How will 2013 change your practice?

Many changes either taking effect in 2013 or requiring preparation in 2013 for implementation in 2014 can have a huge financial impact on the health of your practice. Are you ready? This is the time to take stock of the resources you already have and those which you will need to consider.

Medicaid Reimbursement

With a new influx of lives being added to the Medicaid pool of patients, many PCP and Internists are going to see a large increase of new patients. So in order to compensate physicians for the new workload, fees for evaluation and management services as well as immunization services will be increased to 100% of Medicare allowables for 2013 and 2014.

Supply and Demand

With more patients being added to our system, due to the individual mandate and the increase of Medicaid qualified individuals, some physicians will see a heavier load of patients in their practice. Adding the fact that many of these patients are new to the system and therefore will require more work, practices need to have a plan in place as to how they will be adapting.

OIG 2013 Work Plan

The OIG will be taking a close look at claims from 2002 to 2011 billed with G modifiers (GA, GY, GX and GZ) to determine erroneous payments issued to physicians. These modifiers are used by practice when submitting claims to Medicare, indicating that a denial is expected for these services. However, in a review performed by the OIG, they found that a significant amount of claims submitted with these modifiers were paid in error. There is potentially $4 million of erroneous payments.

ICD-10

What was to be an effective date of October 1, 2013 has now been extended to October 1, 2014. However, practices will need start preparing for the changes soon or at least have an implementation plan in place. Many practices will wait until the last minute to start the planning and preparation because the deadline may once again be extended. However, with the complexity of the new coding system, there are certain areas that your practice may want to consider preparing, to aid in a smoother transition.

So what do these four issues have in common? They all have a potential to impact your practice financially. Too often medical practices choose to ignore changes to the until it is too late. The time to prepare your practice is now.


Proposed Rule Could Mean Trouble For Medical Practices


On February 16th, 2012 CMS posted on the Federal Registry a proposed rule that would extend the period they have to review any possible overpayments to 10 years. This new rule would implement a provision of the Affordable Care Act that is focused on identifying fraudulent activity. The current period is usually about 4 years. Extending it another 6 years could equate to huge trouble for providers.

FRAUD VS. BILLING ERROR

This new proposed rule is an attempt to enforce the False Claims Act. However, when looking back 10 years, practice management technology has changed drastically when compared to systems used widely today. Billing errors due to lack of “smart” PMs would have been a common occurrence, therefore, is it fair to go back 10 years when resources such as claims edit and claims scrubbing software were not so easily accessible to providers and their practices? Many of the claims found to be fraudulent under this new proposed rule could simply have been honest billing errors vs. an attempt to defraud CMS.

RECORD KEEPING

With this new rule, providers will be given a deadline to report and refund any overpayments which they themselves have identified. Ignoring this deadline will result in a large fine placed upon the provider. This now brings up another issue. Under Florida Law, providers need to keep a patient’s medical record for at least 5 years, but that’s it. There are some that will have these records for longer, however, when the law dictates that these should be keep for at least 5 years, how fair is this proposed rule going to be, when it’s asking for overpayments to be refunded on claims which are up to 10 years old? Additionally, with providers changing PMs frequently, it’s going to be very rare to find a practice that has had the same PM for 10 years straight.

The False Claims Act is supposed to be used to identify fraud not billing errors. With this new proposed rule, the chips are all stacked against the providers. They will not have the chance to dispute any of these supposed overpayments because most of the information is no longer accessible to them. If it passes it will be a financial disaster on small to medium sized practices whose biggest payor is Medicare. These practices will not have the financial means to be proactive in ensuring that these overpayments are disputed in time to avoid a financial penalty.