Category: Blog

ARE YOU COMPLIANT WHEN PROVIDING TRANSITIONAL CARE MANAGEMENT SERVICES?

ARE YOU COMPLIANT WHEN PROVIDING TRANSITIONAL CARE MANAGEMENT SERVICES?

May 3, 2023

Transitional care management (TCM) services are intended to help a patient transition, upon discharge, from an inpatient setting back to their home setting.  Here are several areas you will want to look into for proper coding, documentation, and billing guideline use:

Who are the eligible providers that can perform TCM services?
Who can perform the non-face-to-face vs. face-to-face portion of the TCM service?
What types of locations are approved for post-discharge TCM services?

Risk Adjustment Data Submission Deadline Approaching

Risk Adjustment Data Submission Deadline Approaching

May 8, 2023

HPMS released a memo with the upcoming deadlines for Medicare Advantage Organizations, etc. to submit their risk adjustment data to calculate risk scores for Payment Years 2022, 2023, 2024, and 2025.  Data must be submitted by 8pm on the day of the deadline to be counted in the current run.  Submissions after 8pm will be included in the mid-year or final reconciliation run, based on deadline date.  See the table below and review the HPMS site for more details.

Preparing for the end of the Public Health Emergency (PHE)

Preparing for the end of the Public Health Emergency (PHE)

April 17, 2023

The Public Health Service Act, initiating the public health emergency (PHE), was declared on January 31, 2020.  It has been renewed 13 times since then.  The PHE was put into place in response to the COVID-19 pandemic.  Several temporary waivers and flexibilities have been implemented by state and federal governments in response to the challenges faced throughout the nation.  On January 30, 2023, President Joe Biden announced that the PHE will end on May 11, 2023.  The end of the PHE signals the termination of the temporary waivers/flexibilities that were implemented throughout the pandemic (there are a few flexibilities that will extend past May 11, 2023).  Healthcare organizations will need to re-examine their current policies, procedures, processes, workflows, etc. in preparation to transition back to “normal” operations.

CMS Proposed Rule for Inpatient & long-term care Hospitals

CMS Proposed Rule for Inpatient & long-term care Hospitals

April 11, 2023

On April 10, 2023, CMS released a proposed rule that will impact inpatient and long-term care hospitals (LTCH).   The proposed rule recognizes homelessness as a Social Determinant of Health (SDOH), looks to increase equity & safety, and reduce preventable harm.  For FY 2024, acute care hospitals who meet the requirements could see an increase in payments of 2.8% ($3.3B).  LTCHs will also see an increase in the payment rate by 2.9%, however this will be an overall “decrease by 0.9% ($24M), primarily due to a projected decrease in high-cost outlier payments in FY 2024 compared to FY 2023.” (CMS Press release https://www.cms.gov/newsroom/press-releases/cms-proposes-policies-improve-patient-safety-and-promote-health-equity?utm_source=newsletter&utm_medium=email&utm_campaign=name_ocr_cms_updates_auditing_for_compliance&utm_term=2023-04-11)

Advanced Beneficiary Form (ABN) will expire on June 30, 2023

Advanced Beneficiary Form (ABN) will expire on June 30, 2023

April 11, 2023

On April 4, 2023 CMS announced that the current Advanced Beneficiary Form (ABN) will expire on June 30, 2023.  The updated ABN will go into effect on June 30, 2023 and expire on January 31, 2026.

The ABN is used by providers who know that a service is not covered or will be denied by the Medicare fee-for-service (FFS) program.  Prior to providing the service, an ABN must be offered to the patient, so that they can decide whether or not to have the service and be financially responsible for the service.  The ABN will list the service, the reason the service is not covered by Medicare, and an estimate of how much the patient can expect to pay.  The patient will choose one of three options listed below and then sign and date the form:

CMS: COVID-19 Related Exercise of Enforcement Discretion Ending May 11, 2023

CMS: COVID-19 Related Exercise of Enforcement Discretion Ending May 11, 2023

March 24, 2023

CMS issued notice on March 24, 2023 to Medicare Advantage Organizations, Part D Plan Sponsors, and Medicare-Medicaid Plans that the temporary enforcement discretion policy would end when the PHE ends on May 11, 2023.  This means the flexibilities these organizations implemented during the COVID-19 PHE will end and they will need to follow current statutory and regulatory requirements. 

Top 10 Best and Worst States for Physicians

Top 10 Best and Worst States for Physicians

March 21, 2023

HealthExec’s March 20, 2023 article listed the top 10 best & worst states for physicians. This ranking was based on research conducted by WalletHub who compare the 50 states and the District of Columbia across 19 key metrics, including salary, number of hospitals in the per capita area, and quality.

Former Naval Officer Sentenced to Prison for Fraudulent Durable Medical Equipment Claims

Former Naval Officer Sentenced to Prison for Fraudulent Durable Medical Equipment Claims

March 17, 2023

Former Naval officer, Jordan Thomas Broome, has been sentenced to 66 months in prison for submitting fraudulent Durable Medical Equipment (DME) claims of over $2.15M.  Aided by other bad actors (providers who would “robo-sign” prescriptions for DME equipment for patients never seen), Broome illegally obtained over 2,000 Medicare beneficiaries’ personal information and mailed them DME equipment which they never asked for, nor needed.  Read the full Press Release.

Pfizer’s Copay Assistance Program considered an inducement of Medicare beneficiaries

Pfizer’s Copay Assistance Program considered an inducement of Medicare beneficiaries

March 14, 2023

The Supreme Court of the United States (SCOTUS) denied Pfizer’s petition to review the Second Circuit’s Court of Appeals ruling that found Pfizer in violation of the anti-kickback statute.  Two of Pfizer’s cardiac medications have a patient out-of-pocket cost of more than $1,000 per month. 

CMS Posted Their Updated PHE Fact Sheet on February 27th

CMS Posted Their Updated PHE Fact Sheet on February 27th

March o2, 2023 With the Public Health Emergency (PHE) expiring on May 11, 2023, CMS updated their CMS PHE Fact Sheet on February 27, 2023. This fact sheet covers the following: COVID-19 vaccines, testing, and treatments; Telehealth services; Health Care Access: Continuing flexibilities for health care professionals; and Inpatient Hospital Care at Home: Expanded hospital […]

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