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Published byColin Dean Modified over 9 years ago
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Coping with Regulatory and Payer Demands to Practice PM&R Bruce M. Gans, MD
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Payers are seeking ways to avoid payment, shift responsibility, and minimize their exposure to all providers, including physicians
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Do the right things clinically Document them well Code accurately and completely Inform the patient of their liability for paying for your services before you provide them Collect co-pays at the time and site of service when possible Review your insurance plan participation regularly Review your collections regularly Understand your contractual allowance rates
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Audit your records yourself for documentation and coding accuracy Cross-audit your charts with other providers Engage external auditors to review, critique, and educate yourself and your staff
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Appeal everything Follow the rules meticulously Engage professional help Track your success Learn from your mistakes or failures to win
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Medical Administrative Roles Employment Independent Contractor On-call arrangements Risks to be avoided Review the contract carefully Document your work if you must invoice for payment Do the work you invoice for Make sure your payment rate is truly fair market value
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Clinical Roles Incorporating Medicare documentation requirements for inpatient rehab care into your practice Separating or commingling administrative and clinical services Gym rounds Team meetings with patients Use of extenders
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Patients come first Balance your obligation to your patient with the responsibility to show reasonable restraint in how you provide care and authorize/prescribe drugs, goods and services Work in close alignment with others involved in the care of your patients You are looked to as a leader, so lead with wisdom, grace and integrity
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Peter W. Thomas
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Existing RACs continue to audit certain claims RAC legal challenge delays awards of new round of RACs Changes to RAC contracts that benefit providers
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Additional Documentation Request limits by provider group
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New authority for CMS contractors to deny related claims Specific rules governing denial of related claims
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Extent of ALJ hearing backlog AHA Lawsuit to challenge ALJ delay FAIR Fund Amicus brief to demonstrate harm to providers 68% Settlement offer for acute care hospitals re: short day stays Impact of developments on appeals process Pointers on challenging denials of claims, including recoupment and interest
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Series of Congressional hearings exposing burden on providers GAO Report on Medicare Audit Contractors Senate Special Committee on Aging Report on Audits and Appeals Pending legislative efforts on Medicare audits and appeals
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Status of Physician documentation “template” being developed by CMS Prior Authorization of certain DMEPOS Regulatory changes involving Off-the-Shelf Orthotics
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Round II and the future of Medicare competitive acquisition of DME National pricing based on competitive bidding Impact of coding on access to DMEPOS care
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