9.2.10 – Initial EHR Certification Bodies Named NEW
Key step in national initiative toward adoption of electronic health records
The Certification Commission for Health Information Technology (CCHIT), Chicago, Ill. and the Drummond Group Inc. (DGI), Austin, Texas, were named today by the Office of the National Coordinator for Health Information Technology (ONC) as the first technology review bodies that have been authorized to test and certify electronic health record (EHR) systems for compliance with the standards and certification criteria that were issued by the U.S. Department of Health and Human Services earlier this year.
Announcement of these ONC-Authorized Testing and Certification Bodies (ONC-ATCBs) means that EHR vendors can now begin to have their products certified as meeting criteria to support meaningful use, a key step in the national initiative to encourage adoption and effective use of EHRs by America’s health care providers.
“Less than two months following the issuance of final meaningful use rules, we have approved our initial ONC-ATCB certifiers. EHR vendors can begin immediately to get their products certified.” said David Blumenthal, M.D., national coordinator for Health Information Technology. This is a crucial step because it ensures that certified EHR products will be available to support the achievement of the required meaningful use objectives, that these products will be aligned with one another on key standards, and that doctors and hospitals can invest with confidence in these certified systems.”
Applications for additional ONC-ATCBs are also under review.
Certification of EHRs is part of a broad initiative undertaken by Congress and President Obama under the Health Information Technology for Economic and Clinical Health (HITECH) Act, which was part of the American Recovery and Reinvestment Act (ARRA) of 2009. HITECH created new incentive payment programs to help health providers as they transition from paper-based medical records to EHRs. Incentive payments totaling as much as $27 billion may be made under the program. Individual physicians and other eligible professionals can receive up to $44,000 through Medicare and almost $64,000 through Medicaid. Hospitals can receive millions.
To qualify for the incentive payments, providers must not only adopt, but also demonstrate meaningful use of, certified EHR systems. The law envisions that defined meaningful use requirements will help ensure that the patient and provider benefits of EHRs are realized. Initial meaningful use criteria were defined in a final rule issued by the Centers for Medicare & Medicaid Services (CMS) on July 28.
In addition to the CMS rule, ONC also issued standards and certification criteria for EHRs on July 28, aimed at ensuring that EHR systems will support the specific tasks required under meaningful use. Also, through regulations issued on June 24, ONC created a system by which technology review organizations could also qualify as ONC- ATCBs that will certify EHR products as meeting the requirements necessary for meaningful use.
With the initial two ONC-ATCBs now named, EHR vendors can apply to them for certification of their products. By purchasing certified products, providers will have assurance that the products will support achievement of the meaningful use objectives.
“Multiple steps are underway to carry out the intent of Congress in supporting rapid and effective adoption of EHRs throughout our health care system,” Dr. Blumenthal said. “The naming of initial ONC-ATCBs is one important step. Actual certification of multiple vendors’ systems by the ONC-ATCBs is an important next step. CMS is also working to create an online system for providers to register and attest for the EHR incentive programs. The first incentive payments are targeted to be made in May 2011. Meanwhile, ONC is also carrying out new programs of technical assistance and training, especially for smaller hospitals and physician practices.”
Dr. Blumenthal said the Health IT initiative “is on an aggressive schedule to meet the urgent targets set by Congress and the President toward realizing the quality and safety improvements that we can achieve through health information technology.”
To learn more about the ONC-ATCBs named today visit www.cchit.org and www.drummondgroup.com.
For more information about the ONC certification programs visit http://healthit.hhs.gov/certification.
For more information about other HHS Recovery Act Health Information Technology funding and programs, visit http://www.hhs.gov/recovery/programs/index.html#Health.
Source: http://www.hhs.gov/news/press/2010pres/08/20100830d.html
8.13.10 – CMS: Anticipate RAC Medical Necessity Reviews Within Two Weeks
As reported in the Aug. 10 AHA News Now Daily Report, the Centers for Medicare & Medicaid Services’ (CMS) New Issue Review Board has approved the first “medical necessity review” audits for Medicare’s permanent Recovery Audit Contractor (RAC) program, allowing contractors to begin posting items of interest to their respective websites.
The report indicates that the recently approved audits include 18 types of inpatient hospital claims and one type of durable medical equipment claim. The report did not announce specific issues or indicate which of the four RAC contractors were approved, but CMS did state that the new audit issues would be posted on the RAC Web sites, adding that contractors would begin to issue ADRs (Additional Documentation Requests) within the next two weeks.
Read more here.
Source: MHA News Now
3.23.10 – Connolly Posts 30 DRG Validation Issues
More High Volume, High Dollar Value DRGs
Written by Ernie De Los Santos
The Region C RAC, Connolly Healthcare, posted 25 new DRG Validation Issues to their list of CMS-Approved audit issues, on Tuesday, March 16 plus another five (5) on Friday, March 19. Once again, Connolly has been approved for even more MS-DRGs with high Relative Weights (which equates to high dollar reimbursements) and high discharge volumes (which equates to large number of claims to potentially audit).
Four (4) of the newly approved issues are for MSDRGs with Relative Weights of better than 5.0. Also, seven (7) of the 25 new issues are ranked (by number of discharges in FY09) in the top 100 DRGs nationwide. Connolly and the rest of the RACs are not allowed to choose their audit issues simply by virtue of a high reimbursement value, nor can they choose them by random selection. The RAC Statement of Work (SOW) is clear on this issue: the RAC must garner approval from CMS before they can begin widespread review of an issue. To earn that approval, they must present compelling evidence to CMS that suggests improper payments have been made, and that audits of those issues might return significant dollars to Medicare.
Nevertheless, this latest round of approval/postings seems to continue a pattern previously noted in Connolly’s February postings, and reported here on RAC Monitor and on Medical Coding Journal. Such approvals might suggest that Connolly is certainly able to gather sufficient evidence to pursue fairly large volumes of claims, as well as many of the highest paying DRGs.
If the rationale listed by Connolly in a recent Additional Documentation Request Letter (ADR) sent to a Georgia hospital is any indication, it would appear that Connolly has been able to make good use of evidence gathered during the RAC Demonstration. See a copy of the letter and our analysis of it here.
Virginia and West Virginia are still noteably absent from the list of states where Connolly is approved to review these issues. The 13 states affected by the new approved issues are: Alabama, Arkansas, Colorado, Florida, Georgia, Louisiana, Mississippi, New Mexico, North Carolina, Oklahoma, South Carolina, Tennessee, Texas.
2.12.10 – CMS: Only physician fee schedule services require advanced imaging accreditation
The Centers for Medicare & Medicaid Services (CMS) recently confirmed hospitals that they do not have to become accredited to furnish the technical component of advanced diagnostic imaging services. Some hospitals began to query CMS about the issue after the agency published a January 26, 2010 notice approving three organizations to accredit suppliers of the technical component of advanced diagnostic imaging services under the Medicare physician fee schedule. The Medicare Improvements for Patients and Providers Act of 2008 requires these suppliers to become accredited by a designated accreditation organization by Jan. 1, 2012. The requirement does not apply to advanced imaging services paid under Medicare’s hospital inpatient and outpatient prospective payment systems.
1.15.10 – CMS releases proposed HIT ‘meaningful use’ definition
On December 30, 2009, the Centers for Medicare & Medicaid Services (CMS) published the proposed rule defining “meaningful use” of electronic health records (EHRs), while the Office of the National Coordinator for Health Information Technology (ONHIT) issued an interim final rule that sets standards, specifications and certification criteria for EHR technology. Together, these rules set EHR adoption requirements that hospitals and physicians must meet under the American Recovery and Reinvestment Act to qualify for additional Medicare and Medicaid payments beginning in 2011 and to avoid significant payment penalties in 2015.
According to the proposed federal rules for “meaningful use” of EHRs and, in order to be eligible for federal Medicare or Medicaid bonus payments beginning in 2011, at least five rules for clinical decision support (CDS) should be implemented, in addition to keep up-to-date problem lists, write electronic prescriptions, have electronic drug interaction checking, incorporate data from test results into their electronic health records and keep patient vitals.
The updated rules contain several differences from earlier plans:
- Physician practices will only have to enter 80 percent of orders electronically, down from the 100 percent called for in recommendations issued last summer;
- The threshold for hospital use of computerized physician order entry is just 10 percent;
- For 2011 and 2012, hospitals would not have to be able to transmit orders electronically to pharmacies, labs or imaging centers; and
- Physicians will not have to record progress notes in the EHR.
ONCHIT’s interim final rule will take effect 30 days after publication in the Federal Register. More information is available at: HHS press release, CMS proposed rule on meaningful use of EHRs and the ONC interim final rule on standards and certification.
1.8.10 – Joint Commission seeks comments on proposed medical staff standard
The Joint Commission will accept comments through Jan. 28 on proposed revisions to its standard for effective working relationships between medical staff and hospital leadership. The proposed standard (MS 01.01.01) was crafted by a task force convened in January 2008 to mitigate concerns about the existing standard. The Joint Commission Board suspended a previous revision to the standard (MS 1.20), which drew criticism from hospitals and physicians concerned about the potential for substantial unintended consequences.
The Proposed Draft for Standard MS.01.01.01 (formerly MS.1.20) is available at the Joint Commission/Standards section at: www.jointcommission.org/Standards/FieldReviews/ms_01_01_01_comment.htm
12.31.09 – Holding of Claims for Services Paid Under The 2010 Medicare Physician Fee Schedule
On December 23, 2009, the President has signed the Department of Defense Appropriations Act of 2010 which provides for a zero percent (0%) update to the 2010 Medicare Physician Fee Schedule for a two month period, January 1, 2010 through February 28, 2010.
In this regard, the Centers for Medicare & Medicaid Services CMS has instructed its contractors to hold claims for services paid under the Medicare Physician Fee Schedule (MPFS) for up to the first 10 business days of January (January 1 through January 15) for 2010 dates of service. This should have minimum impact on provider cash flow because, by law, clean electronic claims are not paid any sooner than 14 calendar days (29 days for paper claims) after the date of receipt. Meanwhile, all claims for services delivered on or before December 31, 2009, will be processed and paid under normal procedures.
The holding of claims allows Medicare contractors time to receive the new, updated payment files and perform necessary testing before paying claims at the new rates. CMS has instructed contractors to begin processing claims at the new rates no later than January 19, 2010. Therefore, even absent a new update, most claims likely would not have been paid any sooner than January 19, 2010, given the aforementioned statutory 14-day payment floor.
12.24.09 – CMS Medicaid Integrity Contractor Audits
The Centers for Medicare and Medicaid Services (CMS) continue intensifying its pursuit of fraud, abuse and waste in federal healthcare programs. The Recovery Audit Contractor (RAC) audits focus on Medicare Parts A&B claims. Simultaneously with the RAC audits exists the Medicaid Integrity Contractors (MICs).
The Medicaid Integrity Contractors (MICs) are organizations contracted by CMS with the responsibility of auditing individuals and organizations providing Medicaid services. The overall goal of the provider audits is to identify overpayments and to ultimately decrease the payment of inappropriate Medicaid claims. These contractors are firms CMS has chosen to carry out education, review and audit with the following Medicaid Integrity Program goals:
- Education MICs are responsible for educating providers, beneficiaries, and others on program integrity and quality of care issues.
- Review MICs analyze Medicaid providers’ claims data for evidence of atypical billing practices that could result in overpayments.
- Audit MICs conduct post-payment audits of Medicaid providers. The Audit MICs determine which providers to audit in part based on leads received from CMS, state agencies, or the Review MICs.
CMS has divided the country into five MIC jurisdictions, each of which encompasses two CMS regions. Contracts for Education MICs, Review MICs, and Audit MICs are awarded separately for each of the five MIC jurisdictions. The Audit MICs have commenced audits of Medicaid providers in most jurisdictions, and audits are anticipated to begin in the remaining jurisdictions by June 2010.
The audit process
All Medicaid providers are subject to MIC audits. Although Audit MICs, unlike RACs, are not paid on a contingency fee basis, Audit MICs are eligible for financial bonuses based on the effectiveness of their audits.
Review MICs perform post-payment reviews of Medicaid claims and then recommend selected providers to be audited by the Audit MICs. CMS is responsible for ensuring that investigations or other audits of these providers for similar Medicaid issues are not already underway by state Medicaid agencies, state or federal law enforcement, or Medicare contractors. Audit MICs can review
Medicaid claims as far back as permitted under the laws of the respective states that have paid the claims.
RACs vs. MICs
MICs have been termed “RACs for Medicaid,” but there are certainly differences between the programs. For example, the RAC lookback period is three years, but MICs base the length of time on individual state lookback guidelines. Similarly, the number of days a provider has to produce medical record copies for MICs is dependant on state rules, unlike with RACs, where providers have 45 days regardless of their location. In addition, MICs have no set medical request limits, while RACs max out at 200. Also, CMS will not reimburse providers for the cost of copying records, which is also different from the RAC program.
Unlike RACs, MICs are not paid by contingency fee, but rather through a sort of fee-for-service model. The dollars MICs recover aren’t tied to their compensation, according to CMS, although they will be eligible for bonuses based on how “effective and efficient” they are. In some cases MICs will do desk audits, and in other instances, auditors will come on-site to do the reviews.
12.18.09 – AHA applauds proposed Medicare Advantage rule change
On December 8, 2009, the AHA published an article supporting the Centers for Medicare & Medicaid Services’ proposal to exempt hospitals and other health care entities that participate in the traditional Medicare program from separate compliance training requirements under the Medicare Advantage program, the association said in a comment letter today. More information is available on CMS website.
12.11.09 – Hospitals call for incentive definitions that promote EHR adoption
On December 4, 2009 the American Hospital Association published that forty-three hospitals and health systems today urged federal officials to define “hospital” and “hospital-based physician,” as outlined in the HITECH Act, in a way that makes health information technology available to the greatest number of hospitals and physicians. In a letter to the White House Office of Health Reform, Department of Health & Human Services and Centers for Medicare & Medicaid Services, the group recommends defining a hospital “as a discrete site of service, so that individual sites of multi-campus facilities are eligible to qualify separately for the incentives.” Noting that the American Recovery and Reinvestment Act’s HITECH Act provisions define hospital-based physicians as those who furnish substantially all of their services in a hospital setting using the hospital’s facilities and equipment, the letter adds, “We are concerned that broad regulatory interpretation of this hospital-based physician definition may inappropriately exclude physicians practicing in outpatient centers and provider-based clinics merely because their office or clinic is located in a facility owned by the hospital.”
