ALERT: Closing or Relocating Your Physician Practice

ALERT: Closing or Relocating Your Physician Practice

You have spent over thirty years diligently treating your patients, and retirement has finally arrived. The RV or boat is gassed up, the grandkids can’t wait to have a new pal, and you are set to finally shave five strokes off your golf game. However, despite your long, successful, and untarnished career, you receive a last letter from your Department of Health informing you that when you closed your medical practice you failed to follow the proper procedures under you STATE OR FEDERAL law. Can the your State Department of Health really fine me, after I have retired, for failing to comply with the protocol established for Closing or Relocating a Physician Practice? The counterintuitive answer is “yes”.

Administrative Complaint shows, that Department of Health for any State may prosecute a physician for failure to perform “any statutory or legal obligation placed upon a licensed physician”, including certain legal requirements in the event a physician closes, sells, or relocates his or her medical practice.

For more information, or assistance in Closing or Relocating Your Physician Practice, please contact our office:

Paul G. Silverio-Benet

Healthcare Consultant

305-975-1171

sbhealthcaremgmnt@gmail.com

UPDATES FOR 2018

UPDATES For 2018

UPDATE: Centers for Medicare & Medicaid Services (CMS) Administrator Seema Verma recently announced a new approach to quality measurement, called “Meaningful Measures.” The Meaningful Measures Initiative will involve identifying the highest priorities to improve patient care through quality measurement and quality improvement efforts.

UPDATE: ICD-10 and Other Coding Revisions to National Coverage Determinations (NCDs)

The translations from ICD-9 to ICD-10 are not consistent one-to-one matches, nor are

all ICD-10 codes appearing in a complete General Equivalence Mappings (GEMs) mapping

guide or other mapping guides appropriate when reviewed against individual NCD policies. In

addition, for those policies that expressly allow MAC discretion, there may be changes to those

NCDs based on current review of those NCDs against ICD-10 coding. For these reasons, there

may be certain ICD-9 codes that were once considered appropriate prior to ICD-10

implementation that are no longer considered acceptable.

UPDATE: Medicare Part B Premiums/Deductibles

Medicare Part B covers physician services, outpatient hospital services, certain home health services, durable medical equipment, and other items.

The standard monthly premium for Medicare Part B enrollees will be $134 for 2018, the same amount as in 2017. Some beneficiaries who were held harmless against Part B premium increases in prior years will have a Part B premium increase in 2018, but the premium increase will be offset by the increase in their Social Security benefits next year.

CMS also announced that the annual deductible for all Medicare Part B beneficiaries will be $183 in 2018, the same annual deductible in 2017. Premiums and deductibles for Medicare Advantage and Medicare Prescription Drug plans are already finalized and are unaffected by this announcement.

UPDATE: MACRA 2018 final rule

On November 2, 2017, the Centers for Medicare & Medicaid Services (CMS) released a final rule for Year 2 of the Quality Payment Program (QPP), otherwise known as the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). MACRA, as you might recall, is currently in its first year, and the 2018 final rule is an attempt to make things easier for smaller, independent, and rural practices during the 2018 performance period.

UPDATE: Patient debt varies by specialty and location

Should certain medical specialties or locations be particularly watchful? Yes, according to research from various medical practices (via Practice Analysis), which shows that both the percent of revenue from patients and the percent of patient bad debt vary by specialty and by location across the provider network.

Healthcare Consultant  ~ Our Services

HEDIS Compliance

MACRA-MIPS Compliance

Coding & Reimbursement

Local/State/Federal Compliance

Medicare and Medicaid Audits

Practice Administrator

Provider Contracting

Provider Credentialing

Practice Analysis

HCC- MRA Compliance

Opening Medical Office

Retiring, closing, or relocating a practice

For more details contact :  

Paul G. Silverio-Benet

305-975-1171

sbhealthcaremgmnt@gmail.com

Preparing For 2018

227 HCPCS code changes for 2018

New for 2018 includes 141 new codes and 11 new modifiers; 48 revised codes, 2 revised modifiers; 38 deleted codes, 2 deleted modifiers.

HCPCS CODE CHANGES:

19 new J codes, 81 new G codes for quality reporting.

Two new modifiers related to the OPPS reimbursement change for drugs purchased through the 340B program -- one new modifier for non-digital computed radiography technology and one new modifier related to Medicare’s new coverage of diabetes prevention programs, which begins in 2018.

New patient relationship modifiers X1-X5 added for 2018 are for informational, voluntary use only in 2018. These modifiers will be mandatory beginning in 2019.

A new modifier QQ, to confirm that providers are complying with Medicare’s new appropriate use criteria, which early adopters can begin reporting in July 2018. The policy will be required in 2020.

CMS deleted bilateral screening mammography code G0202, as well as diagnostic mammography codes G0204-G0206, all of which included computer-aided detection. Instead, practices should use CPT mammography codes 77065-77067.

Ready for 2018 ?

The time to prepare is now. Providers are urged to review the quality reporting for 2018. Quality measures span four domains: patient/caregiver experience, care coordination/patient safety, preventive health, and at-risk populations.

State and federal governments increasingly are moving toward a health care industry driven by quality. Health care practitioners likely have noticed increased activity among Medicare Advantage payers regarding quality initiatives.

SILBEN Health Services, Inc.,  is your solution and a quality resource to assist providers with today’s healthcare. For more details, please contact:

Paul G. Silverio-Benet

305-975-1171

sbhealthcaremgmnt@gmail.com

  

 Our Services:

HEDIS Compliance

MACRA-MIPS Compliance

Coding & Reimbursement

Local/State/Federal Compliance

Medicare and Medicaid Audits

Practice Administrator

Provider Contracting

Provider Credentialing

Practice Analysis

HCC- MRA Compliance

Opening Medical Office

Retiring, closing, or relocating a practice

Retiring, closing, or relocating a practice…

Retiring, closing, or relocating a practice…

Physician practices undergo closure for many reasons, including physician illness, death, or relocation, or the physician’s decision to sell, practice solo, join another group, or retire.

Who should be notified if it is a nonemergent closure?

Is there a time limit for sending the closure notice?

What other responsibilities should be undertaken by the practice that is closing?

For example, Florida Providers:

Florida Statutes, sets forth the requirements that must be followed when a physician retires, closes his office or relocates his practice.  The statute adopts the concept of a “records owner.”  A “records owner” may or may not be a physician.  A “records owner” means any health care practitioner who generates a medical record after making a physical or mental examination of, or administering treatment or dispensing legend drugs to, any person; any health care practitioner to whom records are transferred by a previous records owner; or any health care practitioner’s employer, including, but not limited to, group practices and staff‑model health maintenance organizations, provided the employment contract or agreement between the employer and the health care practitioner designates the employer as the records owner.

Please note that ALL states have rules and regulations for the closing of a medical office.

Avoid penalties and/or sanctions for FAILURE to comply Rules in Closing A Medical Office.

Paul Silverio-Benet, a Healthcare Consultant , is familiar with all the requirements for you the provider to be in compliance.

For more details, please contact:

Paul G. Silverio-Benet

305-975-1171

sbhealthcaremgmnt@gmail.com

Mediciad Update

Medicaid Update

Verma Outlines Vision for Medicaid, Announces Historic Steps Taken to Improve the Program 

New Policies Help Ensure States Can Focus More Resources, Time Achieving Positive Health Outcomes for Beneficiaries

Today, Centers for Medicare & Medicaid Services (CMS) Administrator Seema Verma discussed her vision for the future of Medicaid and unveiled new CMS policies that encourage states to propose innovative Medicaid reforms, reduce federal regulatory burdens, increase efficiency, and promote transparency and accountability during a plenary session at the National Association of Medicaid Directors (NAMD) Fall Conference in Arlington, Virginia.

During her first major speech on the subject, Verma noted that when the federal government established Medicaid, it was intended to be a partnership with state governments to care for society’s most vulnerable citizens. With the growth of the program over the last several years came increased federal and state spending, which naturally meant increased federal oversight and regulation, said Verma.

“Our vision for the future of Medicaid is to reset the federal-state relationship and restore the partnership, while at the same time modernizing the program to deliver better outcomes for the people we serve,” said Administrator Verma. “We need to ensure that we are building a Medicaid program that is sound and solvent to help all beneficiaries reach their highest potential.”

Verma emphasized her commitment to “turn the page in the Medicaid program” by giving states more freedom to design innovative programs that achieve positive results for the people they serve and pledged to remove impediments that get in the way of states achieving this goal. She announced several new policies and initiatives that break down the barriers that prevent state innovation and improvement of Medicaid beneficiary health outcomes:

Web Site Content on Section 1115 Demonstrations: CMS updated Medicaid.gov to give states a clearer indication of how their reform strategies might align with a core objective of the Medicaid program: serving the health and wellness needs of the nation’s vulnerable and low-income individuals and families. The revised web site content signals a new, broader view of Section 1115 demonstrations, in which states can focus on evidence-based interventions that drive better health outcomes and quality of life improvements. The update signals CMS’s willingness to work with state officials requesting flexibility to continue to provide high quality services to their Medicaid beneficiaries, support upward mobility and independence, and advance innovative delivery system and payment models.

In a significant shift from prior policies, in speaking about the new approach to Section 1115 demonstrations, Verma emphasized the agency’s commitment to considering proposals that would give states more flexibility to engage with their working-age, able-bodied citizens on Medicaid through demonstrations that will help them rise out of poverty. As Medicaid has expanded to able-bodied individuals, the needs of this population are even more imperative, she said. During her remarks, the Administrator made it clear that CMS will openly consider proposals that promote community engagement and work activities.

“Every American deserves the dignity and respect of high expectations and as public officials we should deliver programs that instill hope and say to each beneficiary that we believe in their potential,” said Administrator Verma. “CMS believes that meaningful work is essential to beneficiaries’ economic self-sufficiency, self-esteem, well-being, and health of Americans.”

Streamline and Improve 1115 Demonstration, State Plan Amendments, and 1915 Waiver Processes: CMS released several new policies that improve federal and state program management, specifically through improvements in the review, approval process, and monitoring of 1115 Demonstrations and Medicaid and Children’s Health Insurance Program (CHIP) state plan amendments (SPA) and 1915 waivers. Taken together, these policies include provisions that will allow states to:

• Request approval for certain 1115 demonstrations for up to 10 years;
• More easily pursue “fast track” federal review, which makes it easier for states to continue their successful demonstration programs;
• Spend time administering innovative demonstrations by reducing certain 1115 reporting requirements;
• Expedite SPA and 1915 waiver efforts through a streamlined process and by participating in a new “within 15-day” initial review call with CMS officials.

In addition, the policies will improve how waivers and demonstration projects are monitored and evaluated. Waivers and demonstration projects that are less complex and have been running smoothly will require much less reporting, and waivers and demonstration projects that have a good track record of producing positive results will find an easier path to renewal. In her remarks, the Administrator underscored that these new policies were intended to relieve the regulatory burden on states, avoid increasing administrative costs for taxpayers, and refocus time and resources on improving the health outcomes of Medicaid beneficiaries.

Creation of First-Ever Medicaid and CHIP Scorecards: CMS is in the early stages of developing Scorecards that will provide greater transparency and accountability of the Medicaid program by tracking and publishing state and federal Medicaid outcomes. In her remarks, Verma said that the Scorecards were a “historic opportunity” to demonstrate to taxpayers that their hard-earned tax dollars were being spent appropriately. In addition, the reporting will provide validation to Medicaid beneficiaries that the $558 billion spent on Medicaid is producing positive results and improved health outcomes.

To close her remarks, Administrator Verma noted that federal and state officials have a higher purpose than “just handing out Medicaid cards and being a financier of healthcare.” She stressed that the Administration’s new vision for Medicaid, and the new policy changes outlined today represented the results of a promise to Medicaid beneficiaries and to the American people that fund the program.

“We will not just accept the hollow victory of numbers covered [in the program], but will dig deeper and demand more of ourselves and of you,” said Verma. “For those unable to care for themselves, we will create sustainable programs that will always be there to provide the care you need, to provide choices and allow you to live as independently as possible. For those that just need a hand up, we will provide you the opportunity to take charge of your health care and assist and empower you to rise out of poverty and government dependence to create a better life for yourselves and your family.”

For more information regarding this article or about our services, please contact :

sbhealthcaremgmnt@gmail.com

Paul Silverio-Benet

305-975-1171