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What pathologists can expect from the 2018 Medicare Physician Fee Schedule

Posted by on Jul 17, 2017 in Latest News | Comments Off on What pathologists can expect from the 2018 Medicare Physician Fee Schedule

What pathologists can expect from the 2018 Medicare Physician Fee Schedule

After significantly cutting the technical component for a number a key of pathology CPT codes last year, pathologists should be relieved to hear the vast majority of reimbursements levels are expected remain relatively unchanged next year, according to the proposed 2018 Medicare Physician Fee Schedule. The biggest hit will again impact the Global and Technical reimbursements for prostate biopsies (G0416). CMS is proposing to dock the Global rate by 11.5 percent and the Technical component by a whopping 18.7 percent, dropping their totals to $434.40 and $247.61, respectively. This comes as little surprise, as CMS has slashed payment for prostate biopsies throughout the past half-decade. The other most significant cut will be experienced by flow cytometry codes 88185-TC and 88189-26, with the technical side expected to be cut by 18.8 percent to $30.59 and the professional interpretation set to experience a 4.4 percent reduction to $88.54. Bad news aside, pathologists will be happy to hear all components of 88305 will receive a slight boost this year after seeing its technical and global component slashed by 15 percent and 7 percent, respectively, last year when compared to 2016 compensation rates. Professional interpretations for 88305 will jump 1.2 percent to $40.31, while Global and Technical reimbursement will both experience increases of less than 1 percent. Overall, CMS anticipates their proposed 2018 amendments will cut pathologists overall compensation rates by just 1 percent, while independent labs will see a 2 percent reduction. Keep in mind that the conversion factor for 2017 was $35.8887, while the proposed factor for 2018 is 35.9903. The overall update to payments under the PFS based on the proposed 2018 rates would be .31 percent. The update reflects the .5 percent annual increase established under the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015, reduced by -.19 percent due to the misvalued code target recapture amount, according to CMS. Check out the chart below for a breakdown of the major proposed changes for several key pathology codes. In the spirit of brevity, code sets expected to see cuts or boosts of less than 1 percent were not listed. CPT Code Service Proposed 2018 Current 2017 Change 88112 – Global Cytopath cell ehance tech $69.82 $68.91 1.3% 88112 – TC Cytopath cell ehance tech $40.31 $39.84 1.2% 88112 – 26 Cytopath cell ehance tech $29.51 $29.07 1.5% 88121 – Global Cytp urine 3-5 probes cmptr $536.26 $553.76 -3.2% 88121 – TC Cytp urine 3-5 probes cmptr $484.07 $501.72 -3.5% 88121 – 26 Cytp urine 3-5 probes cmptr $52.19 $52.04 0.3% 88184 – TC Flowcytometry/ 1st marker $61.18 $61.73 -0.9% 88185 – TC Flowcytometry/ additional marker $30.59 $37.68 -18.8% 88189 – 26 Flowcytometry/ read 16+ $88.54 $92.59 -4.4% 88305- Global Tissue exam by pathologist $70.18 $69.62 0.8% 88305 – TC Tissue exam by pathologist $29.87 $29.79 0.3% 88305 – 26 Tissue exam by pathologist $40.31 $39.84 1.2% 88307 – Global Level V, tissue exam by pathologist $268.49 $269.88 -0.5% 88307 – TC Level V, tissue exam by pathologist $180.67 $181.96 -0.7% 88307 – 26 Level V, tissue exam by pathologist $87.82 $87.93 -0.1% 88309 – Global Tissue exam by pathologist $407.41 $413.80 -1.5% 88309 – TC Tissue exam by pathologist $251.57 $258.40 -2.6% 88309 – 26 Tissue exam by pathologist $155.84 $155.40 0.3% 88312 – Global Special stains group...

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6 Highlights of the 2018 MIPS Proposed Rule

Posted by on Jul 13, 2017 in Latest News | Comments Off on 6 Highlights of the 2018 MIPS Proposed Rule

6 Highlights of the 2018 MIPS Proposed Rule

While many clinicians are still working to get a handle on the requirements for the Merit-based Incentive Payment System, they also need to keep an eye on how the program is expected to evolve next year now that CMS has released its 2018 Quality Payment Program Proposed Rule. However, those fearing the bar for penalty avoidance would be raised to unreasonable heights should breathe easy knowing CMS won’t require much more from you than what they asked for in 2017. With that in mind, here are six of the most significant changes:   1)    Significant increase of the low-volume thresholds CMS has proposed to raise the low-volume MIPS exemption thresholds to $90,000 in annual Medicare payments or services to 200 or fewer Medicare beneficiaries, a significant increase from the $30,000 or 100 patient thresholds for 2017. Falling below either one of these thresholds as an individual clinician will exempt you from participation, which means those who were barely over this year’s mark will most likely be exempt from the program next year. Keep in mind, however, that the increased threshold is also applied at the group level if your group elects to report collectively.   2)    No requirements for the “Cost” category While participants had originally been told to anticipate the introduction of a “Cost” category based on the old value modifier in 2018, CMS is now proposing to again give no weight to the fourth MIPS category next year. That being said, the agency is still soliciting feedback on whether Cost should be weighted at 10 percent of the total MIPS score for 2018, given that CMS still intends to count it as 30 percent of a participant’s score in 2019. Regardless, CMS says it intends to track Cost progress in 2018 based on Medicare Spending per Beneficiary and total per capita cost measures. They’re also working to develop a handful of episode-based cost measures.   3)    Slight threshold increase for penalty avoidance Clinicians who were happy with the extremely low bar set by CMS this year to avoid a Medicare penalty in the 2019 payment year should find relief in learning they won’t be asked to do much more next year to avoid a 2020 penalty. While the 2017 performance threshold of 3 (the total MIPS score required to receive a neutral adjustment) was able to be achieved by essentially submitting any quality data or completing at least one improvement activity, the 2018 threshold will be raised to just 15 points. This can be achieved in a variety of ways, including by submitting complete data for just two quality measurements or completing the full requirements of the improvement activities category. Non-patient facing clinicians, hospital-based groups and groups consisting of 15 or fewer members will still only be required to complete either one high-weighted or two medium-weighted activities to get the full score.   4)   Automatic bonuses for small and rural practices Given the reporting hurdles faced by small (15 clinicians or fewer) and rural practices, CMS is proposing to award an automatic five points to these clinicians scores next year. This is likely to be locked in for small practices, however, CMS is still seeking comment on whether rural practices should receive the same benefit.   5)    New facility-based scoring mechanism No concessions for facility-based clinicians was...

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How do you view the pathology recruitment market? (Survey)

Posted by on Jun 26, 2017 in Latest News | Comments Off on How do you view the pathology recruitment market? (Survey)

How do you view the pathology recruitment market? (Survey)

How do you view the current state of the pathology recruitment market? What kind of future do you see for the practice of pathology in the Unites States moving forward? We’re seeking pathologists to help answer these questions and more as part of a survey that will be discussed during a group panel at the upcoming Association of Pathology Chairs Annual Meeting, July 25-28 at in Washington, D.C. Vachette President Mick Raich will participate in the panel, which will seek to assess the current state of pathology in the U.S. by discussing current reimbursement levels, workload and more. The full survey can be viewed here. There are a total of 12 questions, and any answers you choose to provide will remain completely anonymous. Your participation is greatly...

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Salary Study Update: Michigan Pathologists in 2017

Posted by on Jun 13, 2017 in Latest News | Comments Off on Salary Study Update: Michigan Pathologists in 2017

Salary Study Update: Michigan Pathologists in 2017

Earlier this year, we published a white paper that included breakouts in all of the major financial categories for pathologists across the nation based on our client data. We’ve since decided to crunch the numbers a bit further to provide an idea of what the average salary is for a pathologist in Michigan. MORE: Click here to download our pathology compensation study. Vachette manages more than $43 million in annual revenue generated by 82 pathologists throughout the state of Michigan. The average salary that we see in Michigan based on our client data is $531,000 per pathologist. However, you should understand this average was drawn from several different groups operating under varying fee schedules, which may partly explain why you fall below that total. If you are curious as to what Vachette can do to specifically increase your revenue, perhaps now is the time for us to talk. With PAMA cuts expected to reduce current CMS compensation rates by as much as 10 percent in each of the next three years (and that’s not including potential Merit-based Incentive Payment System penalties that will grow in the coming years), ensuring that your revenue cycle management is up to snuff is more important than ever. By auditing processes quarterly and keeping up on industry changes, we keep our clients ahead of the game financially, all while helping them avoid breakdowns in their billing processes. We have been working with hospitals, laboratories, and hospital-based groups for more than 15 years and would love to serve you as well. If you’re interested in learning more about how Vachette can help you generate more revenue, or simply want more info on our audit process, feel free to contact us directly at...

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Missed appeals, MUE denials and more in Vachette’s latest audit roundup

Posted by on May 31, 2017 in Latest News | Comments Off on Missed appeals, MUE denials and more in Vachette’s latest audit roundup

Missed appeals, MUE denials and more in Vachette’s latest audit roundup

As we’ve continued to add new clients in 2017, Vachette’s audit team has been hard at work uncovering and correcting a host of billing and compliance issues in an effort to put missing revenue back in our group’s pockets. As always, failure to properly appeal various denials has continued to be an issue we see with alarming regularity. We’ve also identified a host of issues tied to outdated fee schedules, missing contracts and other often overlooked problems that prevent groups from maximizing their revenue. If you’re interested in learning more about any of our findings or our audit process in general, feel free to contact us directly at 517-486-4262. For updates on our latest finds, follow us on Facebook, Twitter and LinkedIn or visit our website, www.vachettepathology.com. Below are Vachette’s top auditing findings so far in 2017:   Ignoring too many appeals — January 4, 2017 Too often, billers let appeals slip between the cracks and voluntarily write off a large source of potential revenue in the process. Case in point: This week, our team discovered that 16 percent of the cases we reviewed for our client during a billing audit were lacking appeals. Even if you assume only a third of the appeals would be successful, we still projected our client could have lost $775,000 in revenue for the year if the error rate held constant!   Maximizing your fee schedule — January 11, 2017 We cannot stress enough how important it is to ensure your fee schedule is set at a level that maximizes the reimbursements you receive from various insurance carriers. During a recent billing audit, we noticed our client’s fee schedule for 85060 was just $40, a figure that was significantly lower than the amount four different carriers were willing to pay for the service! This is lost revenue!   Missing documentation leads to MUE denials — January 18, 2017 Ensuring your reports are properly documented is crucial, especially as MUE denials become increasingly prevalent. We recently had a client whose biller submitted a claim to Medicare with eight 88361 units and filed an appeal in the report since the MUE for the code is six. Although Medicare acknowledged eight stains were performed, they still denied the claim because the report lacked documentation stating 88361 is computer assisted. We’ve since helped our client install a process to ensure the proper documentation for these cases will be included on all future cases moving forward. Missing codes lead to denials — January 25, 2017 As insurers become increasingly diligent with its denials, groups must be more cautious than ever when it comes to ensuring claims are properly coded. During a recent billing audit, we discovered 4 percent of the cases reviewed showed Medicaid secondary insurance was denied because the taxonomy code in box 33B on the claim form was missing, causing the claims to be denied as NPI not matched. Unfortunately, our client’s biller adjusted the balance off the system and did not refile when the issue was corrected, which left potential revenue on the table   Failure to appeal costs client big time — January 31, 2017 $227,000 — That’s the amount we projected our client could have lost over the course of a year after we discovered their biller was not submitting appeals on cases...

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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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