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McBrayer Blogs
Showing 62 posts in Medicare.
Kentucky’s Evolving Behavioral Health Providers
One of the most important effects of the Patient Protection and Affordable Care Act (“ACA”) is the profound change in the coverage of behavioral health services. Building on the Mental Health Parity and Addiction Equity Act of 2008, the ACA requires both Medicaid and Medicare to provide far more robust behavioral health benefits, especially in the area of substance abuse. This expansion of benefits is not without growing pains - health care providers are waking up to the new reality of a vastly expanded need for substance abuse and other mental health services as well as providers. As state Medicaid programs struggle to finance these new benefits, the need for behavioral health care providers and clinicians has become acute. This is especially true in Kentucky, where access to substance abuse care is crucial due to the epidemic of prescription drug and heroin addictions. Fortunately, however, the Cabinet for Health and Family Services has taken proactive steps to strengthen and expand behavioral health infrastructure to meet the ACA’s directives. More >
Quality Over Quantity: The Shift from Fee-for-Service to Value-Based Payment Systems
The United States Department for Health and Human Services (“HHS”) recently announced its intention to tie thirty percent of fee-for-service Medicare payments to alternative and value-based payment models by 2016. HHS hopes to increase that amount to fifty percent by the end of 2018. Currently, up to twenty percent of payments are made through alternative models, a substantial increase in a short amount of time since almost no payments were made through alternative models as recently as 2011. Two days after HHS’ announcement, a group of key health care industry stakeholders announced the formation of the Health Care Transformation Task Force, a new industry consortium making a public commitment to transition seventy-five percent of its business between now and 2020 to value-based arrangements. These developments demonstrate the shift from fee-for-service payments based on quantity of work regardless of outcome and signals a larger trend to seek quality over quantity. With the seemingly meteoric rise of value-based care, it is important to understand the ramifications of alternative payment models within the health care industry as a whole. More >
New Rule on Medicare Reimbursement for Chronic Care Management Services
In November 2014, the Centers for Medicare & Medicaid Services (“CMS”) issued a final regulation with changes intended to ensure Medicare’s payment system “reflect[s] changes in medical practice and the relative value of services, as well as changes in the statute.”[1] One of the beneficial changes for physicians is the new Medicare reimbursement of chronic care management (“CCM”) services, which began with the New Year on January 1, 2015. All providers should pay special attention to the essential requirements for chronic care management reimbursement and begin identifying eligible fee-for-service Medicare patients. More >
ENROLLMENT: A NEW ENFORCEMENT TOOL?
On December 3, 2014, CMS issued its Final Rule that addresses provider enrollment. These new rules create new tools to police provider enrollment. CMS now has the ability to deny enrollment of providers, suppliers and owners who have been affiliated with an entity that has unpaid Medicare debt. CMS has announced that this provision will help prevent individuals and entities from incurring substantial Medicare debt, leaving the Medicare program, and then re-enrolling as a new business to avoid repayment of the outstanding Medicare debt. CMS has announced that it will only enroll eligible individuals or entities if they repay the debt or enter into a repayment plan. More >
HHS OIG RELEASES FISCAL YEAR 2015 WORK PLAN
Recently, the Office of Inspector General of the United States Department of Health and Human Services (“OIG”) released its Fiscal Year 2015 Work Plan summarizing its oversight and enforcement priorities for the 2015 Fiscal Year. Here are some highlights from the Work Plan. More >
Telehealth/Telemedicine: An Opportunity for Physicians and Providers to Add a New Line of Service
The cost effectiveness of providing health care via telemedicine or telehealth promises to be an effective tool to increase coverage and reimbursement of healthcare provided remotely or through telehealth. Towers Watson, a national consulting company, recently published a 2014 study that suggests that telemedicine could save $6 billion annually for the health care industry. "Achieving this savings requires a shift in patient and physician mindsets, health plan willingness to integrate and reimburse such services, and regulatory support in all states," according to Dr. Allan Khoury, a senior consultant at Towers Watson.[1] Recent studies have assigned significant cost savings generated by telehealth use that include cost savings of $537 million per year for emergency departments using telehealth to reduce transfers and spending reductions of 7.7% to 13.3% per person per quarter in the cost of care for chronically ill Medicare beneficiaries using a health buddy via telehealth. [2] As the cost effectiveness of providing services via telehealth and telemedicine is proven, Medicare, most state Medicaid programs and commercial insurers are increasing coverage as well as reimbursement for telehealth services. State law requirements for providing telehealth and coverage differ greatly. Consequently, physicians and health care providers should be aware of the complexity of providing telehealth and its requirements, but should also incorporate telehealth services into their practices as a new way of providing services and a new line of business. More >
Changes Proposed for Anti-Kickback Statute
It has been said before—healthcare is changing. Most often providers must adapt their practices to comply with governing regulations. Sometimes, governing regulations must be revised to adapt to providers practices. And on occasion, governing regulations must be revised to be consistent with other governing regulations. This is one of those occasions. More >
New Part D Regulations Face Increased Scrutiny from Advocacy Groups & Congress
On March 10, 2014, the Centers for Medicare & Medicaid Services (“CMS”) issued a memorandum to Part D Plan Sponsors and Medicare Hospice Providers entitled, "Part D Payment for Drugs for Beneficiaries Enrolled in Hospice – Final 2014 Guidance" (“Guidance”). The Guidance, effective since May 1, 2014, requires a prior authorization process for Hospice and Part D providers to determine their respective responsibility for drug coverage. The Guidance followed a 2012 OIG report entitled "Medicare Could Be Paying Twice for Prescription Drugs for Beneficiaries in Hospice,” which found that Medicare Hospice patients’ medications were sometimes paid for by Part D rather than by the patient’s Hospice program. More >
Medicare Part D Prescribers Must Act Now
On May 19, the Centers for Medicare & Medicaid Services (“CMS”) issued final regulations which require doctors prescribing drugs for Part D patients to enroll in Medicare. In addition, the regulations establish authority for CMS to revoke a doctor's Medicare eligibility for abusive prescribing practices, among other provisions. The regulations are part of the ongoing effort to curb fraud and abuse and to improve benefits and the quality of care for seniors and people with disabilities enrolled in these programs. More >
Physicians Facing an Increased Risk of Qui Tam Suits
On April 9, the Centers for Medicare and Medicaid Services (“CMS”) released data showing physicians’ compensation for Medicare Part B billing payments in 2012. It was the first time in more than 35 years the data has been made available to the public and it unleashed a fire storm of national headlines. Most news outlets, unfortunately, failed to explain the facts behind the figures. More >