Among the changes mandated in the Affordable Care Act is the expansion in the next few years of Medi-Cal eligible patients. As part of the implementation of California’s Medi-Cal program, Medi-Cal managed care will be arriving in the 25 counties not currently using the plan. This now goes into effect on September 1, 2013. For those already enrolled in managed care plans, there are significant changes in the annual reporting.
Common Questions we’ve received from clients about HIPAA Compliance changes.
Q: If you have a deceased patient, does HIPAA still apply?
A: Yes, the medical record remains confidential regardless of the
Q: What are the rules for emailing or texting protected health information (PHI) to outside vendors?
A: It must be under a Business Associates Agreeement and it must have an encrypted secure line. Standard text messaging is not HIPAA compliant.
Supplemental Payments for Public DPNFs Are Available
Last month, a federal appeals court cleared the way for the AB97 Medi-Cal rate cuts to take effect. This makes it nearly certain that severe DPNF rate cuts (the 08-09 rates less 10%) will be implemented retroactive to June 1, 2011. For many facilities, the resulting rates are 10-20% below what the normal rates would be. This means that DPNFs, many of whom are almost wholly reliant on Medi-Cal payments, will soon be assessed a large payback by the state. However, a long-standing but little known state program is available to provide CPE-generated supplemental payments for publicly-owned or operated DPNFs. While this program will not replace the entire shortfall, it will still provide significant relief of at least 50% of the rate cuts.
DPNF Public Hospital Supplemental Payment Program
The Medi-Cal DPNF supplemental payment program has been in existence since 2001. It is similar to the hospital outpatient program (AB915) in that public DPNFs can claim a supplemental payment equal to the federal share of the amount by which costs exceed the payments received. In past years, prior to the rate cuts, only DPNFs with rates above the statewide median (currently $416.95) qualified for this program, because they were the only ones whose rates fell below projected costs. However, with the rate cuts of recent years, DPNFs with rates below the median now qualify for the program.
Timely Claim Forms Submittal!
The state has only a two-year window in which to claim the federal portion of the CPE from CMS. This means that DPNFs must be timely about submitting the claim forms. The state uses quarterly claim forms, and most DPNFs that already participate in the program submit a claim every quarter. DPNFs newly affected by the rate cuts should submit claim forms for quarters as far back as allowed.
HFS Can Help
HFS is assisting district and county DPNFs in preparing the claims for supplemental payment. Our professionals can provide a range of assistance depending on your organization’s specific needs, from simply providing education, to reviewing facility-prepared claims submissions, all the way to preparing the actual claims and following through to final payment.
We would be happy to answer any questions or assist with your DPNF supplemental payments. Please contact John Pfeiffer at 510-867-1314 or email@example.com.
As required by regulation, CMS must ask for new bids for Medicare claims adjudication and enrollment every five years as Medicare Administrative Contractor (“MAC”) for each region. The new contract term begins in 2013.
Palmetto GBA in Georgia has been the MAC for Region J1 (now named Jurisdiction E), which includes California, for the past five years. Apparently the new contract has been awarded to Noridian Administrative Services out of Fargo, North Dakota. They have been the Medicare Part A & B MAC for Jurisdiction F, which includes upper mid-West and Pacific Northwest states, for the past five years. The CMS award is currently under appeal and may take more time to finalize.
Over the past six months, CMS has published five years of Supplemental Security Income (SSI) data. The SSI data is used to develop Medicare Disproportionate Share Hospital (DSH) payments. Because DSH impacts a majority of hospitals across the United States, CMS previously ordered Medicare Administrative Contractors (MACs) not to issue any Notices of Program Reimbursement (NPRs) until CMS published revised SSI information incorporating data from Medicare Advantage patients. Now, the recent publication of SSI data has prompted MACs to finalize NPRs for Medicare cost reports that have been on hold for the past several years.
This development is causing an avalanche of NPRs for hospitals across the United States. For many, this means reviewing adjustments made three years ago, while at the same time, filing the current year cost report and dealing with other current finance and reimbursement issues. Also, with multiple NPRs being issued at the same time, the 180-day appeal window is starting to tick down for many cost reports. Good news: (more…)
As of September 2012, over 3,000 physicians and 184 hospitals have received over $339M in Medi-Cal incentive payments since the State Level Registry (SLR) began issuing checks last October. Contrary to Medicare’s requirement to implement the entire system and demonstrate meaningful use, the State Medi-Cal program simply requires some basic data and will issue a check even before the project goes live.
The American Recovery and Reinvestment Act of 2009 provides for Medicaid incentive payments to eligible acute care and children’s hospitals that are meaningful users of certified Electronic Health Record (EHR) technology. An eligible acute care inpatient hospital is defined as a health care facility with an average length of stay (ALOS) of 25 days or fewer, and a Claim Control Number (CCN) ending with 0001-0879 or 1300-1399. In addition, to be eligible to receive a Medicaid EHR incentive payment, acute care hospitals must also meet a 10 percent Medicaid patient volume threshold. (more…)
Recovery Audit Pre-payment Review
CMS is now expanding its Medicare Recovery Audit program (RAC) to allow auditors to review claims before being paid to ensure compliance with Medicare payment rules.
This demonstration program is in addition to the RAC program of the past several years, where auditors review claims after payment. That program will remain unchanged. In this demonstration program, CMS is focusing on seven states, including California, where past retrospective audits have resulted in high rates of payment recoveries. Four other states, excluding California, are set for audits of short inpatient stay claims. (more…)
On April 11, 2012, as required by the Affordable Care Act, the Secretary of Health and Human Services (HHS) submitted a proposal to Congress to reform Medicare wage index. After considering the studies and recommendations executed by the Medicare Payment Advisory Commission (MedPAC) and Acumen LLC, HHS is proposing to implement a Commuting Based Wage Index (CBWI) system.
The CBWI is a provider specific wage index, which accounts for a hospital’s cost of labor using commuting patterns. The commuting patterns represent a hospital’s labor market by the number of workers who commute from home to work. This information can be collected from Census results and the Bureau of Labor Statistics (BLS); however, HHS believes the most accurate reflection of commuting data derives from hospital records (e.g. payroll). Therefore, the CBWI would likely create a new data collection process, whereby providers would submit employee information by geographic unit (e.g. zip codes, census tracts). (more…)
The American Recovery and Reinvestment Act of 2009 provides for incentive payments beginning in 2011 for Medicare eligible professionals and acute care hospitals, including Medicare Advantage affiliated hospitals and Critical Access Hospitals that are meaningful users of certified electronic health records (EHR) technology.
Eligible hospitals can begin receiving payments in any federal fiscal year from FFY 2011 to FFY 2015. However, the incentive payment will decrease for hospitals that start receiving payment in FFY 2014 and later. Thus, in order to receive the maximum incentive payment, a hospital must demonstrate meaningful use by 9/30/13. No incentive payments will be made after FFY 2015, and there will even be a negative adjustment to future PPS payments for those hospitals that cannot demonstrate meaningful use by 9/30/15. (more…)
The Centers for Medicare and Medicaid Servicers (CMS) is empowered to survey an accredited provider to validate the accreditation process of the Accrediting Organization, e.g. The Joint Commission or DNV Healthcare. While all hospitals are subject to periodic accreditation surveys, the CMS surveys can be extremely rigorous and stressful. In many cases, hospital senior management may be singularly focused on the survey for a period of months.
HFS has found that while hospitals are usually well equipped to deal with periodic surveys from organizations such as The Joint Commission, they may not be as prepared for a CMS survey. (more…)