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How ACA Administrative Simplification Rules Can Improve Cash and Productivity Presented by: Ken Bradley Vice President, Strategic Planning Navicure
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PPACA Overview Operating Rules Timelines Eligibility Rules Remittance and EFT Rules Practice Benefits 2 © 2013 Navicure, Inc.
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The Patient Protection and Affordable Care Act (aka ACA ) Most public discussion around expansion, individual mandate and exchanges, but there is more. Besides its goals of improving quality and expanding access are ones of controlling costs and making healthcare affordable. 3 © 2013 Navicure, Inc.
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Creates the State Health Benefit Exchanges and defines benefit packages Creates ACO demonstration projects Expands fraud and abuse/compliance efforts Potentially expands Medicaid (dramatically in some states) Requires expansion of quality metrics and their use Contains language attempting to further automate the business of healthcare 4 © 2013 Navicure, Inc.
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We’ll focus on just 9 pages of the ACA Remember HIPAA? ACA dramatically extends and expands it. These 9 pages contain two sections addressing “Administrative Simplification” Section 1104 Creates “Operating Rules” framework Section 10109 Worker’s Comp Edits and payment rule transparency 5 © 2013 Navicure, Inc.
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Fragmented payers + complexity = high transaction costs and overhead costs ◦ McKinsey estimates adds $90 billion per year* Insurance and providers ◦ Variation in benefits; lack of coherence in payment ◦ Time and people expense for doctors/hospitals * 2006 Source: 2009 OECD Health Data (June 2009). Spending on Health Insurance Administration per Capita, 2007 * McKinsey Global Institute, Accounting for the Costs of U.S. Health Care: A New Look at Why Americans Spend More (New York: McKinsey, Nov. 2008). 6 © 2013 Navicure, Inc.
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National Academy of Sciences/Institute of Medicine $2.6 Trillion spent, about $260 Billion administrative Excess is estimated to be $168-183 Billion / year Wasted dollars by category: Unnecessary services - $210 B Inefficiently delivered services - $130B Excess administrative costs - $190B Prices too high - $105B Missed prevention opportunities - $55B Fraud and abuse - $75B 7 © 2013 Navicure, Inc.
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One estimate of the affect on practices $247,500 / year on unnecessary / redundant admin tasks $19,444 / year on phone calls with pharmacies $38,761 / year on verifying patient coverage manually $9,248 / year on resubmitted denied claims Source: National Academy of Sciences/MGMA Physicians today spend about 43 minutes a day (3 weeks a year) interacting with health plans Time not spent on patient care 8 © 2013 Navicure, Inc.
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What if: You were able to receive detailed, consistent benefit info from payers; and payers used remittance and remark codes consistently for common denial scenarios; and EFT and ERA were available and enrollment was the same for all payers? You could reduce costs! The ACA provides a new framework to address many of the reasons for needing to do things manually as well as requirements for more detailed and accurate information. 9 © 2013 Navicure, Inc.
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New concept introduced with ACA’s Section 1104 Allows for the creation of additional business rules and guidelines for the electronic exchange of information Wherever there is a reason for not 100% automation (no paper or manual processing), Operating Rules may be developed to address What prevents 100% automation? Letting various trading partners… “interpretation” the standards where it lets them define transmission methods, acknowledgment format use defined standards in inconsistent ways from everyone else 10 © 2013 Navicure, Inc.
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CORE/CAQH 11 © 2013 Navicure, Inc.
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ACA provides for the creation of Operating Rules to enhance existing or create new standards, but not replace existing ones All existing HIPAA standards are the foundation: 837 Claim 835 Remittance But, there are new ones: 275 Attachments CCD+ NACHA transaction used by banks 12 © 2013 Navicure, Inc.
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Operating Rules go farther than typical standards: Data content, definitions, how to use Required information Consistent use of codes in defined business scenarios Transmission standards Security requirements Response timing Exception reporting Eliminating interpretation … anything that prevents 100% automation 13 © 2013 Navicure, Inc.
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May address ANYTHING that inhibits automation, where data doesn’t flow consistently among various healthcare trading partners 14 © 2013 Navicure, Inc.
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The difference this time: Single word: Certification Health plans are required to attest they are following the rules, or they will face penalties. First set of implemented rules began January 1, 2013. Health plans should have submitted attestation document to CMS by December 31, 2013. HHS will assess possible penalties by April 1, 2014. Penalties: $1 - $20 per day, per covered life with failure to be in compliance Doubled if knowingly inaccurate, incomplete 15 © 2013 Navicure, Inc.
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Jan 1, 2013 Eligibility Claim Status Jan 1, 2014 Remittance EFT Oct 1, 2014 ICD-10 Health Plan ID 2015 Jan 1, 2016 Claims Plan Enrollment / Disenrollment Referral Certification / Authorizations Attachments 16 © 2013 Navicure, Inc.
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January 1, 2013 brought several new eligibility requirements: How to handle patient prefixes and suffixes like MRS, MR, MD, II, JR Prefix/suffix should be removed before attempting lookup Consistent and defined error reporting requirements “AAA” 5010 specifications, e.g., “71” = Patient DOB doesn’t match Response times for both batch and real-time inquiries 20 seconds real-time and next day for batch System availability e.g., minimum 86% availability per week 17 © 2013 Navicure, Inc.
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Payers are required to return details: Much needed critical information was defined in 5010 as “highly recommended” where the Operating Rule now requires them Health plan name required Past (up to 12 months) and future eligibility dates In and out-of network variances Remaining patient deductible amounts Static patient responsibility amounts: co-pay, co- insurance Generic inquiries (type 30), must have plan name and patient financials for each required service type returned 18 © 2013 Navicure, Inc.
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Required implementation: January 1, 2014 Adds new transaction – the CCD+ to the HIPAA list of transactions to allow bank deposit reassociation with 835 remittance data Bank deposit data will contain the 835 remittance advice tracking number Requires defined claim adjustment reason and remark code combinations for common reasons services are not paid EFT & standardized and electronic EFT enrollment Rule # 380 19 © 2013 Navicure, Inc.
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Defined business scenarios 1.Additional information required 2.Missing/invalid/incomplete data from submitted claim 3.Billed service not covered by health plan 4.Benefit for billing service not separately payable 20 © 2013 Navicure, Inc.
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Additional Information Required 21 © 2013 Navicure, Inc.
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Missing/Invalid/Incomplete Data 22 © 2013 Navicure, Inc.
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Billing Service Not Covered 23 © 2013 Navicure, Inc.
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Not Separately Payable 24 © 2013 Navicure, Inc.
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Look for Operating Rules to: Eliminate inconsistent data usage Define missing or unclear usage instructions Create transmission, format and system availability expectations Resulting in less: Variation in business operations from payer-to- payer Manual processing Guessing about what is needed and how processes should work Money spent on administrative costs! 25 © 2013 Navicure, Inc.
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With these new rules, it’s time: If you are not currently doing automated eligibility, now is the time to consider. If you are not currently using remit and EFT, now is the time to consider doing both. 26 © 2013 Navicure, Inc.
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Source: Milliman, 2006 27 © 2013 Navicure, Inc.
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Automated, Consistent and Accurate Transactions Improve operational costs Help reduce denials Eligibility changes show a 10-12% reduction in denials Faster secondary and patient billing cycle Improve denial management Standardized understanding of payment reductions Improve analytics Standardization allows apples-to-apples comparison Permit accurate and point-of-service patient collections 28 © 2013 Navicure, Inc.
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Automate: Eligibility $3.70 manual v. $0.74 electronic Remittance and EFT $2.96 manual v. $1.48 electronic Reduce denials: Use eligibility data to file accurate claims and begin point-of-service patient collection AMA: 21% of claims need follow-up Costing $14-$25 for each follow-up 29 © 2013 Navicure, Inc.
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Core Phase III Rules: EFT and ERA http://www.caqh.org/CORE_phase3.php ACA Timeline http://www.healthcare.gov/law/timeline/index.html Kaiser Foundation – state level activity (e.g. State Benefit Exchange status) http://www.statehealthfacts.org/index.jsp American Health Information Management Association (AHIMA) Operating Rule Overview http://library.ahima.org/xpedio/groups/public/documents/ahim a/bok1_049348.hcsp?dDocName=bok1_049348 The Daily Practice Blog – www.dailypracticeblog.comwww.dailypracticeblog.com 30 © 2013 Navicure, Inc.
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Ken Bradley VP of Strategic Planning Navicure kbradley@navicure.com 770-342-0210 Twitter: @Ken_Bradley 31 © 2013 Navicure, Inc.
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