Medicare Compliance & Reimbursement

OIG Identifies ‘Top Management Challenges’

Practices that live in constant fear over an Office of the Inspector General (OIG) audit might think that the agency’s only challenge is which practice to scrutinize first. But the reality is that the OIG has identified ten management challenges that it faced in 2013 and will continue to tackle going forward.

The following list summarizes the OIG’s Top Management and Performance Challenges for 2013, as noted on the agency’s website at http://oig.hhs.gov/reports-and-publications/top-challenges/2013:

• Overseeing the health insurance marketplaces;
• Transitioning to value-based payments for health care;
• Ensuring appropriate use of prescription drugs in Medicare and Medicaid;
• Protecting the integrity of an expanding Medicaid program;
• Fighting fraud and waste in Medicare Parts A and B;
• Preventing improper payments and fraud in Medicare Advantage;
• Ensuring quality of care in nursing facilities and home- and community-based settings;
• Effectively using data and technology to protect program integrity;
• Protecting HHS grants and contract funds from fraud, waste and abuse;
• Ensuring the safety of food, drugs and medical devices.

HIPAA Audits May Not be Coming Soon Due to Budget Issues

You may get a little breathing room on HIPAA audits. The funding for security rule audits of health care providers seems to have dried up, the HHS Office for Civil Rights (OCR) has told the OIG.

In a new report, the OIG calls OCR on the carpet for a number of problems with its HIPAA auditing program, ranging from documentation to organization to actually conducting the audits. In one of its recommendations, the OIG urges OCR to “provide for periodic audits in accordance with HITECH to ensure Security Rule compliance at covered entities.”

“OCR explained that no funds had been appropriated for it to maintain a permanent audit program and that funds used to support audit activities previously conducted were no longer available,” the OIG says in a summary of the report. The full report is at http://oig.hhs.gov/oas/reports/region4/41105025.pdf.

CMS Postpones Stage Two EHR Meaningful Use Deadline
by 1 Year

If your electronic health record (EHR) implementation isn’t quite ready for prime time, don’t fret. That’s the word from the Centers for Medicare & Medicaid Services’ (CMS) latest announcement, which indicates that you’ll have until 2016 to meet the stage two requirements for EHR meaningful use. That deadline was previously set for 2015, giving you an extra year to meet the stage two requirements.

“Under the revised timeline, Stage 2 will be extended through 2016 and Stage 3 will begin in 2017 for those providers that have completed at least two years in Stage 2,” CMS reps said in a Dec. 6 statement. “The goal of this change is two-fold: first, to allow CMS and ONC to focus efforts on the successful implementation of the enhanced patient engagement, interoperability and health information exchange requirements in Stage 2; and second, to utilize data from Stage 2 participation to inform policy decisions for Stage 3.”

The CMS reps were quick to point out that a significant amount of progress was made during the EHR incentive program’s first stage. “Between 2009 and 2012, EHR adoption nearly doubled among physicians and more than tripled among hospitals,” the news release notes. “As of Oct. 2013, 85 percent of eligible hospitals and more than six in 10 eligible professionals had received a Medicare or Medicaid EHR incentive payment.”

To read more about the EHR stage two postponement, visit www.healthit.gov/buzz-blog/electronic-health-and-medical-records/progress-adoption-electronic-health-records.

Home Health Agencies Brace for Reimbursement-Draining Provisions to Take Effect in New Year

PECOS edits are ready to take effect. In a matter of days, it’ll be time to pay the piper if your referring physicians haven’t enrolled in PECOS as they should have.

Ordering/referring edits, or so-called PECOS edits, will take effect Jan. 6 as planned, Home Health & Hospice Medicare Administrative Contractor CGS notes in its December newsletter for home health providers.

“Billing transactions and adjustments for home health services with the ‘FROM’ date of service on or after Jan. 6, 2014, will be denied if the attending physician National Provider Identifier (NPI) and name do not exactly match the NPI and name that is on the Provider Enrollment, Chain and Ownership System (PECOS) file,” the MAC stresses.

Don’t forget: The edits will compare the first four letters of the last name, CGS reminds home health agencies. Include the first and last name as it appears on the ordering and referring file at www.cms.gov/Medicare/Provider-Enrollment-and-Certification/MedicareProviderSupEnroll/MedicareOrderingandReferring.html.

“Middle names (initials) and suffixes (such as MD, RPNA, etc.) should not be listed in the ordering/referring fields,” the MAC instructs.

Meanwhile: Getting a repeal of home health rebasing was a near miss in congressional budget negotiations for 2014, reported the National Association for Home Care & Hospice in a call on the issue. But “the home care and hospice community is well-positioned to see either a rollback or repeal of the detrimental rule in the early part of the New Year,” the trade group believes. The move will require a major grassroots effort from the industry, however, NAHC cautions.

At least Congress’ budget legislation didn’t include harmful provisions such as home health copayments, observers note.