It seems both ironic and inevitable: I won’t be getting any more “meaningful use” checks. It’s not that I didn’t qualify for the money; I saw plenty of patients on Medicare and met all of the requirements. I was paid for my first year money without much hassle. The problem I am facing is this: I am probably going to be “opting out” of Medicare, and once I do that I will cease to exist as far as HHS is concerned, and they are the ones who write the “meaningful use” checks. No existence equals no money.
This is ironic because I have gotten famous for how well I’ve used electronic medical records, have written advice for physicians trying to qualify for “meaningful use,” and am esteemed enough to be often asked for my opinion on the subject (culminating in a presentation last year for CDC public health Grand Rounds). I have spent much of the past 16 years disproving the myths that small practices couldn’t afford EMR, that EMR decreases profitability, or that they reduce quality of care. We not only could afford EMR, we flourished, using it as a tool to increase both productivity and profitability. Not to overstate the issue, but my practice (and others like it) paved the way for the existence of “meaningful use.” I don’t know if that’s a good or a bad thing.
But, as fate would have it, I am leaving the practice in which I did all of this work and am starting a new practice with a different payment system. Instead of charging for office visits or tests done in my office, I am charging a monthly “subscription” fee for access to my care and to the other resources I offer. But there isn’t a Medicare code for a monthly subscription fee, and the rules of Medicare are such that, as far as I can tell, I cannot have the practice I intend to build and be listed as a Medicare provider. This is the case even if I never charge Medicare for any of my services.
Regarding my status as a Medicare provider, there are three options:
- Accept Medicare as a “participating” provider – This means that I see Medicare patients and accept what they say I will be paid. I bill CMS for my services, which are based on my “procedure codes.” My main procedure is the office visit, but I can also bill for things like immunizations, lab tests, and office procedures. The more procedures I bill for, the more I get paid, but I must justify this billing in my documentation or run the risk of being accused of fraud.
- Become a “non-Participating” Medicare provider - In this scenario, I am paid by the patient for the encounter and then they are reimbursed for what they paid me. The choice of what I bill happens the same way, and I still must set fees based on what CMS tells me (although I can bill a little bit more than I would if I was a participating provider). Billing is, once again, based on the documentation of the visit.
- “Opt out” of Medicare altogether - Opting out means that I am no longer in the Medicare database as a provider and won’t get paid by them at all. Patients are free to come to me, but they must pay what I charge, and I set my fees based on what I think is best. Continue reading “Tough Hard Decision: What To Do About Medicare”
Filed Under: Commentology, THCB
Tagged: Coding, Medicare, Opt out, private practice, Rob Lamberts, Subscription model
Nov 19, 2012
Innovative thinkers and influential healthcare leaders aren’t relying on the decisions coming out of HHS to determine their strategy. Despite the fact that many healthcare organizations were on target to transition from ICD-9 to ICD-10, Health and Human Services (HHS) announced it would initiate a process to postpone the date by which certain healthcare entities have to comply with ICD-10.
The details of the delay have not been revealed, but industry experts are speculating that a one-two year delay is in the works. With only 20 months remaining to the Oct. 1, 2013 deadline, this leaves many organizations in limbo. Do they continue down the path of ICD-10 adoption, revise plans based on speculation about a new timeline or completely put the initiative on hold?
The leaders in healthcare never limited their thinking to a coding mandate. They were aligning their ICD-10 efforts with quality of care initiatives- EMR adoption and improved clinical documentation. They won’t hesitate, they won’t miss a step, and they will focus on providing exceptional care through improved processes, many of which will prepare them for a successful transition to ICD-10 and ICD-11.
The following areas of focus will improve quality of care, reporting and accuracy of reimbursement.
- Lead with purpose- understand the long-term impact of a coding mandate and help providers understand the alignment of greater specificity in coding with quality reporting, improved clinical documentation and clinical decision support.
- Take this time to improve clinical documentation- develop processes and feedback to improve how physicians and other providers document care. This effort will reap financial benefits and directly impact quality of care and reporting. Continue reading “Seizing the Opportunity in the ICD-10 Delay”
Filed Under: THCB
Tagged: Coding, HIMSS 2012, ICD-10
Feb 22, 2012
My typical Medicare patient expects me to deal with 5 or more problems in a single routine visit. There are usually around 3 old ones (e.g., diabetes, hypertension, hyperlipidemia) and at least 2 new ones (e.g., low back pain, fatigue). For those who come with handwritten lists, there may be as many as 10, including every health question that has come to mind over the past 6 months (Should I take a holiday off of Fosamax? Should I add fish oil? Do I need another colonoscopy? Is the shingles shot any good?).
Physicians who do procedures get paid for each one done to a single patient on a particular day. Medicare’s rule for this – the Multiple Procedure Payment Reduction Rule (MPPR) – says doctors should be paid 100% for the first procedure and 50% for each subsequent procedure up to 5. However, for those of us whose work is primarily cognitive rather than procedural, there is an important exclusion: the multiple-payment rule does not apply to E/M codes. In fact, the definitions of 99213 and 99214 unambiguously state, “Usually the presenting problem(s) are of . . . complexity.” Note the “(s)”! It clearly creates a double standard that favors doing procedures and places thoughtful solving of patients’ problems at a disadvantage.
So in my case, 5 or 10 or more separate patient problems equal one payment. The “(s)” in the AMA’s CPT book is the most outrageous injustice to primary care of this generation. Because of it, the AMA’s CPT committee is accountable for even more damage to primary care than is their RUC! Think how different life in primary care would be if the “(s)” were removed and you were paid 50% for each additional patient problem you addressed in a single office visit!
Continue reading “The Math of E/M Coding: When Does 5=1?”
Filed Under: Uncategorized
Tagged: Coding, CPT codes, Medicare payments, MPPR, Paul Fischer
Sep 23, 2011
In a recent Wall Street Journal article, Barbara Levy, Chairwoman of the Relative Value Scale Update Committee (RUC), commented on the American Medical Association’s (AMA’s) decision to have minimal primary care participation on the RUC, saying the committee is an “expert panel” and not meant to be representative. Since the committee is made up of 27 specialists, one family doc, and a pediatrician, the AMA apparently believes it requires little in the way of primary care expertise but lots of experts from every minute surgical specialty.
This is, of course, reflected in the AMA’s coding system. Most of primary care is condensed into four Evaluation and Management (E/M) codes: a “focused” encounter, an “expanded” encounter, a “detailed” encounter, and a “comprehensive” encounter (99212-99215). It does not matter whether the problem is a cold or an acute myocardial infarction. It does not matter if you worked with just the patient or the entire family spanning three generations. It does not matter if the problem was simple and common (eg, essential hypertension) or rare and complex (eg, pheochromocytoma). It does not matter whether you completed everything in a single visit or spent hours fighting with an insurance company for payment. And it does not matter whether you dealt with a couple of well-established problems or a dozen new ones. It is clear that the AMA has little expertise in this area. What is amazing is that they think they have enough!
In contrast, there are 400 pages in the CPT book to help proceduralists get maximum pay for their work. In general, procedure coding follows a scheme based on the part of the body, the number of times you repeat a procedure, how fancy the equipment is, and how many different names you can come up with to do the same work (eg, vein ablation, injection, sclerosing, ligation, interruption, excision, or stripping). This is obviously a boon for many physicians’ income. Continue reading “A Modest Proposal: What If All Specialty Procedures Were Coded with 4 CPT Codes?”
Filed Under: THCB
Tagged: AMA, Coding, RUC
Apr 26, 2011