Q2 2021 Newsletter
Furlong Vision Correction:
Recipients of Furlong Vision Correction’s Gift of Sight Program talk about how it has changed their lives.
This month we’re highlighting the work of Furlong Vision Correction (FVC) in San Jose, California. In 2002, Dr. Michael Furlong started the Gift of Sight program. This charitable program chooses 10 deserving community members a year for vision correction. Treatments include comprehensive consultations, Advanced Topography-Guided Custom LASIK, Photorefractive Keratectomy (PRK) procedures, Keratoconus treatment and post-operative appointments at no cost.
FVC works with local non-profit organizations, other optometric partners and community members, all of whom can nominate potential recipients for consideration. Past recipients have included several U.S. military veterans, a single mother of two training to become an electrician, a local youth pastor who is a former police officer and father of three who gave up his career and became a missionary, and a Hodgkin’s Lymphoma survivor who is a mother of three.
PMRG is proud to have FVC as a client!
21st Century Cures Act and HIPAA Compliance
The 21st Century Cures Act, passed in December 2016, is designed to provide secure health information to patients and healthcare providers.On April 5, 2021, the Information Blocking Provisions take effect.
The 21st Century Cures Act defines information blocking as “the practice by a health IT developer of certified health IT, health information network, health information exchange, or health care provider that, except as required by law or specified by the Secretary of Health and Human Services (HHS) as a reasonable and necessary activity, is likely to interfere with access, exchange, or use of electronic health information (EHI)”.
The Office of the National Coordinator for Health Information Technology (ONC)has stated that an action would satisfy the information blocking provision’s “likelihood” requirement if there is a reasonably foreseeable risk that the action will interfere with access, exchange, or use of EHI.
In the final rule, ONC explained that a policy or action that limits timely access to information in an appropriate electronic format by limiting, disabling, or restricting the use or access to the EHI can be considered information blocking.
A practice might unknowingly block information from a patient.For example, a medical group that has the capability to provide a patient same-day access to their exam or office visit note but takes several days to provide it to the patient could be considered information blockers.Another example might be a medical group that has a policy that restricts access to patient lab results for a certain amount of time to permit review of the lab results by the provider.
Yes.The following are exceptions to the Information Blocking provision of the 21st Century Cures Act:
Exceptions that involve not fulfilling requests to access, exchange, or use EHI:
- Preventing Harm – protecting patients and other persons against unreasonable risks of harm can justify actions that are likely to interfere with access, exchange, or use of EHI.
- Privacy Exception – a medical group should not be required to use or disclose EHI in a way that is prohibited under state or federal privacy laws.
- Security Exception – safeguarding the confidentiality, integrity, and availability of EHI.
- Infeasibility Exception – legitimate practical challenges may limit a medical group’s ability to comply with requests for access, exchange, or use of EHI.
- Health IT Performance Exception – for health IT to perform properly and efficiently, it must be maintained, and in some instances improved, which may require that health IT be taken offline temporarily making EHI temporarily unavailable.
Exceptions that involve procedures for fulfilling requests to access, exchange or use EHI:
- Content and Manner Exception – provides clarity and flexibility to medical groups concerning the required contentof a response to a request to access, exchange, or use EHI and the manner in which the medical group may fulfill the request.
- Fees Exception – allows medical groups to charge fees related to the development of technologies and provision of services that enhance interoperability.
- Licensing Exception – allows medical groups to protect the value of their innovations and charge reasonable royalties to earn returns on the investments they have made to develop, maintain, and update those innovations.
Section 4004 of the Cures Act outlines that violation by healthcare providers will be referred to CMS if they have made a fraudulent attestation under the MIPS Promoting Interoperability Program or to the Office for Civil Rights if there is a potential HIPAA violation. The OIG will outline additional penalties for providers violating the information blocking rules.
- Designate an individual within the organization to be the point person for both information blocking policy development and for any issues that arise from patient requests for EHI.
- Review existing policies and procedures with regards to receiving, processing, and responding to requests to access, exchange, or use EHI and revise the policies as necessary.This process could also include creating standardized forms for receiving, processing, and responding to such requests and procedures specifying how access to EHI may be provided.
- Contact EHR and online web portal vendors to ensure compliance with information blocking requirements regarding patient access to EHI.
- Review your fee schedule for records requests.Provider offices should avoid charging patients—or their designated representatives—who request electronic access to their EHI through internet-based methods.
- Evaluate and review agreements the practice has with IT vendors, hospitals, or other entities to ensure they comply with the information blocking requirements.
- Establish a process to apply exceptions.
- Document any new policy developed to comply with the information blocking provision of the act.Retain this document for six years from the date of its creation or the date when it was last in effect, whichever is later.
- Train physicians, administrative and clinical staff on the importance of adhering to the practice’s information blocking policies.
Stay informed.The federal government is expected to announce additional information blocking policies in 2021.
Meet the PMRG Staff: Jana Holt
Jana Holt has just joined PMRG as a senior consultant and project manager. She brings a wealth of experience with her, and covers much of the service offerings that our founder Ron Rosenberg provided that we have been missing since he retired at the end of 2019. Jana has been in healthcare for 27 years, 21 of which were as a practice administrator. She has a depth of experience in general ophthalmology and retina and, most recently, was managing a busy retina practice in Arkansas. She is a certified professional coder (CPC) and a certified professional medical auditor (CPMA). Her expertise consists of evaluation of practices for efficient billing practices, medical code auditing and education for physicians and their staff, medical practice operations and finance, healthcare compliance, government healthcare regulations, and human resources and staff education.
When she’s not helping physicians find better and more efficient ways to run their practices, she loves all things outdoors – hiking, camping, kayaking, off-roading, snowmobiling and skiing. This love of the outdoors is what caused her and her husband of 22 years relocate to the mountains of Colorado from Northwest Arkansas. She is also the proud mother of 21-year-old son and 17-year-old daughter.
PMRG is fortunate to have someone of Jana’s professionalism and spirit join our team. If you haven’t heard from her, you will be soon!
Comprehensive Billing Report 202103
What is a CBR?
Comparative Billing Reports (CBRs) summarize Medicare claims data and distribute it to providers to provide insight into billing trends. Each CBR is unique to a single provider and is only available to that individual provider. CBRs are not punitive and will not be publicly available.
What is the purpose of a CBR?
These reports can help providers proactively assess any areas of increased risk and/or vulnerability and support efforts to ensure compliance with Medicare payment policy and/or accurate coding. Their purpose is to educate providers about vulnerable areas in the Medicare program and are meant to be a tool to encourage coding and billing guidance, education, and improvement activities.
What can your practice do if you received a CBR?
Ophthalmology Exam codes are vulnerable to improper payments typically because of insufficient documentation to support the eye exam code chosen. It is important to review the documentation in the note and choose the code carefully. A website has been established to assist providers who have received a CBR with information and resources to understand the report.
Recommended steps if you have received a CBR:
- Conduct an Internal or External audit of comprehensive eye codes to ensure you are not over-utilizing the code(s) and that the documentation in the chart supports the selected eye exam code.
- Address the CBR in your practice’s next scheduled compliance meeting. The minutes of the meeting should include the following information:
- Acknowledge receipt of CBR
- Recommend Internal or External Audit
- Conduct Audit
- Include audit results
- Outline plan to address audit findings (i.e. employee/physician education on comprehensive eye code coding criteria, next scheduled audit, more frequent audits for a period of time to ensure proper coding, etc.)
To learn more about how PMRG can help with conducting audits and offering feedback and education for physicians and staff in your practice, contact us using the information below.
Any requests for data
Questions related to client’s invoice