Posts Tagged management

What Are Some Common Challenges and Solutions for Medical Practices?

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What Are Some Common Challenges and Solutions for Medical Practices?

Regulatory compliance and technology are changing the landscape of the health care industry. New technologies, revenue cycles resolution and changes in leadership can all have a positive impact on your practice. Are you prepared to take on these new opportunities? In this article, Tammie Lunceford answers a few questions about how the landscape is changing and how facing these changes can help breathe new life into your practice.

Question: What are some of the common challenges you have seen in medical practices recently?

Answer: I often see revenue cycle problems. It is more difficult now than ever to get paid by the carriers and by the patient. As you know, we’ve had a shift from the carrier paying all of the health claims to now the patient has more responsibility over the costs, and it can be difficult to ask patients for money. Physicians are there to serve the patient and many feel uncomfortable asking the patient for money. I also see problems with adopting new technologies that are available, and problems where too much responsibility is on the front office…having them answer the phone and also deal face-to-face with the patient, which can be challenging. We also have seen a lot of highly qualified managers (Baby Boomers) leaving the market, which can lead to issues with changing leadership.

Question: Can you describe a couple of examples you’ve seen in medical practices where, with a few small changes, you saw a big impact.

Answer: I work with both large and small practices, and I have a couple of stories that I could share. One from this year was a Practice Assessment for a new client. The manager was overwhelmed because the practice had doubled in size over a four-year period. The physicians were overwhelmed because they were finding themselves making decisions for a large practice when they had been a small practice for so many years. Their revenue cycle manager, who had been very loyal to the practice, was not qualified to handle the new load, and were having some financial issues. MACRA was approaching as a big project and that they had no idea how to attempt that undertaking. Plus, throughout their growth, they had failed to build the appropriate infrastructure to adequately support the practice, like hiring a mid-level manager or supervisory staff to assist the manager in staying highly effective. So, after I identified these problems during the assessment, I worked closely with the group and over a short period of time we recruited and hired a revenue cycle manager who was effective and innovative. The practice’s profitability has increased, they relieved the front desk staff from answering the phones and allowed them to focus on the patients standing in front of them. Through coaching the group and the manager, they have been able to work more cohesively and make better decisions. They’ve identified some team leaders to lead other areas, and they are doing great. They are approaching projects more on their own now, but I’m still their advisor and have built a long-term relationship and I know we will continue working with that practice.

We also work with smaller practices. We received a call from a physician who was leaving a large practice and going out on her own to form a “boutique practice.” I assisted her early in her practice. She couldn’t afford a high-level manager to help her make decisions, so I became her advisor. I continued this over a five-year period and we have taken her from being too small to hire a manager to hiring a manager, to hiring to mid-level providers, and now we are about to hire a partner for her. I love forming these lasting relationships with managers and providers.

Question: What new changes are we seeing in healthcare as we move forward into the next few years?

Answer: Because we’ve seen a decline in reimbursement and collections over the last few years, it can be difficult for us to get physicians to invest in their practice because many are afraid. They want to hang on to their money rather than investing in their practice. They really don’t know where we are going in the future of healthcare, there are changes in the payment models, administrative burdens are at their highest, and manager and physician burnout is at its highest. There has never been a time where I’ve seen practices need advisory services more than now. I think with technology growing as quickly as it is, we will need to guide these physicians on what technologies they should incorporate and invest in to keep their practice vital.

Article contributed by Tammie Lunceford, Healthcare and Dental Consultant, Warren Averett Healthcare Consulting Group. Warren Averett is an official Gold Partner with the Medical Association.

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Don’t Forget Your Risk Assessments!

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Don’t Forget Your Risk Assessments!

Many medical practices are planning their Security Risk Assessments for the new year. Whether to better qualify for the 2019 Merit-based Incentive Payment System (MIPS) or to fulfill obligations to comply with the HIPAA Security Rule, a strong strategy now will reap benefits later. It’s a good time to remember what is required when conducting a Security Risk Assessment, as there tends to be confusion around what the Risk Assessment should include.

Here are some helpful reminders as we move through the first quarter of the year:

It’s Not Just a Checklist. A proper Security Risk Assessment is a thorough process where a covered entity under HIPAA should identify, prioritize and estimate the risks to practice operations resulting from the use of or implementation of a specific technology. Once the risks are identified, a plan of mitigation should be created that provides a roadmap for ongoing risk management.

Don’t Just Focus on EMR. While your EMR system, and the safeguards in place to protect EMR data, should absolutely be part of the Risk Assessment process, time should also be spent analyzing and assessing the risk to protected data that sits outside the EMR system. Identify the ePHI in the practice that resides outside the EMR application (e.g. files stored on users’ personal computers, data stored in ancillary systems, copiers and scanners, etc.) and assess the risk associated with this data as part of the assessment.

No Specific Methodology Required. While OCR has provided practices with guidance regarding the Security Risk Assessment Requirement, there is no mandatory process or method by which a practice must follow to comply with the requirement. However, most security professionals recommend following accepted industry frameworks, such as those provided by the National Institute of Standards and Technology (NIST).

Revisit Previous Risk Assessments to Show Progress. When conducting a new Security Risk Assessment, review past analysis and make an effort to document progress made with regards to risk mitigation. As the spirit of the Security Rule has always been to encourage covered entities to use the Risk Assessment as a starting point for ongoing Risk Management, documenting progress made will show the practice doesn’t simply consider the Assessment a rote exercise but a vital part of managing and mitigating risk on an ongoing basis.

You Don’t Have to Outsource Your Security Risk Assessment. OCR is very quick to point out there is no requirement, neither in the Security Rule nor under MIPS, for covered-entities to outsource their Security Risk Assessment. In fact, OCR has published a free, downloadable tool that practices can use to help with efforts to fulfill requirements (https://www.healthit.gov/topic/security-risk-assessment-tool). However, OCR does go out of its way to explain the time commitment and skillset required to adequately evaluate and utilize the tool, and encourages all covered-entities to seek professional assistance when considering using these resources to self-perform the Security Risk Assessment.

A thorough Security Risk Assessment must stand up to an auditor or investigator, especially in the event of a security incident. A lack of proper Risk Analysis is cited in many investigative findings that have also carried large financial penalties. Take the time to consider how your practice will approach the Security Risk Assessment in 2019, and consider it as an opportunity to genuinely look at where you might be vulnerable and how the Assessment can be used as a springboard for true Risk Management.

References:

https://www.healthit.gov/topic/privacy-security/security-risk-assessment-tool

https://www.cms.gov/Medicare/Quality-Payment-Program/Resource-Library/2018-Cost-Performance-Category-Fact-Sheet.pdf

https://www.healthit.gov/topic/privacy-security/top-10-myths-security-risk-analysis

Nic Cofield is Director of Client Services with Jackson Thornton Technologies LLC (JTT). JTT is one of the Southeast’s leading providers of managed IT services, cybersecurity services/consulting and IT Risk Assessments to health care providers. JTT is wholly owned by Jackson Thornton CPAs & Consultants, which is a partner with the Medical Association.

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Evaluating and Managing the E/M Codes for 2019 and Beyond

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Evaluating and Managing the E/M Codes for 2019 and Beyond

Editor’s Note: This article is the first in a series of articles about notable changes in the 2019 Physician Fee Schedule Final Rule.

In the 2019 Physician Fee Schedule (“PFS”) Proposed Rule, the Centers for Medicare and Medicaid Services (“CMS”) proposed some major changes to the PFS, including changes to the way Evaluation and Management (“E/M”) services are reimbursed. The PFS Final Rule[1] contains some good news and bad news. The good news . . . CMS isn’t making any of the major changes it proposed in 2019. The bad news . . . they plan on making some big changes over the next few years.

<<Quick Summary: 2019 Medicare Physician Fee Schedule and Quality Payment Program Final Rule>>

Proposal

CMS proposed to collapse several levels of E/M Codes into one reimbursement level with add-on codes for certain prolonged or complex visits.

Final Rule

CMS is reducing some documentation redundancies for 2019, but it is not finalizing most of the payment proposals described above until 2021.

The Details

Currently, there are 3 to 5 levels of E/M codes depending on the practice setting (3 to 4 in facility settings and 5 for outpatient or office settings). These codes are billed based on the relative complexity of the E/M service provided, as determined in accordance with either the 1995 or 1997 guidelines issued by CMS.[2] The higher the level of E/M service (and associated relative time and resources required to deliver those services), the higher the reimbursement. According to CMS, E/M codes represent approximately 40 percent of allowed charges for PFS services, and outpatient/office visit E/M codes represent about 20 percent of total PFS allowed charges. Despite the frequency with which E/M services are performed and billed, there are a number of complexities surrounding how they are billed and the documentation required for each level of E/M code.

In an effort to alleviate this burden, CMS proposed to collapse the reimbursement for E/M level 2 through level 5 codes into a single reimbursement amount. In addition, CMS proposed to allow two new add-on codes to represent prolonged services and services with a relatively high degree of complexity. Noting the extensive time and resources that will be needed to adjust to the new coding regime, CMS has delayed the effective date of these rules until 2021. There’s time to prepare for the new E/M coding regime, and it may be altered some between now and 2021, but below is a brief overview of the finalized changes for 2021.

Collapsing Reimbursement for Levels 2-4. Importantly, CMS decided not to change the E/M codes themselves but instead chose to pay the same base reimbursement for E/M code levels 2 through 4.[3] In theory, this will reduce the level of documentation required because physicians will only need to meet the documentation requirements for a level 2 E/M code. However, it will also result in a reduction in reimbursement for many physicians who ordinarily bill higher level E/M codes, unless they also bill for one of the new add-on codes discussed below. Despite the changes in reimbursement levels, physicians do not necessarily have to change how they perform and document E/M services. In fact, CMS expects that physicians will continue to document and bill as they normally would. Noting that other government and private payors (including Medicaid, Blue Cross & Blue Shield, etc.) may continue to use the existing coding structure—or would at least need time to adjust to new coding regimes — CMS decided to retain the existing coding structure, changing the reimbursement only.

Add-On Codes. To account for the reduction in reimbursement associated with the new combined reimbursement rate for E/M levels 2 through 4 and to better align reimbursement with the resources utilized in providing E/M services, CMS decided to add two new add-on codes (again, effective 2021) that can be billed with E/M levels 2 through 4. The first is an add-on code for E/M visits for primary care and certain types of specialized medical care. The second is an add-on code to account for additional resources utilized when physicians have extended visits with patients. Despite the addition of these new codes, CMS indicated that there should not be any additional documentation requirements for E/M services.

Reducing Redundant Data Recording (effective 2019). In response to stakeholder feedback, CMS decided to remove the requirement that physicians document the medical necessity of conducting a visit in the patient’s home instead of in the physician’s office.[4] CMS also decided to streamline documentation requirements by allowing physicians to review information already contained in the medical record (review of systems and past, family and/or social history) and update it as needed, rather than re-recording all of the information.

Proposals Not Adopted. CMS decided not to adopt some of its proposals, including proposals to: (1) reduce reimbursement when E/M services are provided on the same day as a procedure; (2) establish separate podiatric E/M codes; and (3) standardize the amounts of practice expense RVUs for E/M codes.

Conclusion

Overall, there are some changes going into effect in just over a month, and others will likely be reshaped and refined over the next two years before they are implemented in 2021. For now, all physicians need to know is that they can continue to document and bill E/M codes as they always have, but in theory with less redundancy in documentation requirements.

Article contributed by Christopher L. Richard with Gilpin Givhan, PC. Gilpin Givhan, PC, is an official partner with the Medical Association.

 

[1] CMS-1693-F, available at https://s3.amazonaws.com/public-inspection.federalregister.gov/2018-24170.pdf.

[2] 1995 Documentation Guidelines for Evaluation and Management Services, available at https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNEdWebGuide/Downloads/95Docguidelines.pdf; 1997 Guidelines for Evaluation and Management Services, available at https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNEdWebGuide/Downloads/97Docguidelines.pdf.

[3] CMS decided to combine levels 2 through 4 instead of 2 through 5, as originally proposed.

[4] CMS reasoned that this decision is best left to the physician and patient, without applying additional payment rules.

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CMS Releases Physician Payment Rule

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CMS Releases Physician Payment Rule

This week CMS released the final physician payment rule for CY 2019. In addition to the changes to the physician fee schedule (slightly higher than the CY 2018 rate), the rule expands payment for telehealth and aligns physician interoperability requirements with hospital requirements and allows more flexibility in the physician quality reporting program. The rule finalizes a consolidated payment rate for evaluation and management (E/M) office and outpatient visit levels 2 through 4, while maintaining the payment rate for level 5 E/M visits. It also reduces payment for new Part B drugs and requires hospital outreach laboratories to begin collecting and reporting private payer payment rates and volumes. Finally, the rule will continue to allow non-excepted off-campus provider-based departments of hospitals to bill for non-excepted services on the institutional claim and will maintain payment for non-excepted services at 40 percent of the outpatient prospective payment system amount for CY 2019.

The Medical Association partnered with the American Medical Association to secure the changes.

Removing Restrictions on E/M Coding

CMS finalized several changes to E/M documentation guideline which were strongly supported by the AMA and other members of the Federation:

  • The requirement to document medical necessity of furnishing visits in the home rather than office will be eliminated.
  • Physicians will no longer be required to re-record elements of history and physical exam when there is evidence that the information has been reviewed and updated. In addition,
  • Physicians must only document that they reviewed and verified information regarding chief complaint and history that is already recorded by ancillary staff or the patient.
  • These changes will take effect 1/1/2019.

The Original Proposal Condensing Office Visit Payment Amounts and Documentation Requirements

In the 2019 proposed rule, CMS proposed to implement a single payment rate for level 2 through level 5 office visits and to reduce documentation requirements for this collapsed payment to that of a level 2 CPT visit code. The Agency proposed to continue to use existing CPT structure for office visit codes 99201-99215, though proposed to change CMS guidelines and only enforce certain aspects of the CPT structure by allowing physicians to choose the method of documentation, among the following options:

  • 1995 or 1997 Evaluation and Management Guidelines for history, physical exam and medical decision making (current framework for documentation)
  • Medical decision making only
  • Physician time spent face-to-face with patients
  • CMS had also proposed an add-on code to each office visit performed for primary care purposes and an add-on code for specialities with inherently complex E/M visits
  • CMS relayed that commenters overwhelmingly opposed the Agency’s proposed payment collapse. CMS will not finalize the proposal for CY 2019.

Other Coding/Payment Proposals Related to E/M

The following policies were also opposed and will not be implemented by CMS:

  • Payment reductions by 50 percent for office visits that occur on the same date as procedures (or a physician in the same group practice). The AMA brought attention to the fact that duplicative resources have already been removed from the underlying procedure through the current valuation process.
  • In addition, CMS proposed to no longer allow for podiatry to report CPT codes 99201-99215 and instead would use two proposed G-codes for podiatry office visits. As well as a new prolonged service code that would have been implemented to add-on to any office visit lasting more than 30 minutes beyond the office visit (ie, hour long visits in total).
  • Condensed practice expense payment for the E/M office visits, by creating a new indirect practice expense category solely for office visits, overriding the current methodology for these services by treating Office E/M as a separate Medicare Designated Specialty. This change would also have resulted in the exclusion of the indirect practice costs for office visits when deriving every other specialty’s indirect practice expense amount for all other services that they perform, which would have resulted in large changes in payment for many specialties (ie a greater than 10 percent payment reduction for chemotherapy services).

Download the CMS Factsheet.

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When Is It Wise to Offer Patients a Reduced Fee Schedule?

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When Is It Wise to Offer Patients a Reduced Fee Schedule?

Some of our practice management roundtable participants are offering certain patients an opportunity to pay fees of less than the standard fee schedule for their care. Below we will discuss how they are reaching that decision and if it could be appropriate for your practice.

Some patients have no insurance coverage but want to pay for their care. For this group, there is logic to support a price which is less than the standard fee schedule, if that fee schedule is already set above the amounts paid by all insurance companies and Medicare. The fee reduction is based on an acknowledgment that billed fees for health care are generally set at higher amounts than the providers expect anyway, so some discounting is within reason. A problem occurs when your group’s fees are set at precisely the amounts paid by your largest payers and any discount reduces your fee to levels below what insurance companies or government payers pay you. This can get you into big trouble because those payers are willing to pay only your UCR or Usual and Customary Rate, and if you are regularly making a lower rate available to others, the large payers could ask for repayments. However, if your fee schedule is sufficiently high, a discount to an individual might still leave you with enough fee to protect against violating any “most favored nation” clause in your contract with an insurance company.

After this logic is used to support fee reductions to uninsured patients, can it also be applied to patients who are underinsured? Most employers have received significant annual increases in medical insurance premiums for coverage of their employees. As a result, the employers are modifying the coverage to increase the deductibles dramatically. In one client practice, the annual deductibles per person were raised from $750 to $5,000 after premiums increased 18 percent, 18 percent and 15 percent over the most recent three years. As a result, patients are presenting at medical offices with personal liability so great that they are not able to pay for care. Some administrators even indicate that patients are postponing needed care because of their inability to pay for it.

If a practice has made a decision to reduce fees for patients without coverage, and since many patients are facing large deductibles, those physician offices are extending discounts to insured patients who wish to personally pay a lower fee in full at the time of service. Under HIPAA, patients do have the right to pay for care and request that you not file a claim with their insurance company, but there are forms the patient must sign to correctly document this handling.

The danger associated with any discounting is the possibility that all the discounted dollars serve to reduce physician bonuses at year end. The practice overhead will not be reduced by reason of discounting. If these discounts are thought of as the last dollars collected, then they would have been available for MD payment at bonus time. However, if by discounting you are collecting patient payment monies that would otherwise have become a bad debt not collected, then the amounts you receive are incremental money for distribution to doctors at year end. Which of these situations applies to you will depend on whether your group is writing off uncollected patient balances that could have been obtained, in part, at the time of service.

So what is the take away relative to this trend? First, have a practice which is so well known for excellence in care that you may pick the patients you want and avoid discounting fees to anyone. Next, make sure your standard fee schedule is set higher than the reimbursement you receive from your practice’s highest payer. Finally, reach an agreement among all of your physicians on the discounting process you want to consistently apply and implement that process by training all staff. Times are changing in health care and one major change is the shifting of cost risks to the patients from their insurance carriers. Be sure your practice is adapting to this area of change.

Article contributed by Sae Evans, Maddox Casey and Jim Stroud, Members, Warren Averett Healthcare Consulting Group. Warren Averett is an official Gold Partner with the Medical Association.

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Medical Association, AMA, Others Take a Stand on New CMS Rule

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Medical Association, AMA, Others Take a Stand on New CMS Rule

The Medical Association joined with the American Medical Association and more than 170 other organizations to support some components of CMS’ “Patients Over Paperwork” initiative, and say three of its components need to be enacted immediately to reduce “note bloat” redundancy, yet also to oppose a proposal to collapse payment rates for physician office visit services over concern about unintended consequences included in the proposed 2019 Medicare Physician Fee Schedule and Quality Payment Program rule.

Read the letter here.

The AMA and other organizations called for the immediate adoption of these proposals:

  • Changing the required documentation of a patient’s history to focus only on the interval since the previous visit.
  • Eliminating requirement for physicians to redocument information that has already been documented in the patient’s record by practice staff or by the patient.
  • Removing the need to justify providing a home visit instead of an office visit.

However, the CMS proposal to “collapse” payment rates for five evaluation and management (E/M) office visit services into two has the potential to create unintended negative consequences for patients.

“We oppose the implementation of this proposal because it could hurt physicians and other health care professionals in specialties that treat the sickest patients, as well as those who provide comprehensive primary care, ultimately jeopardizing patients’ access to care,” the letter states. The AMA and the other organizations joining the letter also oppose a proposed policy that would cut payments for multiple services delivered on the same day.

The organizations note their willingness to work with CMS to resolve issues connected with calculating the appropriate coding, payment and documentation requirements for different levels of E/M services. They also declare their support for the workgroup the AMA created of coding experts who would “arrive at concrete solutions” in time for CMS to implement in the 2020 Medicare physician fee schedule.

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Big Changes Proposed for Evaluation and Management Services

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Big Changes Proposed for Evaluation and Management Services

It’s been more than 20 years since the 1997 revisions to Evaluation and Management guidelines, which focus mainly on physical examination. The 2019 proposed changes provide practitioners a choice in the basis of documenting E/M visits; alleviating the burdens and focusing attention on alternatives that better reflect the current practice of medicine. The implementation of electronic medical records has allowed providers to document more information, yet repetitive templates, cloning and other workflows have pushed the envelope on compliance in documenting the traditional elements of the visit.

The proposed changes to Evaluation and Management were released in the Federal Register on July 27. The Center of Medicare and Medicaid Services is taking comments until Sept. 10, before releasing the Final 2019 Medicare Fee Schedule.

The CPT guidelines are not changing! The American Medical Association is the author of the CPT books, and there is no change in the 1995 or 1997 guidelines for E/M documentation. Medical necessity remains the overarching criteria to select a level of service. There are three proposals to reduce documentation burdens related to CMS:

Proposal One

Simplify History and Exam Documentation, allowing the physicians to focus on changes in health and allow ancillary staff to document chief complaint and history without the physician re-entering it.

Proposal Two

Remove History and Exam from E/M level decision. Currently, history and exam are two of three required elements along with medical decision-making. Medical decision-making would be the sole determinant of E/M level. Providers could use face-to-face time as a determining factor when selecting an E/M service level.

Proposal Three

Pay a single rate for Level E/M visits for the reduced burden in documentation and coding guidelines. Proposals one and two will be a package deal in proposal three. The tables below reflect the proposed payment rates.

Table A – New Patient E/M: Non-facility

Code        2018 Payment Rate     CY 2018 New Payment Rate

99201 $45 $44
99202 $76 $135
99203 $110 $135
99204 $167 $135
99205 $211 $135

 

Table B – Established Patient E/M: Non-facility

Code           2018 Payment Rate             CY 2018 New Payment Rate

99211 $22 $24
99212 $45 $93
99213 $74 $93
99214 $109 $93
99215 $148 $93

 

There are two add-on codes proposed, including one for primary care to cover inherent complexity. The primary care add-on code is GPC1X. It can only be utilized by primary care. By adding the G code to Medicare claims, internal medicine and family practice can actually earn up to five percent more revenue and reduce documentation efforts.

The add-on code available to a list of ten specialties is GPC0X. The specialties were chosen due to the inherent complexity related to E/M. The specialties eligible for this add-on code are: endocrinology, rheumatology, hematology/oncology, urology, neurology, obstetrics/gynecology, allergy/immunology, otolaryngology, cardiology or interventional pain. The big loser in this proposal is pulmonary medicine, with a reduction of 6.2 percent in revenue projected by Part B News. The big winner is urology, with a projected increase in revenue of 22 percent with the add-on code.

As a certified coder, I believe the reduction in documentation is a positive change. Most physicians were not educated on CPT coding as part of their clinical training. Physicians want to be compliant, but the guidelines are too complex to analyze during each encounter. The ancillary staff should be trained to effectively gather pertinent information to support the physician. This would allow physicians to focus on the clinical needs of the patient. CMS expects medical necessity to prevail and each encounter to stand alone in relation to the full medical record.

A proposal for 2019, we aren’t hearing about is an E/M multiple procedure payment adjustment related to duplicative resource costs when an E/M is visited and a procedure with global periods are furnished on the same day. CMS would reduce the E/M payment by 50 percent.

Administrators should review the proposed options for documentation to understand the effect on their practice. If your practice has the potential to see a negative adjustment without the option to utilize an add-on code, you should analyze the E/M dispersion pattern to understand the financial impact to your practice. For the most part, the proposed changes are positive in an effort to reduce the burden of redundant documentation. We should continue to hear much more information regarding this game-changing proposal particularly after the comment period ends on Sept. 10. The final 2019 fee schedule will be released around the first week of November. Stay tuned!

If you would like to send a comment to CMS on these changes (and we suggest you do), go to https://www.federalregister.gov/documents/2018/07/27/2018-14985/medicare-program-revisions-to-payment-policies-under-the-physician-fee-schedule-and-other-revisions.

Article contributed by Tammie Lunceford, Healthcare and Dental Consultant, Warren Averett Healthcare Consulting Group. Warren Averett is an official partner with the Medical Association.

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ProAssurance and Sure Med Compliance Join to Fight Opioid Crisis

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ProAssurance and Sure Med Compliance Join to Fight Opioid Crisis

BIRMINGHAM ─ ProAssurance Corporation has announced an exclusive affiliation with Sure Med Compliance® (SMC) to promote the use of SMC’s Care Continuity Program® (CCP) in an effort to help combat the opioid epidemic in the United States.

ProAssurance-insured physicians will be eligible for discounted access to Sure Med’s Care Continuity Program

The CCP helps physicians and other health care providers develop and maintain responsible prescribing practices for opioids and other scheduled medications by equipping them with tools to verify patients suitable for opioid therapy, identify with significant risk factors, and closely monitor the effects of treatment over time.

“As an industry leader, we are acutely aware of the devastating effects of the opioid epidemic in this country. We are concerned about the epidemic’s professional liability implications for physicians and other healthcare providers, as well as its broader effects on the healthcare system in general. We are proud to affiliate with Sure Med Compliance to offer our insureds exclusive discounted access to this cutting-edge approach to patient safety and effective treatment, ” said Howard H. Friedman, president of ProAssurance’s Healthcare Professional Liability Group.

John Bowman, Sure Med Compliance’s Chief Executive Officer, emphasized the importance of the newly formed affiliation.

“Our Care Continuity Program provides a proven path toward optimal outcomes for patients whose treatment requires the use of opioids and other potentially addictive drugs,” Bowman said. “In turn, CCP helps physicians avoid potential liability issues, which has always been a focus of ProAssurance and why we are so excited about this affiliation. We are confident their national footprint will help Sure Med Compliance reach more physicians and assist more patients than ever before.”

Through this affiliation, ProAssurance insureds who meet certain eligibility requirements will have access to an exclusive 30-day free trial of the CCP. ProAssurance insureds who elect to continue using the Care Continuity Program will receive exclusive discounted rates. ProAssurance insureds may contact Sure Med Compliance to determine eligibility and initiate a 30-day free trial by visiting www.suremedcompliance.com/proassurance or calling (866) 517-2771.

“As a practicing pain management specialist, I have experienced firsthand the challenges physicians face in deciding to prescribe controlled substances. Using the Sure Med Compliance CCP in my practice has helped me ensure proper documentation and address potential issues before they occur,” said Sure Med Compliance’s Medical Director David Herrick, M.D., of Montgomery. Dr. Herrick is a past president of the Medical Association of the State of Alabama and a former member of the Alabama Board of Medical Examiners.

ProAssurance’s Chief Medical Officer Hayes V. Whiteside, M.D., encouraged physicians with ProAssurance to learn more about the CCP.

“Our commitment to provide our insureds with exclusive discounted access to the Sure Med Compliance CCP underscores ProAssurance’s commitment to ensure physicians and other health care providers are equipped with the risk management tools and services necessary to deal with the ever-changing realities of their chosen profession,” Dr. Whiteside said. “All ProAssurance insureds who regularly prescribe opioids, especially those who prescribe for chronic pain, are encouraged to engage Sure Med Compliance to learn more about how their Care Continuity Program can help them develop and maintain safe and responsible prescribing practices, which should lead to better outcomes for their patients.”

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Changes in Patient Access

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Changes in Patient Access

Physicians have struggled with the impact of the Affordable Care Act since its passage in 2010, but there is a new, more powerful and insidious change underway which will have dramatic impact on all medical practices. The free enterprise system together with an emergence of the Millennial generation has begun to break medicine of some traditional bad habits. Historically, a medical practice could take patient phone calls when it had time, book patient visits at the convenience of the physician and permit patients to sit in the waiting room well after the scheduled appointment time, before seeing the physician.

The Millennial generation population, which now exceeds the Baby Boomers in our population, has not been raised to wait patiently for service providers. They reply to texts while waiting for their name to be called for a customized coffee order. When the texts are handled, they are ready to move to the next multi-tasking activity. The prospect of sitting for two hours in a physician waiting room is not acceptable to them. Our nation’s capitalist system is eager to respond to this high value placed on personal time by the Millennials. Several developments signal the opening of care access alternatives.

The appearance of urgent care facilities was the initial sign of changing times. These care delivery offices are now in many cities, and are as near to each other as fast food sources in some locations. Urgent care facilities are a way to avoid the cost of a parking deck, eliminate the need to navigate a physician office building and avoid waiting long past a scheduled appointment time to be seen. Patients expect to pay out of pocket for the ability to obtain quick care and return to their busy schedules. Traditional office-based physicians might be surprised to know how many of their longstanding patients are seeking more convenient help at urgent care facilities.

Patients who want greater convenience can be seen in the comfort of their own home. Several states have this “Uber” healthcare service, as it was called in a recent Wall Street Journal article. The health care service commits to have a physician or mid-level provider to the home within a short period of time. In Colorado, a home health provider is also dispatched in response to some 911 calls. If the situation can be treated in the home, insurance pays the $300 cost per call rather than incurring the $3,000 ambulance transport cost. Certainly, the $100 fee for these normal house calls is affordable by only the more affluent families, but these are exactly the families a medical practice most needs to retain because they can pay for their care out of pocket.

Telemedicine is the next game-changing element in the provision of care. Hospitals are offering telemedicine consultations for certain specialties rather than paying M.D.s to be on call weekends and nights. Insurance providers offer telemedicine consultations for $10 per consult and this service is available 24 hours a day, every day of the week. These consults may be limited to the more simple medical issues, but these matters enable physicians to generate the incremental patient volume which produces year-end profit and bonuses. When this group can receive their prescriptions via a telemedicine visit at night, physician practices are left with the more complex patient problems and limited ability to bill more for the increased time to treat.

What do these easier points of patient access mean to medical practices? If you want to keep your entire patient base, it is time to make certain that care at your practice is eagerly being offered to your patients. Phones should be answered within three rings. Call your main office line from another number, and see how many rings your patients hear before an answer. Listen for the tone with which the phone is answered. Is it tired and bothered, or happy to take the call? Once a call is answered, how soon can the patient be seen? A sick patient might accept an appointment 10 days out, but they will likely heal or see an urgent care facility before the 10 days passes. That means you will find out in 10 days that you have another no-show on your schedule. When a patient wins the appointment lottery and gets an appointment tomorrow, how long do they have to wait past your promised time to see them? Be careful about long wait times. Most of our population are multi-taskers and have something on their schedule after their office visit. Some will even leave before being seen. Most will say nothing about their displeasure and simply not come back.

In short, the growing medical practices are treating patients like they are being served by a luxury hotel. Your practice is either growing or suffering atrophy. Look at your new patient numbers by month for the last 24 months, and see into which category you fall. If you know your group needs to improve, contact one of our healthcare team members for ways to become a survivor in the new world of patient access.

Article contributed by Warren Averett CPAs and Advisors, official Gold Partner with the Medical Association

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Are Tax Cuts Coming for the Small Business Owner?

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Are Tax Cuts Coming for the Small Business Owner?

While physician practices have many specialized health care compliance issues, most are, in essence, small businesses that face the same challenges as any small business. Taxes and regulations are among those challenges affecting all small businesses. And many owners are now eagerly awaiting alleviation of those challenges.

According to the National Federation of Independent Business, small business optimism is at its highest rate since 2004. Small business owners are hopeful that President Trump’s promises of regulatory reform and lower taxes will become a reality, and small businesses will reap the rewards. With Republicans controlling both Houses, that hope appears to be well-founded.

President Trump and the Republican Congress have promised that a repeal of the Affordable Care Act will lower insurance requirements for small businesses, that the deconstruction of the banking regulations of the Dodd-Frank Act will give small businesses more access to credit, and that tax reform will provide small businesses with tax savings. Let’s take a look at some of the specific tax plans President Trump has proposed that have small business owners excited.

Small business owners are hopeful that President Trump’s promises or regulatory reform and lower taxes will become a reality and small businesses will reap the rewards. Small business owners should rightly expect to see tax cuts in the near future.

The new administration has proposed cutting the highest corporate tax rate from 35 percent to 15 percent. S corporations and other pass-through entities may also see a reduced tax rate, as President Trump has proposed a maximum rate of 15 percent on business income that is reinvested into the company. This proposal provides some relief to the business owner on his “phantom income” tax bill. Comparatively, the House GOP tax plan reduces the corporate rate to 20 percent and the pass-through rate to 25 percent.

Of course, small business owners are also individual taxpayers, and President Trump’s tax plan contains several facets to benefit the individual taxpayer. President Trump’s proposal is to reduce the number of personal income tax brackets from seven to three. For joint filers, the proposed marginal rates on taxable income are 12 percent for up to $75,000, 25 percent for $75,000 to $225,000, and 33 percent for more than $225,000. (Dollar amounts for single filers are half of these amounts.) Here, the House GOP tax plan aligns with President Trump’s proposal, save a slight variation in the dollar amounts.

Of particular interest to many high-income earners is the Net Investment Income Tax (“NIIT”). The NIIT was enacted within the Affordable Care Act (“ACA”) and imposes a tax of 3.8 percent on investment income, such as interest, dividends, short-term and long-term capital gains, rental income, royalty income, and passive activity income. It applies only to investment income that exceeds a threshold of $200,000 of adjusted gross income for single filers and $250,000 of adjusted gross income for joint filers. President Trump, however, has proposed to repeal that tax. And because the NIIT is part of the ACA, which is first and foremost on the Republican Congress’s list of laws to repeal, this 3.8 percent tax may be the first tax to go.

President Trump’s tax plan also includes more than doubling the standard deduction, eliminating the estate tax, and providing revised childcare deductions and rebates. Additionally, he has proposed providing for the establishment of Dependent Care Savings Accounts with a government matching program.

It is worth noting, though, that President Trump has a stated goal of tax simplification. To that end, he has proposed to eliminate the reduced capital gains tax rate for carried interest, eliminate personal exemptions, eliminate the head-of-household status, and impose a cap on itemized deductions. As such, not all of President Trump’s proposed tax plan will provide a benefit to the taxpayer’s bottom line.

Even so, small business owners should be energized by the lower rates and simplification. A reduction of tax compliance expenditures could be significant for the small business. Piggyback that on the expected repeal of the Affordable Care Act, and small business owners can anticipate spending less time and effort on the compliance side and more on the business side.

Although portions of the House Republicans’ tax plan are not as aggressive as President Trump’s, the plans set forth similar reductions to the individual and business tax rates. Consequently, small business owners should rightly expect to see tax cuts in the near future.

Article contributed by Leslie H. Pitman, an attorney at Gilpin Givhan. Gilpin Givan is a Bronze Partner with the Medical Association.

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