News / Articles

Time for PQRS – Let’s Review

posted by SamK on December 6, 2012

Michael Jopling, MD, Executive VP, Accel Anesthesia, LLC

December 8, 2012

 

As we approach the end of 2012, it is a good time to review the important elements of the Physician Quality Reporting System (PQRS).  PQRS, formerly known as the Physician Quality Reporting Initiative (PQRI), is a voluntary program that was authorized by the Tax Relief and Health Care Act of 2006 (TRCHA) and was implemented on July 1, 2007. The goal of PQRS is to provide a financial incentive to eligible professionals to improve patient care through evidence-based measures and to prepare for future pay-for-performance programs.

 

Eligible professionals who satisfactorily report data on quality measures for covered Physician Fee Scheduled (PFS) services furnished to Medicare Part B beneficiaries will qualify to earn an incentive payment.  This payment is a percentage of the eligible professional’s total Medicare Part B PFS allowable charges, and it has progressively decreased from a high of 2% in 2009 and 2010 to 1% in 2011 and 0.5% in 2012-2014.  Beginning in 2015 there will be a penalty of 1.5% for failing to report PQRS measures, and in 2016 (and forward) the penalty increases to 2%.

 

The three PQRS measures for anesthesiology include:

 

Measure #30, Perioperative Care: Timely Administration of Prophylactic Parenteral Antibiotics.  This is the percentage of surgical patients aged 18 years and older who receive an anesthetic when undergoing procedures with the indications for prophylactic parenteral antibiotics for whom administration of the prophylactic parenteral antibiotic ordered has been initiated within one hour (if fluoroquinolone or vancomycin, two hours) prior to the surgical incision (or start of procedure when no incision is required).

 

Measure #76, Prevention of Catheter-Related Bloodstream Infections:  Central Venous Catheter (CVC) Insertion Protocol.  This is the percentage of patients, regardless of age, who undergo CVC insertion for whom CVC was inserted with all elements of maximal sterile barrier technique [cap, mask, sterile gown, sterile gloves, large sterile sheet, hand hygiene, 2% chlorhexidine for cutaneous antisepsis (or acceptable alternative antiseptics per current guideline)].

 

Measure #193, Perioperative Temperature Management.  This is the percentage of patients, regardless of age, undergoing surgical or therapeutic procedures under general or neuraxial anesthesia of 60 minutes duration or longer, except patients undergoing cardiopulmonary bypass, for whom either active warming was used intraoperatively for the purpose of maintaining normothermia, OR at least one body temperature equal to or greater than 36 degrees Centigrade (or 96.8 degrees Fahrenheit) was recorded within the 30 minutes immediately before or the 15 minutes immediately after anesthesia end time.

 

Because claims processing times may vary, participating eligible professionals should submit claims from the end of 2012 promptly, so that those claims will reach the Medicare National Claims History (NCH) file by February 23, 2013. PQRS incentive payments will be made as a lump sum in mid-2013.

 

As in years past, thresholds for determining successful PQRS reporting will depend on the number of quality measures applicable to the services provided by the anesthesiologist. CMS recommends that professionals report on every quality measure that is applicable to their patient population in order to increase the likelihood that they will reach the requisite 50 percent reporting requirement for the appropriate measures and also to increase the likelihood that they will not be affected by the bonus payment cap.

 

Claims-based reporting is the traditional method use by eligible professionals.  The EP must report on at least 3 Physician Quality Reporting measures, or 1-2 measures if less than 3 apply to the eligible professional, for at least 50% of applicable Medicare Part B beneficiaries.  The reporting period is Jan 1- December 31, 2012.  Measures Groups containing a measure with a 0% performance rate will not be counted.

 

I hope this information is beneficial to you.  Please contact myself or anyone at Accel Anesthesia with your specific questions and issues.  We are happy to assist with the challenges you face!

 

 

 

 

Create a Culture of Compliance

posted by SamK on November 7, 2012

Sam Kiehl, Executive VP, Accel Anesthesia, LLC

November 7, 2012

 

In today’s regulatory-intense environment, compliance should be an ever-present consideration for anesthesia practices.  At the heart of compliance is a sound compliance program that is reviewed and updated regularly, widely publicized throughout the practice, and enforced without exception.  A compliance program is absolutely essential, and it is most effective when reviewed and updated through a regularly-held compliance meeting.  A current plan that is well-publicized and enforced is your main line of defense when the day comes that your group is the focus of an audit. Do not put yourself at risk of fines and other penalties (even jail time) by letting your compliance plan grow stale.  Consider the following guidelines when creating, updating and implementing your compliance program, so that you may rest easy knowing you are taking appropriate measures to protect yourself, your practice, and your patients.

 

Guidelines for Compliance

 

There should be a clearly written and well communicated compliance program and practice standards.  Specifically address areas of concern where there is the greatest potential for issues.  Establish policies related to anesthesia documentation, recording anesthesia start and end times, concurrency, medical direction, clock synchronization, electronic signatures, as well as billing and coding policies.  Continue to remain educated regarding changes in compliance requirements and new compliance emphases.

 

Internal monitoring and auditing needs to be performed on an ongoing basis.  Compliance plans grow stale quickly.  Review your plan to insure it is being followed.  Evaluate whether changes need to be made to the plan.

 

Maintain a high quality training and education program for all staff members.  Regular and proper training of all staff members is a key to success for any compliance program.  Training should especially focus on those areas of greatest risk or concern.

 

Designate a compliance officer to oversee and monitor the implementation of a compliance program.  The compliance officer facilitates creation and revision of the compliance program, as well as training and implementation of the plan, including ongoing training.  He or she can assist in auditing / monitoring, and investigations into potentially improper practices.

 

Encourage candid communication from staff members.  Assure them that they may speak freely.  Train staff members to report conduct that they believe to be improper or fraudulent.  Staff members need to understand that failure to report fraud and other misconduct is a violation of the compliance program.

 

Enforce the compliance plan without exception.  If a problem is identified, have a plan of action to investigate and remediate issues if required.  And be sure to document your investigations and remediation efforts.

 

Accel Anesthesia can assist you in your efforts to create a culture of compliance at your practice.  We can help you formalize and improve upon your current compliance program, as well as any audits or related investigations into compliance.  Please contact us at Accel Anesthesia with any questions or requests.  We are happy to help you with the challenges you face!

 

 

 

 

HIPAA Random Audits – Are You Prepared?

posted by SamK on October 5, 2012

Samuel Kiehl, MD, Executive VP, Accel Anesthesia, LLC

October 5, 2012

Although HIPAA was initially passed in 1996, the Department of Health and Human Services (HHS) is just now starting to seriously enforce HIPAA regulations with stiff fines and performing random audits, as required under the HITECH Act.  Most alarming are the penalties for a data breech of confidential information which could put a practice out of business for even a minor data breech.

 

For example just last month, a (non-anesthesia) practice in Massachusetts was fined $1.5 million for HIPAA violations.  The investigation by HHS followed a breach report submitted by the practice (as required by HIPAA – “breach notification”) reporting the theft of an unencrypted personal laptop containing electronic protected health information (PHI).  The information contained on the laptop included patient prescriptions and clinical information.  The investigation indicated that the practice failed to take necessary steps to protect the information, such as conducting a thorough analysis of the confidentiality risk to PHI maintained on portable devices, implementing security measures sufficient to ensure the confidentiality of such PHI, and implementing policies and procedures to restrict access to such PHI.  The investigation indicated that these failures continued over an extended period of time.  Similarly Tennessee Blue Cross Blue Shield was fined $1.5 million for a breach violation earlier this year when server hard drives containg PHI for one million individuals were stolen.  HHS is looking hard at not only these large entities, but small practices as well – in March of this year, HHS reached a $100,000 settlement with a five-physician cardiac surgery group, for failure to train employees and other HIPAA violations, including no Policies and Procedures, no Risk Analysis, and no Business Associate Agreements.

 

We recommend that covered entities look closely at their policies and procedures as they pertain to HIPAA, making sure that documentation is comprehensive and current, including business associate aggrements.  In particular, it is vital to show that you have performed an IT security audit, and that your policies and procedures include a security risk management process.  Additionally, facilities need to ensure their staff is trained on HIPAA law and proper procedures.  If your employees know their responsibilities as pertaining to privacy and other HIPAA matters, you will be that much safer.  Accel Anesthesia can assist you in your efforts to  meet HIPAA requirements, educate employees, as well as many other services.

 

 

 

 

Planning for a Successful ICD-10 Implementation

posted by SamK on September 4, 2012

Craig Adkins, Executive VP, Accel Anesthesia, LLC

September 4, 2012

 

On August 24, 2012, the Centers for Medicare and Medicaid Services (CMS) announced that the ICD-10 compliance date was moved from October 1, 2013, to October 1, 2014.  And while many practices breathed a huge sigh of relief, it is clear that practices can no longer delay the planning required for a successful ICD-10 implementation.  We advise anesthesiologists to plan now to avoid potential operational and financial problems.  Delays from payers could have significant impacts on your cash flow!

 

Here are the most important ICD-10 implementation steps for your anesthesiology practice.

 

Perform operational impact analysis. ICD-10 will impact almost all aspects of your practice. All personnel, systems and functions in your work flow must be evaluated from patient referral and scheduling to billing.  Identify staff, workflows, systems and business processes that currently use ICD-9.  Identify possible work flow changes needed to implement ICD-10, including changes to forms and superbills.  Assess whether it will be helpful to hire a consultant such as Accel Anesthesia to assist you in the planning and implementation process.

 

Train your staff.  Training is an integral piece of the implementation process.  Training on the fundamentals is essential for everyone.  Deeper training will be required for those who work more closely with coding.  Send appropriate staff to medical coding classes or boot camps.  Develop a timeline for training.

 

Assess the impact on payer contracts and insurance plans.  Include ICD-10 in payer contract negotiations. Understand the changes in documentation required for each plan.  Insist that ICD-9 reimbursement policies stay in effect during transition.

 

Estimate and approve budget required to cover ICD-10 implementation costs such as software / hardware procurement and staff training as well as productivity losses.  Establish a back-up plan and budget for possible cash flow interruptions caused by coding slow down, health plans not ready to accept ICD-10, IT / vendor issues, etc.  List factors that might alter your budget during the course of the project.

 

Contact your system vendors to assess their readiness for ICD-10, and their timeline for implementing ICD-10.  Billing, Practice Management and EMR systems (including interfaces) will need to be upgraded to ensure all forms are 5010 compatible and can store and transmit both ICD-10 and ICD-9 codes.  Develop a timeline for testing systems.  Be aware of system downtime.

 

Don’t let the CMS delay cause you to delay your ICD-10 planning and implementation. ICD-10 is going to happen and you and your practice need to be ready. With any change of this magnitude, there will be bumps along the way, but you have the power to minimize them through careful and timely planning.

 

 

 

 

Which Staffing Model is Appropriate For My Practice?

posted by Michael Jopling Partner, Accel Anesthesia, LLC on August 8, 2012

Michael Jopling, MD, Executive VP, Accel Anesthesia, LLC

August 8, 2012

 

As reimbursements decline and the pressure to reduce anesthesia costs rise, more and more anesthesia groups require continuous evaluation to determine the most appropriate and effective staffing model for their particular practice situation.

 

A logical mechanism for improving the profitability of a practice is to change the proportion of physician to non-physician anesthesia providers. This may enable a practice group to meet the demands of payers to reduce costs.

 

Differing staffing models can have other important advantages. For example, they can improve the ability to adapt to unplanned illnesses and absences from work, adjust how emergency procedures are handled, and offer solutions for general OR efficiencies.

 

However, there are particular internal and external challenges to consider when analyzing the effects of the different anesthesia staffing models.  The decision on which model is appropriate comes down to several factors, including surgeon preference, types of procedures performed, hospital productivity targets, local anesthesia market conditions, potential transition issues, surgery center size, and federal or state regulatory requirements.

 

Having an updated plan which allows an objective comparison of the costs and benefits of various models is invaluable to a hospital or anesthesia practice. Armed with an effective plan, hospitals and anesthesia practices can utilize their limited resources more effectively. Accel Anesthesia can model various staffing scenarios and assist in understanding what is optimized and what is compromised so that an informed decision can be made.

 

 

 

 

Employee Theft, Is Your Practice Getting Ripped Off?

posted by Michael Jopling Partner, Accel Anesthesia, LLC on July 1, 2012

By Craig Adkins, Executive VP, Accel Anesthesia, LLC

July 1, 2012

 

Employee theft is a significant risk for most medical practices.  According to the MGMA, embezzlement costs group practices billions of dollars every year.  Their research goes on to say that even “honest” employees steal.  So if you thought your practice was immune to this risk, you could be wrong, and you could be losing thousands or even hundreds of thousands of dollars.

 

The amount of loss according to the Association of Certified Fraud Examiners (ACFE) is approximately $25 billion annually for all medical practices.  And the vast majority (86%) of these perpetrators are first-time offenders – they had never been charged with a fraud-related offense. So even if you think you’ve hired honest employees, who have clean backgrounds and no history of fraud, your practice is still far from immune to the risk of theft.

 

Preventing theft starts by taking a few important precautionary measures like checking references before you hire someone and performing background checks.  You should also route all checks that come to your practice via mail to a bank lock box.  Internal controls are also important – all transactions must be documented whether accounts payable, accounts receivable, refunds, adjustments, co-payments or write-offs.  Then you must reconcile your accounts.  Additionally, there are operational measures that you can implement to further reduce your risk of embezzlement.  One of the most important measures is to segregate duties.  For example the employee who prepares the accounts payable checks should be different than the employee (or physician) who signs the checks.  And then someone else should reconcile the bank account and review accounting entries.  Bank statements and blank checks should be secured so only the designated employee s, physicians, and/or accountants have access.

 

Beyond the usual safe guards, one of the best methods to prevent theft is to engage someone to perform independent audits of your files and payments. Even a bi-annual audit of random files can act as a deterrent. The key to security and loss prevention rests in barriers to keep staff members honest rather than spending the money to anticipate every possible thievery.   If employees know their work will be reviewed and do not know when that review will take place, they are far more likely do their work honestly and not steal.  The ACFE has found that organizations that use surprise audits have approximately 50% lower losses, and they detect embezzlement 37% sooner.

 

Key findings and highlights of the ACFE report, as well as the full report, can be found on their website at http://www.acfe.com/rttn-highlights.aspx.