social Security Act, titles II and XVI.
As of September 30, 2017, the Department of Health and Human Services Office of Civil Rights (OCR) has received notices of 237 breaches. 46% occurred as result of hacking or IT security incidents; many at the business associate level. Ransomware is rampant and projected to increase 670%. As a covered entity, although a breach occurs at your business associate, under HIPAA, you are responsible for your protected health information and responding to the breach. OCR has been clear that breaches of 500 or more records will be investigated. Given the significant increase in breaches over the past few years, advance preparation is critical and can reduce the cost and burden of breach response.
An Oklahoma physician agreed on August 28, 2017 to pay the government $580,000 to resolve allegations that he violated the False Claims Act by submitting claims to the Medicare program for services he did not provide or supervise. According to the government, the physician allowed a company that employed him and in which he had an ownership interest to use his NPI numbers to bill Medicare for physical therapy evaluation and management services that he did not provide or supervise. The government further alleged that after he separated from the company and deactivated his NPIs associated with the company, he reactivated those NPIs so that the company could use them to bill Medicare for services he neither performed nor supervised.
On June 20th, CMS issued its proposed rule for year 2 of the Quality Payment Program (QPP) under Medicare Access and CHIP Reauthorization Act of 2015( MACRA). Comment period ends August 20.
As we approach the beginning of summer, our minds are likely not on summer vacation. The process of assessing our electronic medical record vendor, absorbing the details of MIPS, and making the decisions on how to prepare, is overwhelming for small practices. The transition to value based medicine has been evolving over the last 10 years in stages; adopting electronic health record, Quality Reporting, and Meaningful Use. Many administrators and physicians did not realize the importance of each project; from choosing the right EMR, to implementing it properly, therefore achieving best practice workflows.
Social Security Disability under Title II of the Social Security Act*
Surveys have shown that most Americans know little about Social Security law and the vital benefits it provides. By far, the least understood Social Security benefit is Social Security Disability Insurance (SSDI). This lack of knowledge has been measured through objective testing in various academic studies. Anecdotally, I know this to be true based on recurring questions and comments I have received from the public and clients alike over the last several decades of my work as a social security disability attorney.
In the last 10-15 years, the use of mid-level providers has increased to expand the base of patients in many practices. The Nurse Practitioner scope of practice is more flexible and there are specialty designations available to foster expertise in certain areas. The insurance companies have expanded the number of plans covering a mid-level provider’s services.
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