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2020 Official ICD-10-CM Coding Guideline Changes Are Here!

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It’s that time of year for offices to get ready for the ICD-10-CM code revisions. As part of that process, it’s also good to know what is going on with the ICD-10-CM Official Guidelines for Coding and Reporting. In the examples listed below, strikeout text is deleted and highlighted text ...

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Are You Aware of Medicare Advantage Plans Timely Filing Rules?

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The Medicare Fee for Service (FFS) program (Traditional or Original Medicare) has a timely filing requirement; a clean claim for services rendered must be received within one year of the date of service or risk payment denial. As any company who has billed Medicare services can attest, the one-year timely filing ...

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Will Medicare Change Their Rules Regarding Coverage of Services Provided by a Chiropractor?

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Two separate pieces of legislation introduced in the House of Representatives (H.R. 2883 and H.R. 3654) have the potential to change some of Medicare’s policies regarding doctors of chiropractic. Find out what these two bills are all about and how they could affect Medicare policies.

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The OIG Work Plan: What Is It and Why Should I Care?

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The Department of Health and Human Services (HHS) founded its Office of Inspector General (OIG) in 1976 and tasked it with the responsibility to combat waste, fraud, and abuse within Medicare, Medicaid, and the other HHS programs. With approximately 1,600 employees, HHS OIG is the largest inspector general's office within ...

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Are These Problems Hurting Your Practice?

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There are many things that can be missed when trying to run an effective and profitable practice. This article covers some important tasks that are often overlooked such as not reviewing your payer contracts or failing to check eligibility.

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Denial Management is Key to Profitability

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Q/A: Can I Put the DC’s NPI in Item Number 24J for Massage Services?

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Question: Are there scenarios in which it is acceptable to put the DC's NPI in box 24j for massage services?  Answer: While the answer to this is yes, it is essential to understand that there are very limited scenarios. In most cases, Item Number 24J is only for the NPI of the individual ...

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Rules for Rendering Unproven, Investigational or Experimental Procedures

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If you haven’t reviewed your state guidelines or taken a recent look at third-party payer policies on unproven, investigational or experimental procedures, now is the perfect time to make sure you’re up to speed with this important information.  Most providers are surprised to see commonly used devices or techniques listed ...

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Q/A: Do I Really Need to Have an Interpreter?

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Question: I heard that I need to have an interpreter if someone who only speaks Spanish comes into my office. Is this really true? Answer:  Yes! There are both state and federal laws that need to be considered. The applicable federal laws are: Title VI of the Civil Rights Act of 1964,  Americans with Disabilities ...

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2018 Medicare Improper Payment Report Shows Slight Improvement but There's Still Work to be Done

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The Medicare Improper Payment Report for 2018 is not a measurement of fraud. Rather, it is an estimate of the claims paid by Medicare which did not meet Medicare coverage, coding, and billing rules. The estimated Medicare FFS payment accuracy rate (claims paid correctly) from July 1, 2016 through June 30, 2017, was 91.9 percent. ...

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Q/A: Can I Refuse to File a Patient's Medical Insurance for an Auto Accident?

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Question: Can a Chiropractor refuse to file a patients Medical Insurance for an Auto Accident? Answer: There isn't a simple answer to this question. It depends on who is responsible and state laws. Who is responsible (the auto insurance or the medical insurance) can depend on state requirements as well as who is ...

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Small Breaches Can Be Subject to Large Penalties

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Small Breaches Can Be Subject to Large Penalties    We may have heard about the large fines issued by the Office for Civil Rights (OCR) against big organizations like Anthem or the University of Texas MD Anderson Cancer Center. These organizations have been in the news due to privacy breaches that constituted violations ...

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What Medical Necessity Tools Does Find-A-Code Offer?

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Find-A-Code is a great resource for individuals working in all aspects of healthcare, from providers and ancillary staff to the attorneys and payers who assess and critique the documentation supporting the services performed. When recently asked what tools Find-A-Code has to help support medical necessity, our response was, "We provide many resources ...

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Q/A: Two Payers Both Paid the Claim. Who Gets the Refund?

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Question  We have a personal injury situation where we submitted a claim was sent to the patient's auto policy carrier who refused payment. We then submitted it to her other insurance. Eventually, both companies paid her claims. Her auto paid at full value, and her secondary paid at a reduced rate ...

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Q/A: I’m Being Audited? Is There a Documentation Template I can use?

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Question: Our Medicare contractor is auditing claims with 98942. Do you have any suggestions for a template for documentation to warrant the use of 98942? Answer: When you submit a claim with code 98942 you are stating that you have determined that it was medically necessary to adjust all 5 of ...

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OIG Announces New Review For Medicare Part B Payments for Podiatry and Ancillary Services

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Due to prior OIG work identifying inappropriate payments for podiatrists and ancillary services, the OIG announced in Feb 2019 they will begin a new review starting in 2020.  The OIG stated they will review Medicare Part B payments to determine if medical necessity is supported in accordance with Medicare requirements.   Part of the ...

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Let's Talk High Risk E/M Services

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Have you ever assigned a high-complexity E/M code (e.g., 99205, 99215, 99223, 99233, 99245, etc.) and wondered if it would stand up to further scrutiny? Well, let’s take a closer look at the requirements for reporting high-level E/M services.   Both the American Medical Association and Medicare-published E/M Guidelines agree that a ...

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Watch out for People-Related ‘Gotchas’

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In Chapter 3 — Compliance of the ChiroCode DeskBook, we warn about the dangers of disgruntled people (pages 172-173). Even if we think that we are a wonderful healthcare provider and office, there are those individuals who can and will create problems. As frustrating as it may be, there are ...

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Prepayment Review Battle Plan

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Any type of payer review can create some headaches for providers and cause problems for a healthcare office. Even for a practice that has taken administrative steps to try and prevent a prepayment review, it can still happen. A prepayment review means that you must include documentation WITH your claim. ...

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Clearing Up Some Medicare Participation Misunderstandings

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Even though we may think we truly understand what it means to be a participating provider, Medicare doesn’t quite work the way that other insurance plans do. Far too many providers do not understand the difference and get into hot water. To further complicate matters, the rules are different for ...

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Q/A: How do we Know Which Codes a Payer Will Allow?

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How do we know which codes a payer will allow? The best way to determine the codes (CPT, ICD-10-CM and HCPCS) allowed by a payer is to review their payer policy. While it is good to know the official guidelines (e.g., ICD-10-CM Official Guidelines for Coding and Reporting, AMA Guidelines, Medicare ...

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Date of Service Reporting for Radiology Services

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Providers need to ensure that they are reporting radiology dates of service the way the payer has requested. Unlike other many other professional services which only have one date of service (DOS), radiology services can span multiple dates. Medicare requirements may differ from professional organization recommendations.

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Understanding NCCI Edits

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Medicare creates and maintains the National Correct Coding Initiative (NCCI) edits and NCCI Policy Manual, which identify code pair edits. When performed on the same patient, on the same day, and by the same provider, the secondary code is considered an integral part of the primary code, and payment for ...

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Proposed Rule: Expanded Telemedicine Benefits for Medicare Advantage Beneficiaries

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Telemedicine continues its rise, with new technologies allowing for better communication and access to more aspects of healthcare than ever before. Each year Medicare has made strides, albeit small strides, in their telemedicine coverage while commercial payers continue to make great strides, constantly improving and expanding telemedicine service offerings to ...

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Charging Missed Appointment Fees for Medicare Patients

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Some providers mistakenly think that they cannot bill a missed appointment fee for Medicare beneficiaries. You can, but Medicare has specific rules that must be followed. These rules are outlined in the Medicare Claims Policy Manual, Chapter 1, Section 30.3.13. You must have an official “Missed Appointment Policy” which is ...

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Medicare Advantage Providers are not Required to be Enrolled in Medicare

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There was a ruling that was requiring providers to be enrolled in Medicare in order to provide services for Part C (Medicare Advantage (MA)) and/or Part D. However, on April 2, 2018, CMS released the 2019 Final Rules for MA and Part D which changed this previous ruling. According to ...

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Are HIPAA Changes Coming?

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On December 14, 2018, the Office for Civil Rights (OCR) issued a Request for Information (RFI). They are considering making changes to some of the HIPAA regulations. Earlier this year at the HIMSS (Healthcare Information and Management Systems Society) meeting, Roger Severino, the head of the Office for Civil Rights ...

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Keeping Up to Date

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Keeping up to date on coding and documentation changes, is critical for medical coders, billers, auditors, and compliance personnel. Every year American Medical Association (AMA) creates, revises, and deletes CPT codes on January 1st. Same thing occurs with the ICD-10 codes in October. For CPT codes, the intention of the...

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Errors Billing Outpatient Services When Patient is also Inpatient

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The OIG recently reported that Medicare inappropriately paid acute-care hospitals for outpatient services provided to patients who were inpatients of another facility including long term care hospitals, inpatient rehabilitation facilities, inpatient psychiatric facilities, and critical access hospitals.  CMS suggests using the following resources to ensure compliance: Medicare Inappropriately Paid Acute-Care Hospitals for ...

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No Good Deed Goes Unpunished

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You simply need to read the headlines, posts, and tweets, about providers across the healthcare profession being audited, fined, and some even convicted, to see that the costs of non-compliance are real. We tell ourselves, “It won’t happen to me.” The reality is that it easily could. Your license is your livelihood.

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Billing 99211 Its not a freebie

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It seems like a simple code to bill, but CPT 99211 (established patient office visit) is by no means a freebie when it comes to documentation and compliance. This lowest level office visit code is sometimes called a "nurse visit" because CPT does not require that a physician be present...

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Q/A: Does My LMT need an NPI? How do I Bill Her Services?

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Question: I am setting up an LMT to work as employee under Dr. Clifton, DC. i need to know several things - hoping they are related and can be grouped into this one question.... does she need her own NPI? where does that NPI # go? what box #? if not, ...

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Chiropractic OIG Audit Recommendations - Lessons Learned

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The OIG recently concluded an audit on a chiropractic office located in Florida and had some significant findings. They recommended the following: Refund to the Federal Government the portion of the estimated $169,737 overpayment for claims for chiropractic services that did not comply with Medicare requirements and are within the 4-year ...

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HIPAA Handling Patient Requests for Medical Record Restriction

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Healthcare compliance professionals frequently face confusing situations about sharing of protected health information (PHI). The Health Insurance Portability and Accountability Act (HIPAA) supports the protection of privacy of medical records. However, even when a patient does not authorize sharing of his record, there are permitted uses and disclosures, such as...

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Q/A: Do I Have to Accept Any New Patient?

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Question: Is it legal for us to not allow a patient to be seen in our office if their parents have bad debt with us?

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Finalized Confidentiality of Alcohol and Drug Abuse Patient Records Regulations

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In January, the U.S. Department of Health and Human Services (HHS) issued updates to the privacy regulations regarding the confidentiality of patient information of substance use disorder patients (42 CFR Part 2).  This notice included references to better alignment with HIPAA regulations, but did state that Part 2 is more protective ...

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PSAVE Pilot Program - What Does it Mean to You?

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Noridian's pilot program Provider Self-Audit with Validation and Extrapolation (PSAVE) has been extended which means that it has been successful for the payer, which means that they are saving money. Historically, when a pilot program is proven to be successful, it isn’t too long before other MACs follow. Before signing up to participate, providers need to carefully evaluate the program. Are the benefits worth the costs?

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Are incident to services worth the risk

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Incident-to services allow non-physician practitioners (NPPs) such as nurse practitioners and physician assistants to bill under a supervising physician if they perform services that are incidental to a physician-created plan of care. Incident-to billing offers two key benefits: First, the physician is reimbursed at 100% of the contracted rate with...

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Q/A: Is it Legal to Shred Archived Patient Records After a Certain Amount of Time?

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Shredding patient records. When is it appropriate? Read more to find out.

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Attention Providers - Please Make Time to Read this Letter

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In an effort to show CMS is committed to changing the rules to accommodate their providers CMS released a letter to Doctors of Medicare Beneficiaries. The letter offers encouragement and a promise to reduce the burden of unnecessary rules and requirements. The letter states “President Trump has made it clear that ...

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Dual Medicare-Medicaid Billing Problems

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It is important to keep in mind that Medicaid is run at a state level so there can be some differences when it comes to coverage. However, the rules regarding balance billing of covered services is set at the federal level. The law states (emphasis added): A state plan must provide ...

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WHO Said ICD-11 is Coming Soon

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Sooner or later ICD-11 will be released, and it sounds like it will be sooner than later. WHO released the news on June 18, 2018. The World Health Organization stated “ICD-11 will be presented at the World Health Assembly in May 2019 for adoption by Member States, and will come ...

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Medicare Claim Submission Exceptions

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There are several exceptions to the Medicare "Mandatory Claim Submission Rule." What are they?

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Q/A: Can a PT Assistant Perform Physical Therapy Modalities?

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Whether or not a physical therapy assistant (PTA) may perform physical therapy modalities depends on two factors: state law and payer policies. Read here for more.

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Home Oxygen Therapy -- CMN for Oxygen

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The Certificate of Medical Necessity (CMN) for Oxygen is a required form that helps to document the medical necessity for oxygen therapy. It also documents other coverage criteria for the oxygen use. For payment on a home oxygen claim, the information in the supplier’s records or the patient’s medical record must be substantiated with the information in the CMN.

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Inappropriate Use of Units Costs Practice Over $800,000

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A recent OIG enforcement action emphasizes the need to understand the proper use of units. A healthcare provider in Connecticut improperly submitted multiple units for drug screening urine tests. The proper billing of units has proven to be problematic for more than just lab tests. Is your billing of drugs & biologicals, injections and timed codes appropriate?

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The Range of Motion Conundrum

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As both a chiropractor for 31 years and one who reviews a lot of medical records for the medicolegal arena and has been teaching documentation for many years, the range of motion question comes up frequently. Although we used to get reimbursed very well for a specific range of motion code back in ...

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Creating a Culture of Compliance in 2018

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This year (2018), healthcare organizations (Hospitals, Health Systems, and Physician Groups/Practices) must focus on the criticality of creating a culture of compliance to ensure effectiveness and efficiency. Focusing on "compliance"-only approaches leaves healthcare organizations exposed to areas of liability oftentimes far more than what they could ever imagine or even...

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Routine Waiver of Patient Out of Pocket Expenses

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Medical billers often encounter the dilemma of a physician who wants to be the hero to his or her patients and waive their out-of-pocket expenses. Out-of-pocket expenses include a patient's co-payment, coinsurance, deductibles, charges above U&C (Usual and Customary), and even services a plan may not cover in some situations....

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What is a Legal Hold and e Discovery Anyway

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Whether I am assisting clients or presenting, I am often asked about legal holds and e-discovery. The transition from paper to electronic records, which include emails, computer faxes, protected health information ("PHI"), personally identifiable information ("PII") and documents that are created, received, maintained or transmitted in an electronic format created...

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Q/A: Am I Supposed to List the Frequency and Duration on the ABN?

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How to fill out Box D (Services) on the ABN form. What information is required?

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Q/A: How Do I Respond to a Patient's Request to Not Submit the Claim to Their Insurance?

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A number of patients now have high deductible plans. Sometimes, deductibles can be $5000 or $10,000. My payer contract states that I must submit all claims to insurance for covered services. However, sometimes patients with these high deductibles come to my office and state that they would prefer to receive a modest discount for paying cash and in turn, not have their services submitted to insurance. As a doctor, this places me in a tough situation. Do I follow the patient's wishes or the payer contract?

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The Devil is in the Data Details

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As an auditor who has reviewed thousands and thousands of encounter documents for level of service, a predictable pattern has merged when it comes to the Medical Decision Making (MDM) component that has attracted my attention.

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Q/A: Should I be Using Modifier 96 on PT Claims?

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As chiropractors we feel the new modifier 97 is more appropriate than 96 for our PT codes such as stim and traction. Yet Carefirst is asking for 96 only. Should we use this code on all the PT codes and for all the other insurance companies?

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Q/A: Someone Broke into My Office. What do I do Now?

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My office was broken into last night. I use electronic health records, but we do store some protected health information for my patients in paper files. These files are not secured, so the burglars did have access to them. It did not appear that the files were touched as the burglars were looking for cash. What responsibilities to I have to my patients in a situation like this? Do I need to contact them and advise them that their PHI could have been compromised?

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The PSAVE Pilot Program: Should You Self-Audit Your Medicare Claims?

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As the Medicare program has grown, the Centers for Medicare and Medicaid Services (CMS) has employed a variety of different claims audit mechanisms to better ensure that the Medicare Trust Fund is protected from waste, fraud and abuse....

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CMS Compliance Guidelines Focused Trainings

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Since the publication of the Compliance Program Guidelines in 2012, the Medicare Part C & D Oversight and Enforcement Group, Division of Compliance Enforcement, has presented a series of focused trainings for the industry on the application of the seven elements of an effective compliance program. These trainings are designed ...

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Documentation for Home Health Services (Part A non DRG)

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The Medical Learning Network provides coverage guidance, which should be documented, for home health services.

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Documentation for Skilled Nursing Facilities

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The Medicare Learning Network provides guidance on required documentation for Skilled Nursing Facilities (SNF).

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The Comprehensive Error Rate Testing Program

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With nearly a million physicians in this country, how do auditing organizations determine whom to audit?

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Scoring & Reporting Your Audit Findings

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This week we had a great question posted to our online forum, and I thought it would be a nice thought- provoking question for our auditing and compliance tip of the week.

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OIG Reviews Medicare Advantage Claims

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On January 16, 2018, the OIG released a report of their findings on claims data for Medicare Advantage plans. While it appears that there were not significant issues, they did find that: "Types of potential errors included inactive or invalid billing provider identifiers; duplicated service lines; missing required data; inconsistent dates; ...

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Mobile Health: Growing Engagement and New Responsibilities

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This week I'm blogging about an M-word. Not MACRA or MIPS, but Mobile Health or mHealth....

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Developing Coding Policies for Compliance

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Every physician practice depends upon correct coding and billing for their financial success. Coding drives reimbursement. All of the resources available for coding information and guidance are meaningless without the practice manager translating it into provider-specific coding policies and compliance plan. As a practice manager, you need to develop a ...

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Dental and Medical- Controlled Substance Awareness

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As an effort to cut down on opioid abuse and related crimes, in August of 2017 the Attorney General Sessions established a new Department of Justice (DOJ) section called “Opioid Fraud and Abuse Detection Unit”. Due to the serious public health issue and drug overdose deaths, this unit was established and ...

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Creating a Culture of Compliance in 2018

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This year (2018), health care organizations (Hospitals, Health Systems and Physician Groups/Practices) must focus on the criticality of creating a culture of compliance to ensure effectiveness and efficiency....

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HIPAA and the Opioid Crisis

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HIPAA and the Opioid Crisis guidance released by HHS.

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NEW on Find-A-Code...National Coverage Determinations (NCDs)

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Medicare limits its coverage of services to those considered to be reasonable and necessary for the diagnosis and treatment of an injury or illness based on coverage guidelines. National Coverage Determinations (NCDs) are created based on research, evidence-based processes, public participation, and other resources, and made available to the public. ...

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Compliance: What is it and Why is it Important

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Compliance. It is one of the buzz words in healthcare that is heard all the time but what is it really, and why is it so important?

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Patient Relationship Codes

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Section 1848(r)(4) of MACRA requires that claims submitted for items and services furnished by a physician or applicable practitioner on or after January 1, 2018, include codes for the following: care episode groups patient condition groups patient relationship categories Previously, CMS decided to use procedure code modifiers to report patient relationship codes on Medicare ...

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Quality Payment Program in 2018

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I checked the government website to see if I am an eligible clinician and it says that I am not. I just don't want to get blindsided with a letter saying I will be penalized. Is there anything you would suggest or recommend that I do now to protect myself from future penalties. Thank you

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