Medicare Compliance & Reimbursement

Industry Notes:

Keep Your Compliance Calendar on Task or Face the Consequences

Plus: Get ready for the Medicare card makeover in 2018.

Don’t shelve that compliance checklist just yet, new advice from the HHS Office of Inspector General suggests.

In the past, the OIG “updated its public-facing Work Plan to reflect … adjustments once or twice each year,” the agency noted on its website, adding that starting on June 15, 2017 it plans to release updates monthly.

The OIG’s “work planning process is dynamic and adjustments are made throughout the year to meet priorities and to anticipate and respond to emerging issues with the resources available,” the OIG explains. This change “will enhance transparency around OIG’s continuous work planning efforts.”

Key Medicare targets: A few of the “Recently Added Items” to make the monthly updates concerns opioid issues under Medicare Part D and will “build on OIG’s previous work and include in-depth analysis of opioid utilization among Medicare Part D beneficiaries,” the brief notes.

Medicare reimbursement initiatives will also be added to the OIG watch list with monthly reviews of quality measures reporting standards met by providers and suppliers who create or join Accountable Care Organizations (ACOs) under Medicare Shared Savings Programs (MSSPs), the website suggests. This line item on the monthly update goes hand-in-hand with the OIG’s review and upkeep of MACRA’s Quality Payment Program transition.

The OIG hopes to “assess the Centers for Medicare and Medicaid (CMS’s) progress in addressing key challenges to implementing the Quality Payment Program (QPP), a new initiative intended to shift Medicare from a volume-based payment system to one that rewards value,” the Work Plan summary says.

This new OIG guidance suggests that the revised and more timely Work Plan is a work in progress. “This web-based Work Plan will evolve as OIG continues to pursue complete, accurate, and timely public updates regarding our planned, ongoing, and published work,” the website maintains.

Resource: To take a look at other “Recently Added Items” to the new monthly OIG Work Plan and the statement addressing the increased compliance reviews, visit https://oig.hhs.gov/reports-and-publications/workplan/index.asp.

In other news …

Medicare cards are getting a revamp in 2018. With a start date sometime in April of 2018, beneficiaries will no longer be identified by their Social Security Numbers on their Medicare cards. The time to prepare your staff and patients for that change is now.

“The Centers for Medicare & Medicaid Services is readying a fraud prevention initiative that removes Social Security numbers from Medicare cards to help combat identity theft, and safeguard taxpayer dollars,” CMS says in a release.

“The new cards will use a unique, randomly assigned number called a Medicare Beneficiary Identifier (MBI), to replace the Social Security Based Health Insurance Claim Number (HICN) currently used on the Medicare card.” Beneficiaries’ new, unique MBI numbers will contain a combination of numbers and uppercase letters.

Deadline: “CMS will begin mailing new cards in April 2018 and will meet the congressional deadline for replacing all Medicare cards by April 2019,” the agency says.

To help your patients get ready for the transition, you can double-check that their address in the system is accurate. “Your patients will not get a new card if their address is not correct,” CMS advises.

“If the address you have on file is different than the Medicare address you get in electronic eligibility transaction responses, ask your patients to correct their address in Medicare’s records through Social Security.”

Your billing department also needs to make sure it’s up for the new 11 digit alpha numeric MBI, CMS instructs. Ask any vendors you use about their MBI readiness to make sure they’ll be prepared for the change. “Make and internally test changes to your practice management systems and business processes by April 2018, before we mail the new Medicare cards,” CMS says.

More information about the new cards under the Social Security Number Removal Initiative (SSNRI) is at www.cms.gov/Medicare/SSNRI.