The beginning of a new year is a time of reflection for many people. This helps us to focus on our personal or professional goals and begin the year with a renewed energy to be better than we were last year! As you strive to improve in 2016, I encourage you to reflect on the important work of taking care of patients while meeting the many compliance requirements that come with that job.
Start with your annual Security Risk Assessment. This is part of the continuous process of identifying, correcting and preventing HIPAA security issues within your practice. Ensure you have policies and procedures in place that address potential HIPAA vulnerabilities. These include such things as outlining your practices contingency plan, documenting your Business Associate Agreement process and ensuring that your breach notification process is complete and up to date. Staff must also be aware of and understand these policies. Consider reviewing one policy each month as part of your staff meeting.
Review your Compliance Plan and ensure the policies are current and reflect the actual processes used in your office. Having a policy that you don’t follow can actually be worse than not having one at all. While your Compliance Manual may incorporate many of your HIPAA polices, it should also reflect your policies to ensure healthcare compliance. This includes internal monitoring and auditing to prevent fraud, waste and abuse as well as training, education and compliance expectations for new staff. Your practice’s Compliance Plan should ensure open lines of communication that allow staff to report issues without fear of retaliation. The Office of Inspector General has published guidance on the components of an effective compliance program for individual and small group practices. It may be beneficial to review this to ensure you are on track with your program.
The attestation period for 2015 Meaningful Use is January 4, 2016 thru February 29, 2015. Keeping in mind that the intent of this program is to ensure your electronic health records are being utilized in a meaningful manner, the work cannot stop with the attestation. It is a good practice to review your data throughout the year to ensure your information is being completed and captured correctly. Remember an assessment of your security risks is also a requirement of Meaningful Use. If you are audited, be prepared:
Keep copies of what you have attested to.
Be aware of all deadlines.
Submit all of the requested information.
Never alter your records.
Some of you many have recently received notification that Medicare will be applying a negative payment adjustment to your 2016 submitted charges resulting in a 2% decrease in your Medicare payments. This is a result of not meeting PQRS reporting requirements in 2014. Medicare has recently published information on the 2016 PQRS measure codes. Review the processes used to capture these measures in your practice and ensure they are up to date. Failing to meet PQRS in 2016 may affect your Medicare payments in 2018.
Consider creating processes to ensure that new providers are credentialed prior to seeing patients. Claims submitted for services performed should always include the name and the NPI of the provider performing the service, except in a situation where a locum tenens (replacement provider) arrangement is in place. It is not appropriate to bill the service under a credentialed provider’s name.
Finally, if you are considering opting-out of Medicare, be aware of issues that may arise due to that status. Once you decide to opt-out, you have just 90 days to reverse that decision. Once those 90 days have passed, opted-out providers cannot reenroll with Medicare for two years. Some commercial payers have a requirement for participating providers to be Medicare enrolled providers. A decision to opt-out may affect your status with those insurance plans.
As you take time to reflect and find ways to improve in 2016, consider your practice’s compliance requirements. Not only will this prepare your practice in the event of an audit, it will assist you in ensuring you are providing the best care to your patients.
May 2016 be a productive and compliant year!