Friday, August 18, 2017

While waiting for a state health-records exchange, medical society launches one



Frustrated that after 10 years of effort the state of Connecticut has yet to launch a functioning health information exchange (HIE) allowing physicians, hospitals and other health care providers to share patient medical records, the Connecticut Medical Society is offering one of its own.
Available to all clinicians in the state and called CTHealthLink, it is based on a system currently used in Kansas.

Part of the motivation was the threat that clinicians would miss out on Medicare and Medicaid incentives given for participating in a health information exchange and would instead be subject to penalties, said Matthew Katz, executive vice president and chief executive officer of the Connecticut State Medical Society (CSMS).

“The Connecticut medical society decided to go ahead and try to do it because our members are missing out on the opportunity for financial benefits,” and many have to pay penalties for not participating, Katz said.

For the 2017-18 federal fiscal year, only 800 of the eligible medical professionals and none of the eligible hospitals are expected to receive Medicaid incentive payments, according to planning documents for the state health information exchange.

In 2007, Connecticut first attempted to create a health information exchange (HIE) specifically for Medicaid with a $5 million grant, before most physicians had switched to electronic health records. It was cutting edge, but the state’s medical professionals weren’t ready for it, said Dr. Thomas Agresta, a professor and director of medical informatics in family medicine at UConn Health, who has been involved in HIE efforts since the beginning.

Between 2007 and 2016 the state tried twice more to design and implement an HIE for all providers. Neither attempt produced a functioning system despite extensive planning and $18 million in funding.

“Everybody was hyped up and interested in the potential for health, but not aware of changes that needed to occur,” Agresta said. “Most people were a little naïve in terms of complexity.”

Before deciding to join CTHealthLink, all providers — hospital systems, like Yale New Haven Health, private practices and physician groups — are facing this decision: Is it worthwhile to sign on with CTHealthLink or should they wait for a fourth attempt at a state HIE system to pan out?
A health information exchange allows any participating clinician to see the procedures, tests, lab results and medical histories ordered for their patients by other participating clinicians, preventing repetition that wastes time and money.

CTHealthLink also provides a portal that allows patients to see their own records, something providers have expressed interest in having at state-held planning discussions for attempt four.
Yale New Haven Health says it will need to make sure the CTHealthLink system would truly benefit patients and be cost-effective before signing up, said Lisa Stump, chief information officer for the hospital system.

“There are a few questions that need to be answered before I’m confident in submitting our data,” Stump said. “Is there good structure around opting in and out, so that patients get a choice” of whether to have their medical information shared?

Stump said Yale New Haven Health also would want to be sure CTHealthLink would improve care enough to make a subscription worth the cost. When the state system begins operating all hospitals will be required to join, whether they are part of CTHealthLink or not.


CTHealthLink will cost between $50 and $120 per physician per month, depending on when a facility joins, whether the physicians are CSMS members, and whether the provider is a very large practice or a hospital system, Katz said. There is also a set-up cost based on the internal records system a practice or hospital uses.


“If we do the math, even at the lowest rate of $50, for a medical practice of 1,200 physicians, it is $720,000 per year…and at $120 it’s $1.7 million,” Stump said.

For an organization the size of Yale New Haven Health, which includes five hospitals and 3,500 to 4,000 physicians, it would be two or three times more.

“The benefit of any HIE is how robust the data are in the HIE. We are a large health exchange and have good sharing within our system” and with the Veterans Administration’s Healtheway system, Stump said. “Is that cost (of CTHealthLink) going to bring us a value more than the means we already have.”
And more than the state system will in the coming years.

Incentives for participation in an HIE are available to all physicians and many other clinicians through the Medicare quality payment program (MIPS). Eligible clinicians who don’t participate in MIPS by the end of 2017 would see a 4 percent reduction in their Medicare reimbursement in 2019.
“Even though it is starting late (in the year), it is more than enough time to get the federal benefits,” Katz said.

CTHealthLink expected to sign contracts in July and to begin sharing data between medical practices beginning in August and September. But as of August 15, none of the contracts had been finalized.
According to CSMS, the process has been delayed because determining the set-up cost each hospital or practice’s electronic health record vendor is going to charge is taking longer than expected.


The goal is to include at least 80 percent of the state’s 9,600 physicians in fewer than five years, Katz said.


Connecticut Hospital Association spokeswoman Michelle Sharp said the association “is pleased that CSMS is seeking a solution for its physician practice members who may need additional support to elevate their health IT infrastructure.”

CTHealthLink is set up like a central data warehouse that allows doctors and patients to view all their patients’ health records in one place, Katz said, with only a three-minute delay from the time an electronic health record is posted.

Katz said the model is much less expensive than others in use, and wouldn’t require any state or federal funding to operate. However, the state’s health information technology officer, Allan Hackney, said there are cheaper ways to do it.

“Whenever you bring data to the center, it is automatically a more expensive undertaking, because you have to curate the data, store it, secure it, back it up, you have to have disaster recovery, all those things layered across each other,” Hackney said.

Hackney’s position was created in 2016 after a third state attempt to construct an HIE by the Department of Social Services ended without a product and the responsibility was transferred to Hackney and an advisory council.


Despite the previous work, the fourth attempt began by working to understand what providers really needed, with $10 million in combined federal and state money.

The state knew from experience that if it were going to succeed this time, it needed the input of individuals who would be using the system as well as technology that wouldn’t become outdated before the project was complete.

At the same time, DSS requested more than $14 million in grant money — 90 percent percent from the federal government and 10 percent from the state — to implement a Medicaid-specific health information system that eventually would tie into the larger state system, if both are successful. 
According to the office of the lieutenant governor, DSS needs to construct its own system as quickly as possible because of specific Medicaid reporting requirements.

But efforts to implement a strategy to make reporting for Medicaid easier have always been a central part of the state HIE efforts, whether they were led by DSS or not, and that is no different with the fourth attempt, planning documents show. But it is not clear when the universal statewide system would implement the needed Medicaid features.

The system is scheduled to be functioning by the beginning of 2018, but various features and access to different kinds of data will be added incrementally, based on priorities identified by the system’s users.

Unlike the CTHealthLink model, the state is working on a system that allows data to be pulled directly from its source instead of being gathered all in one location, a lower-cost and lower-risk option, Hackney said.

The state system will be built to connect all clinicians, from physicians to pharmacists to behavioral health workers, even if they are participating in CTHealthLink or any other, smaller exchanges already, Hackney said.

Eventually, the system will allow all medical information, including veterans’ information from the Department of Defense as well as prescriptions and immunization records, to be accessed by all participating medical professionals.

The order of the first few features to be created will be decided by September, according to the office of the lieutenant governor.

Despite the potential for a more user-friendly product, according to Hackney, this will take time, and Dr. Jeff Gordon, CSMS president, who works in a private practice owned by Hartford Healthcare, said the state already has lost the faith of many health professionals because of its many failed attempts. 

“CSMS have a model that they’re using that’s been proven to be financially sustainable,” Gordon said. “Hospitals and physician groups have a good relationship with us; they don’t have a good relationship with the state.”

Despite the previous failures, Agresta said he has more faith in the state’s latest attempt because the technology is finally ready for it.

“Unlike the first few attempts, when we tried to do this in the past, and very few people understood what exchanges could do, there is more understanding of data,” Agresta said. “During the 2010-2012 time frame, we were still trying to get physicians to adopt EHRs. Basically we were asking them to learn to crawl, to walk and to run all at the same time.”

Although CTHealthLink hopes the Kansas model will work just as well in Connecticut, Hackney is not as confident.

The difference in Connecticut, Hackney said, is that healthcare providers already have invested millions in their own internal systems, and the major providers of those systems have connections to allow record exchanges between clinicians that use the same vendor. Hartford Healthcare, Yale New Haven and Trinity New England, parent of St. Francis and St. Mary’s hospitals, all use the same vendor, Epic, and UConn Health is in the process of switching over to it, Agresta said.

Other hospitals, physician groups, behavioral health facilities and small practices have yet to be linked in such a way. They are still waiting for a system like CTHealthLink or the state system to connect them with their patients’ other providers.

Hackney said he doesn’t want Connecticut to fall into the same trap that many other states have, where systems are developed and then not adopted by many providers, or the systems become obsolete after only a short time as technology progresses.

“My view on this is that the only way state efforts will win is if it is collaborative and focused on value,” Hackney said. “If we focus on value, you know you’re going to hit people with a difference in the way they deliver health care.”


Wednesday, August 16, 2017

Chicago Podiatrist Sentenced to 7 Years for False Documentation



A Chicago podiatrist has been sentenced to more than seven years in prison and ordered to pay nearly $7 million in restitution following his conviction for health care fraud.


Dr. Yev Gray was sentenced to 90 months in prison and ordered to pay $6,974,895.00 in restitution related to the submission of false reimbursement claims for non-rendered podiatric services.

According to court records, Dr. Yev Gray was the owner and president of Aggeus Healthcare, headquartered in Chicago, Illinois, which provided podiatry services to residents of long- term care facilities. As of September 2015, Aggeus was operating in at least 16 states. In Missouri, Aggeus contracted with podiatrists to provide services in eleven facilities, with seven of the facilities located in the cities of Bourbon, Hannibal, Maryland Heights and Poplar Bluff, Missouri.

According to court records, Dr. Gray created an electronic medical record (EMR) system, which automatically inserted into patient records, diseases and symptoms that the patients did not have. Dr. Gray also pressured Aggeus podiatrists to provide unneeded services, such as Doppler studies, the incision and drainage of abscesses, and the removal of calluses. Some of the podiatrists complied, provided the unneeded services, and signed the false treatment notes; others refused. Despite repeated complaints from patients, nursing homes, and some of their podiatrists, Dr. Gray and his co-defendants continued to create false patient records and to bill for medically unnecessary services. From 2009 to September 2015, Medicare paid Aggeus Healthcare millions of dollars based on the false reimbursement claims submitted by Aggeus.


Yev Gray, 49, Chicago, IL, pled guilty on May 12, 2017 to one felony count of conspiracy to commit healthcare fraud and one felony count of making false statements relating to health care matters.

Natalie Gray, a lawyer and the wife of Dr. Gray, is currently serving a one-year prison term for her role in the health care fraud conspiracy. The CEO of Aggeus and four Aggeus podiatrists are awaiting sentencing.



Sunday, July 30, 2017

Arm Your Team for Victory


What will define those who claim victory and those who are defeated in the battle towards value based care? Will it be those organizations with the most money, power and seats at the table? Or will it be those who are nimble, flexible and open to change?

I believe it will be both. As victory will not be defined by the owners and head coaches but instead by how the players execute on the field. It will be the game time decisions that matter most.

A quarterback who can read the defense and adjust accordingly will provide far greater value to the offense than the most athletic quarterback who misses the blitz every time.

Perhaps Napoleon said it best, “Battles are won by the power of the mind.” For in a game of inches, the winners and losers will be defined by those who can execute in the moments that matter most.

Prepare your team for victory with information at the point of care!

ERM Consulting has developed the industries best tools for players on the frontline.


Coding and Documentation Guide for Providers and Coders

This 42 page guide includes proper ICD-10 coding and clinical documentation for the most common diagnoses included in the risk models. A complete list of CMS-HCCs with RAF and demographics included. Order 1 for your entire team! Orders of 100 or more can be white labeled with your logo at no charge. Please email logo to kgifford@ermconsultinginc.com after purchase.






CMS-HCC Quick Coder


This 36 page guide contains a list of the most common HCC codes in the Medicare (CMS-HCC) model. Common codes are included from both the medical and prescription models. Orders of 100 or more can be white labeled with your logo at no charge. Please email logo to kgifford@ermconsultinginc.com after purchase.










Ohio Doctors Would Report Opioid Diagnosis Codes Under Deal


Ohio doctors have reached tentative agreement with the Kasich administration on a proposed rule requiring them to report the specific diagnosis of every patient who receives a prescription painkiller.


Ohio doctors would report the specific diagnosis of every patient who receives a prescription painkiller under a tentative agreement reached Friday with the Kasich administration.

The 11th-hour compromise between the Republican governor's office, the state Medical Board and associations representing doctors and hospitals followed months of wrangling over new opioid prescribing rules proposed in April in a state that leads the nation in opioid addiction and death.

A record 3,050 Ohioans died from drug overdoses in 2015, a figure expected to jump sharply once 2016 figures are tallied.

The compromise on prescription reporting was reached in time for a legislative rule-making panel's scheduled vote Monday.

The disputed rule required prescribers to enter what's known as an ICD-10 code into Ohio's online reporting database for every controlled substance prescription. The administration argued the reporting mandate was critical to fighting Ohio's top status for opioid abuse and death.

Under the compromise, hospitals and doctors' offices would report codes for opioids right away, but they would have an additional nine months to begin reporting all other controlled substances.

Medical Board Director A.J. Groeber said collecting ICD-10 codes — in other words, knowing what conditions doctors are treating using potentially addictive opioids — is "the linchpin" both to effective regulation and education.

"It's not just about going after the bad actors," Groeber said. "We want to be able to do that, but we also want to educate the vast majority of our well-intentioned licensees to make sure that they know that they can treat patients effectively with fewer pills and fewer days' supply."

Ohio State Medical Association spokesman Reggie Fields said doctors didn't object to the goal, but to the method for accomplishing it, which they saw as unworkable.

"The bottom-line goal here is to try to improve the opioid prescribing that's taking place across the state of Ohio, and we are in complete agreement with that," Fields said. "The only issue we had here was the vehicle that had been proposed to get there was just unfeasible to be able to accomplish, because of the administrative and financial burden."

Ohio Hospital Association spokesman John Palmer said that was because the list of ICD-10 codes is massive and many doctors' offices and hospitals are not yet set up to incorporate the relatively new code system into their reporting.

"There are thousands upon thousands of codes, from things like knee replacements to hip replacements to a splinter or an Orca whale bite or a tiger bite," he said. "So it's just a whole slew of different diagnoses codes."



Tuesday, July 25, 2017

Only 6% of PCP's Able to Identify 11 Risk Factors for Pre-Diabetes


Most primary care doctors can't identify all 11 risk factors for prediabetes, a small new survey finds.

Researchers from Johns Hopkins University said their findings should prompt doctors to learn more about this condition that affects an estimated 86 million adults in the United States and could eventually lead to type 2 diabetes.

"We think the findings are a wake-up call for all primary care providers to better recognize the risk factors for prediabetes, which is a major public health issue," said study first author Dr. Eva Tseng in a university news release. She's an assistant professor at Hopkins' School of Medicine.

It's estimated that 90 percent of those with prediabetes are unaware that they have the condition, according to the U.S. Centers for Disease Control and Prevention.

The American Diabetes Association (ADA) explains that changes in diet, exercise and certain medications can help prevent people with prediabetes from going on to develop type 2 diabetes.

To investigate why so many people with prediabetes go undiagnosed, the researchers asked primary care doctors attending a medical retreat to complete a survey testing their knowledge of key risk factors for the condition.

The ADA has guidelines that list a total of 11 specific risk factors that determine if a patient should be screened for prediabetes. They include physical inactivity, a first-degree relative with diabetes, high blood pressure, and a history of heart disease.

A total of 140 doctors took the survey. Nearly one-third of those surveyed weren't even familiar with the ADA's prediabetes guidelines. Only 6 percent were able to identify all 11 risk factors. On average, the doctors could correctly identify just eight of the warning signs.

The doctors also had to identify the healthy range for glucose tests results used to diagnose prediabetes as well as recommendations about weight loss and physical activity for people with the condition.

Only 17 percent identified the correct values for fasting glucose and another key measure of glucose, known as HbA1c, which are used to diagnose prediabetes, the study authors said.

Only 11 percent of the doctors said they would refer a patient to a behavioral weight loss program, even though that's what the ADA recommends. But 96 percent did choose to provide counseling on diet and physical activity.

Most of the doctors said they wouldn't prescribe metformin for prediabetes. But in 2017, the ADA recommended that metformin be considered for patients with prediabetes who haven't reduced their risk for diabetes through lifestyle changes alone.

"Primary care providers play a vital role in screening and identifying patients at risk for developing diabetes. This study highlights the importance of increasing provider knowledge and availability of resources to help patients reduce their risk of diabetes," said study senior author Dr. Nisa Maruthur, an assistant professor of medicine at Hopkins' School of Medicine.

The results were published recently in the Journal of General Internal Medicine.

More information
The U.S. Centers for Disease Control and Prevention provides more information on prediabetes.

Read More


Tuesday, July 18, 2017

Physicians participating in Advanced APMs in 2017 will receive a 5% Incentive Payment in 2019



Under CMS’s new Quality Payment Program, which will adjust Medicare Part B payments starting in 2019 based on data from this year, physicians and other eligible clinicians must qualify for one of two payment “tracks”, either the Merit-Based Incentive System (MIPS) or the Advanced Alternative Payment Model (Advanced APM) track.   A physician who qualifies under the MIPS in 2017 can earn up to a 4% payment adjustment to Medicare Part B payments in 2019.  Physicians who qualify under the Advanced APM track can earn up to a 5% payment adjustment in 2019.  
Since the Quality Payment Program went into effect on January 1, 2017, it has been unclear whether physicians participating in an Advanced APM in 2017 would be able to meet CMS’ quality and reporting requirements and earn a 5% payment adjustment to their Medicare Part B claims in 2019.
CMS recently provided clarity on this issue by predicting that almost 100% of physicians and other eligible clinicians participating in Advanced APMs in 2017 will qualify for a 5% payment adjustment to their Medicare Part B claims in 2019.  CMS based this prediction on an analysis of Advanced APM claims data submitted from January through August 2016 (before the Quality Payment Program went into effect).
CMS also stated that physicians who participate in an Advanced APM need to meet only one of two criteria to earn the 5% payment adjustment in 2019:  (1) receive 25% of the physician’s Medicare Part B payments through the Advanced APM; or (2) see 20% of the physician’s Medicare patients through the Advanced APM.  [A list of Advanced APMs in which a physician may participate in 2017 can be found at the following link: CMS List of Advanced APMs]
Participating in an Advanced APM can have several benefits (including being exempt from reporting quality data under the MIPS payment track), but also involves taking on some risk.  If you are considering participation in an Advanced APM, please contact an experienced attorney to discuss.
CMS is expected to issue formal determinations regarding the qualification of particular physicians for the Advanced APM track later this year.



Friday, July 14, 2017

OPPS, ASC, PFS: Proposed 2018 Policy and Payment Rate Changes





  • Hospital Outpatient, ASC: CMS Proposes 2018 Policy and Rate Changes
  • Physician Fee Schedule: CMS Proposes 2018 Payment and Policy Updates


  • Hospital Outpatient, ASC: CMS Proposes 2018 Policy and Rate Changes

    Proposed rule and Request for Information promote improvements to quality, accessibility, and affordability of care
    On July 13, CMS issued a proposed rule that updates payment rates and policy changes in the Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System. The proposed rule is one of several for 2018 that reflect a broader strategy to relieve regulatory burdens for providers; support the patient-doctor relationship in healthcare; and promote transparency, flexibility and innovation in the delivery of care. 
    The OPPS and ASC payment system are updated annually to include changes to payment policies, payment rates, and quality provisions for those Medicare patients who receive care at hospital outpatient departments or receive care at surgical centers. Among the provisions in this rule, CMS is proposing to change the payment rate for certain Medicare Part B drugs purchased by hospitals through the 340B program. The proposed rule also includes a provision that would alleviate some of the burdens rural hospitals experience in recruiting physicians by placing a two-year moratorium on the direct supervision requirement currently in place at rural hospitals and critical access hospitals. In addition, CMS is releasing within the proposed rule a Request for Information to welcome continued feedback on flexibilities and efficiencies in the Medicare program.
    For More Information:
    See the full text of this excerpted Press Release (issued July 13).



    Physician Fee Schedule: CMS Proposes 2018 Payment and Policy Updates

    Proposed rule & Request for Information provide flexibility, support strong patient-doctor relationships
    On July 13, CMS issued a proposed rule that would update Medicare payment and policies for doctors and other clinicians who treat Medicare patients in CY 2018. The proposed rule is one of several Medicare payment rules for CY 2018 that reflect a broader strategy to relieve regulatory burdens for providers; support the patient-doctor relationship in healthcare; and promote transparency, flexibility, and innovation in the delivery of care. 
    The Physician Fee Schedule is updated annually to include changes to payment policies, payment rates, and quality provisions for services furnished to Medicare beneficiaries. This proposed rule would provide greater potential for payment system modernization and seeks public comment on reducing administrative burdens for providing patient care, including visits, care management, and telehealth services. The rule takes steps to better align incentives and provide clinicians with a smoother transition to the new Merit-based Incentive Payment System under the Quality Payment Program. The rule encourages fairer competition between hospitals and physician practices by promoting greater payment alignment, and it would improve the payment for office-based behavioral health services that are often the therapy and counseling services used to treat opioid addiction and other substance use disorders. In addition, the proposed rule makes additional proposals to implement the Center for Medicare and Medicaid Innovation’s Medicare Diabetes Prevention Program expanded model starting in 2018.
    For More Information:
    See the full text of this excerpted Press Release (issued July 13).


    Monday, July 3, 2017

    Urban Coding Legends: Morbid Obesity

    Should you code morbid obesity when a patient has a BMI of 36?

    This is one of my favorite questions to ask physicians, coders and healthcare executives when I am teaching. Why? Because it is guaranteed to elicit the following three responses:

    A.      Yes, absolutely! As long as the patient has 3 or more chronic conditions….

    B.      No, I never use that code. I don’t want to upset anyone with open notes and patient portals…

    C.      No, morbid obesity should only be coded with a BMI of 40.0 or more…

    One-third of the audience will select “A” as the correct answer, one-third will select “B” and one-third will choose “C”. This scenario will play out the same way in Miami, Philadelphia, Austin, Chicago, Little Rock or any other city in America. Why? Because it is an urban coding legend…

    Urban Coding Legend #1: 

    Morbid obesity should always be coded when a patient has a BMI greater than 35.0 and 3 or more chronic conditions. 

    True or False?
    The answer is false. Obesity is defined and classified by both the United States Preventive Task Force and The National Institutes of Health and National Heart, Lung, and Blood Institute using the following classification:
    Obesity is divided into three classes. The third class, extreme obesity, also called severe obesity, is synonymous with the term “morbid obesity” and is diagnosed based on a BMI of 40.0 or greater.
    According to the NHLBI: A person with a BMI (body mass index) value of 40 or greater would be considered morbidly obese. An adult who has a BMI of 30 or higher is considered merely "obese.". Grade 3 overweight (commonly called severe or morbid obesity) is a BMI greater than or equal to 40 kg/m2.

    The Origins

    This “urban coding legend” originated from the corridors of “risk adjustment optimization” teams, searching for “low hanging fruit” and the clinical evidence to “support” it.


    The following events, recommendations and guidelines set the stage and a story was born…

    1.       USPTF Updates Recommendations
    In 2012, the U.S. Preventive Services Task Force (USPSTF) issued updated recommendations regarding the screening and management of obesity for adults.

    2.       The American Academy of Family Physicians
    The AAFP publishes clinical evidence to support the USPTF Recommendations:
    From the AAFP:
    In patients with a BMI of 25 kg/m2 or greater, further evaluation of risk factors is required. Blood pressure and lipid levels should be measured, and fasting glucose tested.
    Bariatric surgery may be considered in adults who have not achieved weight loss with dietary or other treatments and who have a BMI of 40 kg/m2 or greater, or for those who have a BMI of 35 kg/m2 or greater with significant obesity-related comorbidities (e.g., severe hypertension, type 2 diabetes, obstructive sleep apnea).
     Bariatric surgery may also benefit patients with obesity-related comorbidities who have a BMI of 35 kg/m2 or lower, but it is not routinely recommended for these patients

    3.      Medicare Payment Guidelines:
    In response to the updated USPTF Guidelines and AAFP clinical evidence supporting the benefit of gastric bypass surgery as a treatment for obesity Medicare updated their payment policies for this procedure:
    (Rev. 2841, Issued: 12-23-13, Effective: 09-24-13, Implementation: 12-17-13)
    Covered Bariatric Surgery Procedures for Treatment of Co-Morbid Conditions Related to Morbid Obesity
    Medicare contractors acting within their respective jurisdictions may determine coverage of stand-alone LSG for the treatment of co-morbid conditions related to obesity in Medicare beneficiaries only when all of the following conditions are satisfied:
    ·         The beneficiary has a body-mass index (BMI) ≥ 35 kg/m2;
    ·         The beneficiary has at least one co-morbidity related to obesity; and
    ·         The beneficiary has been previously unsuccessful with medical treatment for obesity.
    4.       Revised HCC Model
    On April 1, 2013 CMS released the Announcement of Calendar Year (CY) 2014 Medicare Advantage Capitation Rates and Medicare Advantage and Part D Payment Policies and Final Call Letter.
    In the Final Call Letter, CMS confirmed that they would be implementing the updated, clinically revised CMS-HCC risk adjustment model proposed in the Advance Notice for CY2014. The new model expanded the current number of Condition Categories from 70 to 79.
    Under the revised model, the “Metabolic” category was expanded from one (HCC 21) to three (HCC 21, HCC 22, HCC 23). Given the prevalence of obesity, the new HCC 22 “morbid obesity” was quickly identified as a “low hanging fruit” for optimization teams. By coding morbid obesity with a BMI of 35.0 vs. 40.0 the prevalence rates, A.K.A. payments, to the plans would greatly increase.
    The previous three events were loosely woven together to form support for the practice and an urban coding legend rose like a phoenix from the ashes.



    HCC 22 includes the following ICD-10 Codes:

     Do you see a BMI under 40 in the above chart?

    Remember clinical, coding and payment guidelines can not be substituted to fit the situation as needed.

    ERM Consulting Inc.
    Kameron Gifford, CPC


    Thursday, June 22, 2017

    Book Your Onsite Risk Adjustment Workshop Today!




    Train your entire team onsite with our 1/2 day, 1 day and 2 day workshops!                
    • AAPC CEUs available for your coders, CDI specialists, compliance team and auditors.
    • AAFP and AMA CME available for all physician training.

     2017 dates are filling up quick!

    • Intro to Risk Adjustment
    • Advanced Risk Management for Value Based Care
    • Intro to HCC Coding
    • Advanced HCC Coding
    • CDI for Risk Adjustment
    • Risk Adjustment Validation
    • Rapid Practice Innovation (TCPI)
        
          Half-day Workshops start at $3500
          One-day and Two-day Workshops start at $5000

          Visit ERM Consulting to learn more or email Kameron Gifford



        

        

    Tuesday, June 13, 2017

    How Can We Improve?

    Are you looking for the very best in risk adjustment education?

    If so, join us in Orlando, Florida on July 21, 2017 for a day of risk adjustment, clinical documentation improvement and HCC coding.

    Why Should I Come?

    • CME / CEU available from AAPC, AMA and AAFP

    • Network with plan leaders, managed care executives, medical directors, primary care physicians, fiancé leaders and coders from across the country.

    • Have your toughest questions answered by risk adjustment experts.

    • Best of all, you will take home great tools!

                 Bring the whole team and save 20% on 3 or more

    Agenda:

    • Review the different risk adjustment models and their impact on medical practice management.

    • Discuss the impact of shifting from RAPS to EDS. What does this mean for office based claims.

    • Take a deep dive into HCC Coding and Documentation. Review real examples to see what validates, what doesn’t, and why.

    • Avoid risk adjustment pitfalls. Recent litigation relating to false risk adjustment certifications and  overpayments.

    • Tips for engaging physicians.Learn how to leverage frontline staff to be successful in the world of risk adjustment and value based payments.


    Who Should Attend:

    • Managed Care Executives

    • Physicians / Medical Directors

    • ACOs, MSOs, IPAs and Health Alliance Members

    • CMS TCPI Participants

    • Value Based Care Organization

    • Medicare Advantage, Commercial and Medicaid Plans

    • Rural Health Centers and FQHCs

     

    Each Attendee will Receive:

    • Clinical Documentation and Coding Guide $ 99 Value

    • HCC Quick Coder (Mappings to ICD-10 Codes) for MA and Commercial Models

    • Risk Adjustment Workbook and Appendix with Easy to Use Templates

    • Laminated Coding and Documentation Tools

    FOR DISCOUNTED HOTEL RATES:
    Call to 407-964-7165 between 8:30am and 5:00pm,
    Monday through Friday to book your room.

    For More Events Visit ERM Consulting

    AAPC CEU and AAFP CME Available!

    This Live activity, Advanced Risk Management and CDI for Primary Care, from 07/21/2017 - 07/01/2018, has been reviewed and is acceptable for up to 5.75 Prescribed credit(s) by the American Academy of Family Physicians. Physicians should claim only the credit commensurate with the extent of their participation in the activity. 

    AMA/AAFP Equivalency:

    AAFP Prescribed credit is accepted by the American Medical Association as equivalent to AMA PRA Category 1 credit(s)™ toward the AMA Physician’s Recognition Award. When applying for the AMA PRA, Prescribed credit earned must be reported as Prescribed, not as Category 1.

    Saturday, June 10, 2017

    The Centers for Medicare & Medicaid Services (CMS) announced predictive Qualifying APM Participant (QP) status for 2017 Advanced APMs.

    Predictive Qualifying APM Participants

    The Centers for Medicare & Medicaid Services (CMS) announced predictive Qualifying APM Participant (QP) status for 2017 Advanced APMs. By looking at historical Part B claims data, CMS predicts that nearly 100% of eligible clinicians in Advanced APMs with data currently available will be QPs in performance year 2017.
    Click on the links for additional Information:

    What is the Predictive QP status analysis?


    One of the Quality Payment Program’s goals is to be clear about your Qualifying APM Participant (QP) or Partial QP status. 

    For the 2017 Predictive QP analysis, this is how CMS determined if you, from your participation in one of the following Advanced APMs, are predicted to be a QP for the 2017 performance year and are likely to be eligible for the 5% APM Incentive Payment in the 2019 payment year. These calculations are predictive in nature, meaning they are a prediction of your QP status in performance year 2017, if you participate in at least one of these Advanced APMs in performance year 2017:
    • Comprehensive ESRD Care (CEC) -Two-Sided Risk
    • Comprehensive Primary Care Plus (CPC+)
    • Next Generation Accountable Care Organization (ACO) Model
    • Medicare Shared Savings Program -Track 2
    • Medicare Shared Savings Program -Track 3
    For this analysis, CMS used administrative claims with dates of service between 1/1/16 and 8/31/16 that were processed between 1/1/16 and 11/30/16. Actual QP determinations will use claims data from the relevant performance year as of three points in time, or “snapshot” dates: March 31, June 30, and August 31.

    If you are a participant in the Comprehensive Care for Joint Replacement Model (CJR)—CEHRT Track, CMS did not make predictions about your QP status for performance year 2017. The CJR-CEHRT Track did not begin until 2017 so there are no historical claims data available.

    In addition, CMS did not make predictions for the Oncology Care Model (OCM)—Two-Sided Risk Arrangement as there are no OCM practices currently participating in this arrangement.

    What were the Predictive QP & Partial QP determination steps?

    CMS took the following steps to estimate QPs and Partial QPs in our 2017 predictive analysis.
    1. Identified eligible clinicians participating in Advanced APMs using the APM Entity participation lists.
    2. Identified attribution-eligible beneficiaries from Medicare Parts A and B administrative claims data and Medicare beneficiary enrollment information.
    3. Identified beneficiaries attributed to Advanced APM Entities.
    4. Calculated payment amount Threshold Scores.
    5. Calculated patient count Threshold Score.
    6. Determined predictive QP or Partial QP status for an APM Entity group based on the payment amount or patient count. We applied the more advantageous QP Status to the eligible clinicians participating in the APM Entity.
    How did CMS identify attribution-eligible beneficiaries?

    CMS found beneficiaries to be attribution-eligible to an APM Entity if during the historical assessment period they:
    • Weren't enrolled in Medicare Advantage or a Medicare Cost Plan.
    • Didn't have Medicare as a second payer.
    • Were enrolled in both parts A and B for the entire QP performance period.
    • Were at least 18 years of age on January 1.
    • Were a United States resident.
    • Had at least one claim for E/M services furnished by one or a group of eligible clinicians used in assignment in an APM Entity during the historical assessment period.
    To match the attribution eligibility criteria with each APM’s attribution methodology, we may apply exceptions to the evaluation and management requirement for attribution-eligible beneficiaries. Such an exception will be applied in 2017 to the CEC model, including the predictive QP analysis.







    Download the Fact Sheet to Read More



    CMS Is Accepting Future Measures and Activities for Three MIPS Performance Categories

    CMS' Annual Call for Measures and Activities for the Merit-based Incentive Payment System (MIPS) track of the Quality Payment Program (QPP) is accepting Quality and Advancing Care Information measure proposals through June 30, 2017 for the 2018 program year; measures submitted beginning July 1, 2017 will be considered for the 2019 program year.
    CMS encourages clinicians, measure stewards, organizations, and other stakeholders to identify and submit measures and activities to be considered for the Quality, Advancing Care Information, and Improvement Activities performance categories of MIPS in future years.

    Submission Details
    Measures and activities should be relevant, reliable, and valid at the individual clinician level. To be considered, proposals must include measure specifications, related research, and background.
    A final list of measures and activities for MIPS clinicians will be published in the Federal Register no later than November 1 of the year prior to the first day of the performance period. Please note that some Advancing Care Information measures finalized in the 2018 final rule may not take effect until 2020, depending on the functionalities and workflow changes needed for implementation.
    For More Information
    Remember to review the Annual Call for Measures and Activities fact sheet to learn more and understand the process for submitting measures for the MIPS performance categories. Please direct any questions on measure and activity submissions to the QPP Service Center at QPP@cms.hhs.gov.