“Professional Component Payment Reductions for Diagnostic Imaging Examinations When More Than One Service Is Rendered by the Same Provider in the Same Session: An Analysis of Relevant Payment Policy” Journal of the American College of Radiology, September 2011

J Am Coll Radiol. 2011 Sep;8(9):610-6. Epub 2011 Jun 29.
Allen B Jr, Donovan WD, McGinty G, Barr RM, Silva E 3rd, Duszak R Jr, Kim AJ, Kassing P.
Source: Trinity Medical Center, Birmingham, Alabama 35213, USA. bibb@mac.com

Abstract
PURPOSE:
The aim of this study was to assess potential physician work efficiencies when more than one diagnostic imaging study is interpreted by the same provider during the same session.

METHODS:
Medicare Physician Fee Schedule data from the American Medical Association Resource-Based Relative Value Scale Data Manager for 2011 were analyzed to quantify relative contributions of preservice, intraservice, and postservice physician work to the total work of rendering diagnostic imaging services. An expert panel review identified potential duplications in preservice and postservice work when multiple examinations are performed on the same patient during the same session. Maximum potential percentage work duplication for various diagnostic imaging modalities was calculated and compared to US Government Accountability Office estimates.

RESULTS:
The relative contributions of preservice and postservice work to total work varied by modality, ranging from 20% [computed tomography (CT)] to 33% (ultrasound). The maximum percentage of potentially duplicated preservice and postservice activity ranged from 19% (nuclear medicine) to 24% (ultrasound). Maximum mean potentially duplicated work relative value units ranged from 0.0212 for radiography to 0.0953 for magnetic resonance imaging (MRI). Maximum percentage work reduction ranged from 4.32% for CT to 8.15% for ultrasound. This corresponds to maximum professional Physician Fee Schedule reductions of only 2.96% (CT) to 5.45% (ultrasound), approximating an order of magnitude less than the Government Accountability Office’s recommendations.

CONCLUSION:
Although potential efficiencies in physician work occur when multiple services are provided to the same patient during the same session, these are highly variable and considerably less than previously estimated.

Copyright © 2011 American College of Radiology. Published by Elsevier Inc. All rights reserved. PMID: 21719354

CMS Transfers Demand Letter Responsibility from RACs to MACs

By Doris Rodes, MD, CPC – Director of Auditing

The Centers for Medicare and Medicaid Services (CMS) recently announced that Medicare’s recovery audit contractors (RACs) will no longer issue demand letters to providers as of January 3, 2012.

CMS is transferring the responsibility to Medicare administrative contractors (MACs), who will perform the adjustments based on the RAC’s review and issue an automated demand letter. MACs will then be responsible for fielding any administrative concerns providers may have such as timeframes for payment recovery and the appeals process. However, MACs will include the name of the initiating RAC and his/her contact information in the related demand letter.

You will have to know how to appeal these adjustments. If you are a billing client of HCSWNY, contact our billing department for more information. If you are not a client but would like more information, contact HCSWNY at 716-206-1580, or dichristinae@hcswny.com, or you can go to CMS’ Web site.

Year End Planning for Taxes, Bonuses and Benefits

by Melissa Wagner, CPA – Director of Financial Operations at HCSWNY
It is time to plan for the year-end activities and situations that may affect your practice.

For any practice that is a cash basis taxpaying entity, you should be working with your bookkeeper and accountant to plan the best method of running down your cash balances. If you are one of our clients for management services, we will be providing your accountant with any information needed to facilitate your tax planning process.

As your tax preparer can further explain, the benefits to keeping your year-end cash balances low include: having more expenses paid this year to offset practice revenue and partner tax considerations (anyone who is going to be taxed on income should have the option of actually having that income in hand). Work with your accountant to see if you should be distributing additional payments to partners as those added draws need to be paid by the last payroll of the year. Also, consider paying January 2012 invoices before year-end to further pay down cash, and transfer expenses to the 2011 tax year.

In addition to tax planning, your practice should be working to ensure that all year-end staff bonuses are in the pipeline for processing in a timely fashion, and that all voluntary retirement contributions are communicated to your payroll and benefits administration vendors for processing prior to year-end.

Your human resource, accounting and payroll vendors should be able to provide you with maximum contribution tables for 401Ks, Simple IRAs, and Health Savings Accounts. If you are a management client of HCSWNY you will be receiving all applicable information by letter this week.

Remember that holidays can affect processing time for any requests, so be sure you know what days your vendors will be open to process your cash offsets, additional draws, invoice payments and retirement plans and contributions. The sooner you notify them, the more likely nothing will be missed by year-end.

If you have any questions and are not a current client, please contact 716-206-1580 or dichristinae@hcswny.com for more information or to see if we can make next year easier for you. If you are a current client, you may contact us directly as you have in the past.

Recovery Audit Contractors Looking at E & M Services

by Janine Wackowski, RHIA – HCSWNY Director of Coding

Earlier in October, the HHS OIG Work Plan for Fiscal Year 2012 was unveiled. As always, the work plan revealed many areas of focus for physicians. Specifically, the RAC auditors will be looking at your compliance with billing assignment rules, “Incident-To” services, surgical global periods and E & M services including E & M trends and E & M documentation.

FOR OUR NOVEMBER NEWSLETTER FOCUS, we want you to be aware of potentially inappropriate payments for E & M services as a result of what appears to be “cut and paste” type documentation. Specifically, it has been noted by Medicare that many providers have shown an increase in the frequency of medical records with identical documentation across services.

They plan to review E & M services to assess whether the providers selected the code for service based upon the content of the service and that they have the documentation to support the level of service reported. Be very careful about “cookie cutter” or “cut and paste” notes in EMR documentation. Medicare feels that while chief complaints, HPI and PFSH may differ in most notes, the ROS and exams look identical from patient to patient.

Often the ROS and exams make no mention of the chief complaint or findings that relate to the assessment or plan for the patient.

This is likely to trigger increased audits and demands for repayment.

We encourage anyone, whether a current or prospective client to contact us at 716-206-1580 or dichristinae@hcswny.com if you would like us to take a look at your EMR templates and/or random encounters to see if you are at any risk from this specific aspect of RAC auditing.

REMEMBER ALSO THAT THE NYS OFFICE OF THE MEDICAID INSPECTOR GENERAL IS ALSO LOOKING AT PHYSICIANS – this focus is on finding any practice providing Medicaid Services that does NOT have an “effective” compliance plan. Feel free to contact us for more detail on what constitutes effective compliance planning and actions.

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