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Check your MIPS status online with new CMS tool

Posted by on May 8, 2017 in Latest News | Comments Off on Check your MIPS status online with new CMS tool

Check your MIPS status online with new CMS tool

While most clinicians should have received their Merit-based Incentive Payment System (MIPS) eligibility letters by now, CMS has also recently provided groups a way to check online whether or not they are required to participate in the new quality reporting program. Individuals can check whether they fall below the Medicare volume threshold ($30,000 or less in Medicare payments or seeing 100 or fewer Medicare patients) or qualify for another exemption by entering their NPI here: https://qpp.cms.gov/learn/eligibility. It’s important to note that if an individual doctor is told they don’t meet the thresholds to be forced to participate as an individual, they don’t have to report with clinicians in their group who do have to participate unless they elect to report as a group. In that case, even doctors who don’t meet the volume thresholds would be required to participate with their group. With that in mind, some of groups may decide it’s best to report as individuals instead of as a group if they have multiple members who don’t have to participate and would prefer to avoid being affected by bonuses or penalties. CMS is basing its participation determinations on 12 months of data ranging from Sept. 1, 2015 to Aug. 31, 2016. Later this year, another assessment will be run based on data between Sept. 1, 2016 and Aug. 31, 2017. That means that even if someone is told right now that they have to participate, that may change later this year when later data is reassessed if their Medicare volumes went down between the two periods. Just as a reminder, clinicians enrolled in Medicare for the first time in 2017 are also exempt for this...

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Looking for a registry to assist with 2017 MIPS? Check out the full CMS list

Posted by on Apr 20, 2017 in Latest News | Comments Off on Looking for a registry to assist with 2017 MIPS? Check out the full CMS list

Looking for a registry to assist with 2017 MIPS? Check out the full CMS list

With the inaugural reporting period for the Merit-based Incentive Payment System now underway, physicians should be preparing to report their quality metrics and practice improvement activities if they’re not participating in an Advanced Alternative Payment Model that exempts them from MIPS. While many individual physicians and groups were able to survive the Physician Quality Reporting System through claims-based reporting, the expected elimination of that reporting method after 2017 means groups should be considering their options to get on board with a registry that can assist with MIPS reporting. Late last week, CMS released its list of approved registries for 2017. The full list can be viewed here. CMS-approved registries and clinical data registries collect quality data from a clinician or group practice and submit it to CMS on behalf of MIPS participants. Unlike claims-based reporting, which essentially sets a reported measure in stone once an applicable claim is submitted to CMS, registries can provide ongoing feedback on your reporting before it’s finalized to help ensure you’ve reported to the best of your ability, as opposed to waiting for CMS to provide feedback on your work more than a year after it’s been submitted. One of the most noteworthy new additions for Pathologists is the Pathology Quality Registry offered by the College of American Pathologists. While the registry is not expected to go live until it can be unveiled at the CAP annual meeting this fall, CAP officials have said they plan to offer an additional eight pathology-specific quality measures in addition to the eight that have carried over from PQRS (although they’ve yet to reveal what those measures will be). This means that groups who previously had little hope of receiving a bonus due to a lack of applicable measures may now have more options available to them. Typically, we’ve seen these registries cost groups about $300-$400 per reporting physician. However, we strongly suggest you attempt to negotiate a better rate if you’re part of a large group. Feel free to contact Vachette if you’ll be utilizing a registry for the first time this year. We’ve worked with several registries on behalf of our clients and would be happy to provide guidance to help you find the partner that can best help your group maximize its MIPS scoring potential. While there are numerous registry options available, you’ll want to be sure you only consider registries that support the quality measure groups or individual measures that are applicable to your practice. Keep in mind that Vachette also offers additional guidance that can help you or your practice work through the numerous changes to value metrics. For the cost of a few specimens per month, we will ensure you do not lose any money during the transition from PQRS to MIPS. Contact our office at 517-486-4262 today so we can help you get...

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Republicans weighing AHCA amendment

Posted by on Apr 6, 2017 in Latest News | Comments Off on Republicans weighing AHCA amendment

Republicans weighing AHCA amendment

Throughout Donald Trump’s presidential campaign, promises were made and a clear line was drawn in the sand indicating that if he was elected the Affordable Care Act (ACA) would be repealed and replaced.  In March the GOP took its first swing during Trump’s presidency at replacing the ACA with the American Health Care Act (AHCA). Health care experts on both conservative and liberal sides of the political spectrum described this attempt at reform as a failure right out of the gate due its inability to lower deductibles, offer affordable and comprehensive coverage to the middle class and the potential changes it could bring to Medicaid. On Thursday, House Speaker Paul Ryan revealed an amendment to the AHCA that would establish a federal risk sharing program for insurers, an idea that has received support from both moderate and conservative Republicans. The revised act would aim to lower premiums and increase the total number of insurers who offer plans, which Republicans in turn hope would create a competitive marketplace with more choices for consumers. Currently, many consumers are left with limited choices in the marketplace after a recent exodus by many carriers. According to Ryan, the amendment maintains the ACA mandate to provide coverage to those with pre-existing conditions while also providing states with more options. The “high-risk sharing” pool would be used to reimburse insurers for covering patients with expensive conditions, which Republicans hope would in turn lead to lower premiums across the board. The pool would be administered by the federal government for three years before being handed over to the state level. Freedom Caucus members, Republicans of the most conservative and libertarian nature, were not convinced that the initial AHCA effectively abolished some of the more troublesome elements of the ACA. With Freedom Caucus members essentially voting against their party, it was decided that the AHCA would be withdrawn and no vote would take place. It will be interesting to see how those members respond to this latest proposal. Ryan said he believes the gap between his party’s two sides is narrowing, but that will remain speculation until the bill is actually voted on, let alone passed. After the AHCA vote was initially pulled, Ryan stated that the country is, “going to be living with Obamacare for the foreseeable future,” putting doubt in the minds of all citizens in regards to the GOP’s ability to craft a successful (and popular) replacement. Now, it’s looking like Republicans may be able to stop their infighting long enough to turn one of Trump’s early failures into a potential win. By Jake Hoogendoorn, Marketing...

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How to identify PQRS penalties

Posted by on Mar 13, 2017 in Latest News | Comments Off on How to identify PQRS penalties

How to identify PQRS penalties

Unlike other Medicare penalties, it’s not always apparent when a group is being penalized for PQRS. Do you know how to identify whether your group’s Medicare payments are being penalized because of prior poor performance under the Physician Quality Reporting System? You may assume identifying the 2 percent PQRS penalty is as simple as locating the PQRS remark code (N699) on your Medicare remittances and matching it up with a corresponding adjustment. Unfortunately, it’s a bit more complex than that. For whatever reason, CMS has elected to deduct the 2 percent penalty straight from your allowable amount, which means you won’t find a line adjustment that indicates your actual payment compared against the full allowable amount like you see with sequestration penalties. One biller we work with believed that since no adjustment was shown on the remittances, the PQRS remark code was simply a warning and not an indication of a reduction. Fortunately, we were able to use Medicare’s Fee Schedule Look-Up tool to show the payment the group received was actually 2 percent lower than the full allowable! So, other than understanding how the penalty was applied beforehand, what could the group and their biller have done to avoid this confusion? For starters, they could have paid attention when CMS informed them in the fourth quarter of 2016 that they had failed to satisfactorily report during the 2015 PQRS reporting period and would subsequently receive a 2 percent penalty on their 2017 Medicare payments (remember, PQRS penalties are applied two years after their corresponding performance year). However, we understand these communications can be missed, which is why we help our clients build reimbursement tracking or contract management reports that allow billers to quickly identify allowable amounts from various payers. By uploading your Medicare Fee Schedule, future payments you receive can be compared against your database to ensure you’re receiving your full payment. Remember, 2016 was the final PQRS performance year, which means 2018 will be the last time you could potentially see the 2 percent PQRS penalty. Unfortunately, penalties are only set to increase in subsequent years under the new Merit-based Incentive Payment System that combines PQRS with other quality and value reporting programs. This means those who have been ignoring quality reporting cannot afford to continue to do so. If you’re Medicare payments are down and your biller can’t explain why, or if you’re seeking an expert to assist you and your biller with new quality reporting requirements, call Vachette Pathology today at 517-486-4262 or visit us online at vachettepathology.com. We’d be happy to set up a free consultation with your group to outline exactly how we’ll ensure you avoid these penalties moving forward while also helping your practice locate money that has been slipping through the...

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Can your biller help you successfully navigate MIPS?

Posted by on Feb 23, 2017 in Latest News | Comments Off on Can your biller help you successfully navigate MIPS?

Can your biller help you successfully navigate MIPS?

With the inaugural reporting period for CMS’s new Merit-based Incentive Payment System now underway, you should be preparing a plan for how you’ll fulfill the program’s requirements, which can vary greatly depending on several factors ranging from the size of your practice to the number of patients you deal with directly each year. In recent years, many groups have relied on their billers to assist with reporting quality metrics required by the Physician Quality Reporting System. However, we’ve encountered numerous groups who have suffered Medicare penalties due to their biller’s failure to properly submit all the claims data required by PQRS. The reality is that although billers have good intentions, they often cannot keep up with the constant changes to these programs put forth by CMS. This has progressed to the point that many billers have now said they will either no longer assist with quality reporting or are charging additional fees to continue doing so. With that in mind, here are 22 items to consider as you prepare for MIPS: Are you confidant your biller truly understands the intricacies of the four MIPS performance categories: Quality, Practice Improvement, Advancing Care Information and Cost? Does your biller understand how those categories relate to the Physician Quality Reporting System (PQRS), Value Modifier (VM) and Electronic Health Record Meaningful Use (EHR MU) programs? Have you and your biller examined your Medicare payment history to determine whether or not you’re required to report under MIPS? Were you aware that CMS has dubbed 2017 as a “transition” year for MIPS? Have you and your biller had a conversation about what this entails, and what future years of the program could look like? Do you know whether you qualify for a MIPS exemption because of your hospital’s participation in a CMS-approved alternative payment model (APM)? Aware you aware of the potential benefits, as well as the risks, of participating in these various APMs? Have you received PQRS or Value Modifier penalties in the past? Was your biller able to explain why you came up short? If you did receive Medicare penalties under previous programs, did your biller offer to assist you with the appeal process? Was the appeal successful? Are you aware of whether you meet CMS’s designation as a non-patient facing clinician under MIPS? You should understand both the threshold for this designation and its potential impact on the categories you’ll be required to report on. Do you understand the differences between quality reporting under PQRS and the new Quality category of MIPS? How intimately does your biller understand the various quality measure groups of the Quality category? Can they help you determine which measures are applicable to your group, and how many you must report on to achieve your full score? Does your biller know the MIPS scoring thresholds that could open your group to receive additional Medicare bonuses beyond the maximum 4 percent initially offered for 2019? Has your biller determined whether or not your group will be required to report in the Advancing Care Information category? Do they understand how a category’s weight is redistributed if you receive an exemption? Have they discussed what Practice Improvement activities among the more than 90 available options would best suit your group. Have they supplied you with a plan for how to best...

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Understanding the benefits of registry reporting

Posted by on Feb 20, 2017 in Latest News | Comments Off on Understanding the benefits of registry reporting

Understanding the benefits of registry reporting

Understanding Registries With the first reporting period for the Merit-based Incentive Payment System now underway, you’re probably already spent some time considering how you’ll report your quality data (and if you haven’t, now’s the time to start)! Most groups fulfilled their PQRS requirements in the past by submitting data through the routine Medicare claims process, however, that process has become more burdensome in recent years and can leave you with uncertainties over whether you’ve reported all the applicable data required. What is a reporting registry? The registries referred to in this article were created to assist physicians in reporting quality data to CMS as part of the old Physician Quality Reporting System. Instead of placing the entire reporting burden on an individual group or practice, registries allow groups to submit their data to a third-party vendor that can scrub the submission to ensure it’s as accurate as possible before being sent off to CMS. This process aims to provide users with feedback that can help them fix their reporting processes during a submission period as opposed to waiting more than a year and a half for CMS to provide feedback on your data. Why use a registry? Working with a registry greatly reduces the burden on your billing and reporting staff. The registry staff can provide guidance with compiling necessary data. The registry can send in test submissions, which in turn allow them to minimize issues during the actual submission period. What’s the cost? Typically around $300 per physician. How are they approved by CMS? In order for an entity to be considered a qualified registry, the registry must successfully complete the self-nomination process and follow requirements outlined by CMS each year. Individual physicians or group practices who wish to report via registry should review the 2017 Qualified Registries once it is released this spring to find a registry that best meets the practice’s needs, since the vendor may only support specific measures or reporting options. (Click here to view the 2016 list of approved registries.) Who is able to report through a qualified registry? For the initial 2017 MIPS reporting year, both individuals and group practices can report through a qualified registry. Unlike past years, those wishing to report as a group will not need to complete the Group Practice Reporting Option registration in order to be recognized as a reporting group. Instead, those groups will now be able to self-nominate as a group through their registry. This is also the first year that groups will be prevented from submitting their quality data through the Medicare claims...

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Pathology Charges, Payments and Salary Trends in 2016 — White Paper

Posted by on Jan 14, 2017 in Latest News, White Papers | Comments Off on Pathology Charges, Payments and Salary Trends in 2016 — White Paper

Pathology Charges, Payments and Salary Trends in 2016 — White Paper

This white paper will look at pathology charges, payments and salary trends as of December 2016. I have done this review several times throughout the past 14 years of my career to shine a spotlight on the “real” compensation of pathologists. Our data comes from private practice pathologists, not from academic centers or salaried groups. We received assistance with the data collection process from several billing firms, including Physicians Professional Management Corporation of Lewiston, Maine; APS Medical Billing of Toledo, Ohio and several other sources. Many other billers were contacted with a request to help us gather data, however, they all declined. We also used data from more than 95 pathology practices in the 2016 Vachette Pathology database. In total, our study looked at the compensation of more than 550 pathologists in 2016. This study also examines Medical Director and Part A compensation, anatomic pathology billing and collections, clinical pathology billing and collections and independent laboratory billing and collections. Your Name (required) Your Email...

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Commercial insurers aim to lower lab reimbursements with pre-authorization programs

Posted by on Jan 12, 2017 in Latest News | Comments Off on Commercial insurers aim to lower lab reimbursements with pre-authorization programs

Commercial insurers aim to lower lab reimbursements with pre-authorization programs

Laboratory pre-authorization or “management” programs are controversial models that have gained prominence in recent years after being implemented in Florida by UnitedHealthcare in Oct. 2014 as part of a partnership with Beacon Laboratory Benefit Solutions (a subsidiary of LabCorp). The primary goal of these programs is to ensure health care providers within a particular state only use labs within a carrier’s “choice network” when ordering certain outpatient lab services for members of that network. Under these rules, the use of out-of-network labs is not permitted. These programs have been largely opposed by physicians in states where they’ve been put into effect, given that these doctors believe this practice causes unnecessary delays for patient treatment, and creates unnecessary obstacles for physicians ordering tests. Some doctors also believe these hurdles damage longstanding clinical relationships between physicians and their preferred labs. It also means that patients who may have been frequenting their doctor’s preferred labs now have to go to one of a handful of in-network labs. Receiving a “lab of choice” designation under these programs typically depends on meeting certain “quality” standards (e.g., CAP or TJC Accreditation, secondary pathology reviews or sub-specialty credentials) and “efficiency” standards. Under UHC’s program, standards include accepting UHC payments in the lowest quartile for the lab’s place of service classification (independent lab, outpatient hospital lab, or physician office lab). Since Beacon’s implementation in Florida, a couple commercial carriers in other states have followed suit and implemented their own authorization lab programs. Although they don’t all function in the exact same fashion, they each serve the purpose of funneling work to carriers’ preferred labs while alienating labs that choose not to play ball. Let’s take a quick look at some of the major players. Beacon Laboratory Benefit Solutions (LBS) Pre-authorization program first implemented as a pilot in Oct. 2014. Under the program, physicians serving UHC’s commercial patients in Florida must notify UHC when ordering any of 80 clinical laboratory tests, including ANA, C. difficile toxins, Pap test (with or without HPV), biopsies, and thyroid panel, among others. Pre-authorization is also required for some, but not all of these tests. The program has been largely opposed by Florida physicians, who believe it causes unnecessary delays for patient treatment, and create unnecessary obstacles for physicians ordering tests. An in-network lab that is not a “Lab of Choice” may be chosen by the ordering physician, but Beacon’s system creates barriers to this selection. The physician must navigate to another screen and will be presented alerts warning that “reimbursement may be impacted.” The program does not allow use of out-of-network laboratories. Payments are denied for any lab tests that don’t meet the Beacon requirements, however there is no penalty to referring physicians who do not comply with the program. UHC expects laboratories to enforce compliance by pressuring referring physicians to complete the notification process when required. Anecdotal evidence from Florida indicates referring physicians are frequently non-compliant, and that laboratories are simply not being paid for testing performed on UHC patients in those cases UHC is Florida’s second largest health insurer with approximately a 14 percent share of the market. Was originally slate to be implemented in Texas on March 1, 2017, however, pushback from various physician groups has delayed that implementation indefinitely. Avalon Healthcare Solutions Partnered with Blue Cross Blue Shield of South Carolina and Blue Choice...

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Examining the differences between PQRS and MIPS

Posted by on Jan 6, 2017 in Latest News | Comments Off on Examining the differences between PQRS and MIPS

Examining the differences between PQRS and MIPS

2017 is here, which means the inaugural reporting period for CMS’s new Merit-based Incentive Payment System (MIPS) is now in effect. You’ve probably heard that reporting quality measurements under MIPS will follow a format similar to what was required under the old Physician Quality Reporting System (PQRS), but may not be aware of the exact differences between the two programs. Fortunately, we’ve compiled a chart that can be used as a visual to quickly understand the major differences created by this transition. If you have any additional questions about the specifics of either program or want to know more about how you can successfully report quality measurements this year to avoid a Medicare penalty in 2019, feel free to contact us by calling 517-486-4262. We’ve assisted numerous groups throughout the nation by helping them create a game plan to succeed with MIPS reporting and would gladly discuss how we could do the same for your...

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Best practices for approaching payer audits

Posted by on Nov 3, 2016 in Latest News | Comments Off on Best practices for approaching payer audits

Best practices for approaching payer audits

As we continue to see an increasing number of payer audits in the pathology world, we wanted to take the time to walk you through some best practices and helpful tips for navigating these audits and protecting your revenue. It’s important to note that these audits will not be limited strictly to Medicare. Many managed care organizations have identified this as potential cost savings and now have their own internal audit teams or have hired third party auditors to validate your charges. Sometimes, these requests may not be directly addressed as an audit and may instead come in another form. It is imperative that you or your biller are on the lookout for these types of communication (or denials). Some auditors are finding 100% error rates – and may go back years to reprocess and take back payments already made to you. You must be vigilant in understanding your contract and the payer’s limitations on takebacks. We’ve seen clients successfully win money back because, under their contract, the payer could only recoup back “x” number of months or years. Unfortunately, many billers are still appealing these incorrectly because they are not communicating these denials and getting the coding department or doctors involved to write these appeals! Several of our groups that bill stains are having issues with limitations of units, medical necessity denials and back end audits.  The billers are often not staffed well enough to have a successful appeal process, which many of these carriers are banking on to begin with! These payers are looking for signed requisitions for IHC/special stains/molecular orders and/or documentation of medical necessity. Action steps for appeals: Include in the pathology report the trigger words:  “ X was ordered because…”. The auditors are most likely not pathologists, they usually just look for trigger words. When an audit request is received, it’s not enough to just send the final reports. Also, include an additional signed attestation by the pathologists that they ordered such and such stains/flow/ihc/molecular. Include a copy of relevant medical chart notes that makes it clear why the pathology specimen was ordered in the first place, i.e. surgeon’s note saying a colectomy was indicated due to presence of cancer or obstruction....

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