Jan 18, 2007

The FMA E-News is emailed to all members of the Florida Medical Association semimonthly. The FMA, located in Tallahassee, Fla., serves as an advocate for physicians and their patients to promote the public health, to ensure high standards in medical education and ethics, and to enhance the quality and availability of health care.

Watch for the legislative update tomorrow of this week's events.

FRONTLINE ALERT
IF YOU ARE SELF-INSURED
 If you are self insured, you should be aware that the Department of Health conducts audits to ensure that physicians are complying with the law.  Sections 458.320 and 459.0085, Florida Statutes require that physicians who self insure either post a notice in the reception area or provide a written statement to patients.  If you are an FMA member and would like a copy of a sign to post or a notice to give to patients, you may send an email to and it will be provided to you.  If you have other questions regarding the financial responsibility requirements for physicians in Florida, you may write to .

 
2007 MEDICARE THERAPY CAP
This document, which can be downloaded at the link below,  explains the exception process for billing Medicare for therapy provided and billed above the $1780 financial cap in 2007. Please note that the manual exception process that existed in 2006 no longer exists.  By appending modifier –KX to a line item on your claim you are certifying that documentation exists that the services are medically necessary, are documented as coded and meet any other Medicare requirements.  The –KX modifier by itself will bypass the system edits and allow claims to be paid when the patient has reached their $1780 cap.

Additionally in this transmittal are some revised and new documentation requirements.  You and your therapists should pay particular attention to all red font – probably not a bad idea to review the document in its entirety.  Make sure you familiarize yourselves with the information on page 27.  CMS is "recommending" that at least one of four assessment tools be used to document current status and used again to document progress, or lack of progress.  If one of these tools is not used, the transmittal goes on to give examples of other forms of documentation that may be acceptable.  It is very important to document utilization of the appropriate measure in the evaluation/plant of treatment and for comparison at appropriate intervals (i.e., every 10 treatment days or once every 30 days, whichever is less).  Therapy services are on the OIG's Work Plan for 2007, so it would not be surprising to see audits start this year.  As always, a Medicare audit can just be the inconvenience of copying records and nothing more as long as the documentation supports that services were rendered according to Medicare policy for a covered service – hence the importance of therapists understanding what those documentation requirements are.  Visit http://www.fmaonline.org/phys/2007therapy-caps.pdf for further information.


TIME IS RUNNING OUT - HAVE YOU RENEWED YOUR LICENSE?
Approximately half of Florida MDs are set to have their licenses to practice medicine expire on January 31, 2007. However, the Florida Department of Health reports that only 69 percent have renewed. If you have not received your licensure renewal information and are unsure if it is your year to renew, go to www.flhealthsource.com to view your profile, which has your license expiration date at the top. You cannot practice if your license expires. Renewing after the deadline is costly and time consuming, and third party payors can refuse to reimburse you for services rendered under an inactive license so renewing early is important. The Board of Medicine has made this easy by putting the renewal process online. To renew online, go to www.doh-mqaservices.com and click on "Licensees" and then "Renew License." You will need an account/user ID number and password, which was included in your license renewal notice sent in October. If you do not have your notice, you may email licensure_services@doh.state.fl.us or call 850.488.0595, and press menu option 3. If you are an FMA member, you can contact the FMA for more information at .
 
 

AMA LISTS SEVERAL FACTORS AFFECTING 2007 MEDICARE PAYMENT RATES
New legislation concerning the Medicare fee-for-service program contains a number of very important provisions affecting physicians and other providers and suppliers of services to Medicare enrollees.  The legislation, passed by Congress last month, reverses a 5 percent negative update for physician services that would have applied under the prior law and retains geographic payment adjustments that benefit physicians in many states. However, it does not reinstate the payment rates for individual physicians' services at 2006 levels.  A number of other factors will affect 2007 Medicare physician payment rates, including the statutorily mandated five-year review of physician work relative value units (RVUs), the statutorily required budget-neutrality adjustment to the work RVUs and a revision to the methodology for calculating practice expense RVUs. Only the conversion factor and the geographic adjustments will be the same as in 2006.  Payment rates for many services will change because of revisions in work RVUs and practice expense, as well as the imaging service cuts included the Deficit Reduction Act.  Because of these changes, the Centers for Medicare & Medicaid Services (CMS) has extended the current participation enrollment period for physicians to Feb. 14. Participation choices will be retroactive to January1, 2007. Physicians should check their Medicare carriers' Web sites for new fees and limiting charge rates.  Visit http://www.cms.hhs.gov/center/physician.asp for more resources from CMS, including two important Medicare fee-for-service provider education articles, on how these factors and the new legislation will affect your practice.  (AMA Federation News, January 9, 2007)

 

TIMELINES TO REMEMBER WHEN FILING CMS 1500
The AMA has developed a list of timelines to assist your billing staff when they are filling out the revised CMS 1500 claim forms. For a list of Tips for filing CMS 1500 claim forms go to http://www.fmaonline.org/phys/cms_tips.pdf

 
ONLY FIVE MONTHS REMAIN UNTIL THE NPI COMPLIANCE DATE
Are you ready to use your NPI?  A recent survey of the health care industry, conducted by the Workgroup for Electronic Data Interchange (WEDI), indicates that providers should be moving from the enumeration stage into the implementation stage to ensure NPI readiness by the compliance date.  Remember, it is estimated that it may take up to 120 days to complete the work needed in order to implement the NPI into your current business practices.  The following steps will assist you in your preparation:

Enumerate:  Have you applied for your NPI(s)?  Not only should individual providers (Type 1) have enumerated, but organizations and subparts (Type 2) should have enumerated also.

Update:  Have you received your software application updates, upgrades and/or changes relevant to NPI?  Be sure that the updates not only address the HIPAA Transactions, but includes the CMS1500, UB04 and/or Dental claim form changes.

Communicate:  Have you communicated your NPI(s) to your health plans and other organizations you work with?  Keep in mind, as outlined in current regulation, all covered providers must share their NPI with other providers, health plans, clearinghouses, and any entity that may need it for billing purposes -- including designation of ordering or referring physician.

Collaborate:  Do you know the readiness of your trading partners (such as health plans, TPAs, clearinghouses, etc...)?  It's important to work with your trading partners to know their readiness with NPI and how it impacts you.

Test:  Have you started testing the NPI, both internally and externally? 
Not only do you need to test the HIPAA Transactions such as 837 Claims, but if you process 835 Remittance Advice, be sure to test that your system can process the NPI appropriately.  Also, if you submit paper claims, be sure that you've tested the data being printed in the correct fields.

Educate:  Have you educated your staff on what the NPI is and the use of it?
It's important that staff who may be using the NPI in day-to-day work, such as verification of eligibility, or other tasks that may need the NPI, be aware of the NPI and the provider identifiers that it replaces.  The staff may have to change policies and procedures.

Implement:  Have you implemented the NPI into your business practices?
Once testing is complete, changes will go into production.  Prior to doing this, you'll need to make sure your trading partners are ready to process with the NPI only.
 

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