mi acep straight talk nov. 2017 · presence of the teaching physician during procedures and e/m...
TRANSCRIPT
MI ACEP Straight Talk Nov. 2017
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2019 MPFS Part II—Plus
Compliance, Balance billing
& Audit Hot Topics
Nov. 13, 2018
Ed Gaines, JD, CCP
Chief Compliance Officer
Emergency Medicine
Division
Zotec Partners, LLC
Greensboro, NC
877-271-2506
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MI ACEP Straight Talk Nov. 2017
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Time to retire Paul & my annual tradition as he
moves south…..
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(Instead we’ll start a new
tradition/new age—much more
calming)
➢The Ludington, MI
lighthouse and harbor,
or the state park.
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http://www.shorelinemedia.
net/ludington_daily_news/
webcams/ludington-daily-
news-harbor-
cam/html_9d8697f4-876a-
11e3-a68d-
001a4bcf887a.html
MI ACEP Straight Talk Nov. 2017
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Objectives and Outline for discussions:
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➢Discuss several of the key changes in this year’s 2019
final Medicare Physician Fee Schedule (MPFS)
➢What’s happening on MAC & Medicare audit front
➢Discuss several compliance hot topics : front & back
end issues.
➢Brief discussion on the out of network (OON) and
balance billing controversies now that there are no less
than 3 federal proposals.
➢Q & A throughout or at the break
Medicare’s TP rules have an extensive history:
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MI ACEP Straight Talk Nov. 2017
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ACEP’s Coding & Nomenclature Comm. (CNAC) medical student
FAQ—performance requirements vs. documentation
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https://www.acep.org/administration/reimbursement/reimbursement-
faqs/teaching-physician-guidelines-
faq/#sm.0000qy15nptfcdp211h59u0h5s3nr
Major changes in teaching physician
documentation stds.
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https://www.law.cornell.edu/cfr/text/42/415.174
MI ACEP Straight Talk Nov. 2017
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Perhaps the performance requirements have not changed
(yellow/top) but documentation has changed (teal/bottom)
➢“We proposed to add new paragraph (a)(6) to
§415.174 to provide that the medical record must
document the extent of the teaching physician’s
participation in the review and direction of
services furnished to each beneficiary”
➢“[T]he revised paragraph would specify that the
presence of the teaching physician during
procedures and E/M services may be
demonstrated by the notes in the medical records
made by a physician, resident, or nurse ”
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Other proposals NOT adopted in the 2019 MPFS
➢-25 modifier proposal to cut by -50% the
reimbursement of the OP & office E/Ms:
➢CMS savings at 6.7M RVUs or $241,468,000
➢Reallocation of RVUs to maintain budget neutrality?
➢MedPAC supports but CMS will study.
➢Price transparency: CMS had specifically called out ED,
radiology and anesthesia on OON balance billing & how
CMS could advance transparency to Pts.
➢CMS rec’d comments & did not show direction
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MI ACEP Straight Talk Nov. 2017
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Illinicare claims that their policies
follow “CMS/Nat’l CCI guidelines”
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Case study: IBC implements the 50% E/M cut on -25 modifier
procedures for commercial & Medicare Advantage— Part B News
(PBN) 8/28/17
➢ IBC, QCC Ins. Co., Keystone Health Plan and AmeriHealth
➢Article states policies apply to a provider’s office—not POS specific.
➢25 states & DC impacted
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MI ACEP Straight Talk Nov. 2017
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CMS proposal to eliminate the restriction on
same group TIN billing 2 E/Ms on the same DOS.
➢ “As for all other E/M services except where specifically noted, the
Medicare Administrative Contractors (MACs) may not pay two E/M
office visits billed by a physician (or physician of the same specialty
from the same group practice) for the same beneficiary on the same
day unless the physician documents that the visits were for
unrelated problems in the office, off campus-outpatient hospital, or
on campus outpatient hospital setting which could not be provided
during the same encounter” (Pub. 100-04, Medicare Claims
Processing Manual, Chapter 12, Section 30.6.7.B.”
➢CMS did not finalize its proposal (@557) in the
final 2019 MPFS.
➢Could have implications for FSEDs in future.
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Medicare compliance & DOJ
enforcement
Hot topics for 2018-19
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MI ACEP Straight Talk Nov. 2017
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Key Agencies/Players in compliance and fraud and
abuse (F&A)
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ExecutiveBranch
Secretary of Health and
Human Services (HHS)
The Centers for Medicare & Medicaid Services
(CMS)**
HHS Office of The Inspector
General
(OIG)
US Attorney General
The US Attorney’s Office (USA)
Medicare Administrative
Contractors
(MACs)
1. F&A recovers $11.60 for every $1
2. **Fraud Prevention System”= over Bs in $ saved.
3. FPS= 22% of fraud investigations, FierceHealthcare 10/2/17
CMS’ Plans for the future:
➢“Currently, the Medicare program only
reviews less than 3/10 of 1% of the nearly 1.5
billion Medicare claims that CMS pays
annually.” CMS Administrator Seema Verma,
July 25, 2018, speech to the Commonwealth
Club of CA
➢The goals going forward are to “prevent
inappropriate care on the front end.”
➢Medicare is adding over 10K seniors per day.
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MI ACEP Straight Talk Nov. 2017
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Prepayment reviews of CPT 99285 in addition
to TPE process for WPS J8B
➢ 100 CPT 99285s were selected prepayment
review in IN & MI.
➢ 3 services were allowed as billed
➢ WPS is using that as justification to
conduct 99285 prepayments for all.
➢ No extensions for prepay review for
records-- https://goo.gl/houQGP
➢ Palmetto GBA/RR Medicare also conducting
prepayment reviews:
➢ https://goo.gl/pK7rqS
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Uniform Program Integrity (UPIC) Contractor—
AdvanceMed for MI
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https://www.nciinc.com/about-
us/advancemed/
MI ACEP Straight Talk Nov. 2017
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What are the main federal laws regulating physician
payments & hospital/physician relationships?
➢Federal False Claims Act (FCA) (31 USC Sec.
3729-3733).➢ Ultimate “hammer” for feds. as minimum penalties are $5,500 per
gov’t payor claim.
➢Anti-kickback Statute (AKS) (42 USC Sec. 1320a-
7b(b).
➢Physician Self Referral Law (Stark) (42 USC Sec.
1395nn)
➢EMTALA (42 USC Sec. 1395dd)➢http://www.acep.org/News-Media-top-banner/EMTALA/
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➢Treble damages (3 X the overpayment).
➢99285 ($176) less 99284 ($120) (2018)= $56 X 3= $168
➢Overpayment is the ED Group’s liability.
➢ FCA has specific “anti-retaliatory” provisions in
addition to employment discrimination laws that
protect against retaliation.
➢“Relators”=Qui Tam provisions of the FCA
➢15-30% of the FCA recovery.
➢+ attorney’s fees.
In addition to the FCA penalties …
MI ACEP Straight Talk Nov. 2017
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From Modern Healthcare, 5/24/16, on the US
DOJ allegations against Prime Healthcare
➢“Multiple witnesses who worked at Prime hospitals told federal
investigators that Prime Chairman and CEO Dr. Prem Reddy would
criticize emergency department doctors who passed up
opportunities to admit Medicare beneficiaries; request more hours
for emergency department doctors whose patients had high rates of
admissions and fewer hours for those whose patients had low rates
of admissions; and tell doctors to find ways to admit all patients
over age 65. Witnesses also allege that he told emergency doctors
that insured patients who spent more than two hours in the
emergency department waiting for test results should be admitted,
but that was not necessarily the case for uninsured patients.”
➢ http://www.modernhealthcare.com/article/20160524/NEWS/160529956
➢Case may become “poster child” for DOJ’s “Individual
Accountability Policy”, a/k/a the “Yates Memo”: individual
monetary sanctions + exclusion for responsible executives.
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MI ACEP Straight Talk Nov. 2017
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“Denial ain’t just a river
in Egypt” M. Twain
➢Karin Berntsen, former Director of Performance Improvement at
Alvarado Hospital Medical Center
➢Ms. Berntsen will receive $17,225,000 as her portion of the
settlement amount.
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https://www.justice.gov/opa/pr/prime
-healthcare-services-and-ceo-pay-65-
million-settle-false-claims-act-
allegations
Here’s another qui tam based on HMA’s
admission practices—by and ED physician group.
➢Drs. T. Mason & S. Folstad’s and
their group, Mid-Atlantic
Emergency Medical Associates
(MEMA) qui tam against Health
Management Associates (HMA).
➢MEMA was terminated by HMA at
2 of their hospitals for refusing to
order tests and admit Pts w/out
medical necessity.
➢Q&A with Dr. Mason.
➢http://www.epmonthly.com/www.
epmonthly.com/features/current-
features/sins-of-admission/
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MI ACEP Straight Talk Nov. 2017
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Large ED group in CLT
settles qui tam 9/2018
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➢HMA Sr. Execs. set 15-20%
admission rate benchmarks for
EDs across their system.
➢+50% for Medicare Pts. benchmark
➢ED physician exec. told ED
physicians “you’re going to admit
20% or you will be fired” in Carlyle
PA hospital.
➢The Carlyle hospital entity plead
guilty to criminal fraud and was
sold.
➢HMA was acquired by CHS.
➢CHS agreed to a “non-prosecution
agreement” (NPA)
Case study: medical directorships
➢ED context: whether
directorships are
based on fair market
value (FMV)
➢Important to have
excellent legal and
accounting advisors.
➢Directorships that are
not FMV raise Stark
and Anti-kickback
issues.
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https://www.beckershospitalreview.com/legal-
regulatory-issues/upmc-hamot-cardiology-practice-
pay-20-7m-to-settle-whistle-blower-
lawsuit.html#disqus_thread
MI ACEP Straight Talk Nov. 2017
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Case study: if in non-ED settings like urgent care clinics (UCCs),
new vs. established Pt issue is …(well) HUGE!
➢New vs. established Pt primer—it is
clinician specific and NOT TIN/EIN
specific.
➢Hospital acquired cardiologist
group.
➢Productivity bonus based on
wRVUs if they exceeded targets.
➢CCO + certified coder told group to
bill Pts as new since becoming W-2s
of hospital.
➢ Physician questioned it--$123K
settlement
➢New/est. is not relevant to the ED
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Case study: Back end compliance issues—ACA’s stat. mandate for
repayment of gov’t refunds w/in 60 days of “identification”
➢FERA statute 2009—failure to
refund is “a reverse false claim”
➢ACA 2010: statutory requirement
of 60 days w/ 6 year look back.
➢“Recoupment P&Ps alone are not
enough”—must have a Q/A
process including audits.
➢This case… “despite repeated
warnings….”
➢Whistleblower: former employee
of the medical group➢ https://www.justice.gov/usao-mdfl/pr/jacksonville-
cardiovascular-practice-agrees-pay-more-440000-
resolve-false-claims-act
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MI ACEP Straight Talk Nov. 2017
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Sen. Howard Baker’s famous line from Watergate— “what did they
know and when did they know it”--the so-called 60 day rule:
➢“[CMS] believe[s] that contractor overpayment
determinations are always a credible source for other
potential overpayments.” CMS-6037-F
➢ Contractors—MACs and ZPICs—are including in letters
that the clinicians should voluntarily identify additional
overpayments that are the subject of their letter
notification. Report on Medicare Compliance 10/2918 at 2
➢Controversial issue but CMS contractors are giving
clinicians explicit notice—like it or not.
➢Clinicians who are appealing overpayments may wait
until appeals are exhausted before further investigation
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Medicare MAC TPE & Appeals
Hot topics for 2018-19
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MI ACEP Straight Talk Nov. 2017
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MAC initiated Targeted Probe & Educate Medical Reviews
(TPEs), nationwide 10/1/17
➢MACs to conduct medical reviews (MRs), e.g. outlier analysis.
➢20-40 claim probe MR of provider/supplier claims
➢MAC letters will outline the probe & educate process
➢Up to 3 rounds or review including individualized education during a
round to address specific issues
➢MACs to phase out all other medical record reviews—not RACs.
➢Non-responses are counted as “errors”
➢ https://www.cms.gov/Regulations-and-
Guidance/Guidance/Transmittals/2017Downloads/R1919OTN.pdf
➢Strategies: 855 Medicare enrollment addresses are current + follow
timelines + take the education/use it to educate
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3 rounds and then
extrapolation?
➢If claim error rate is
at or above 20%,
then clinician goes
to the next round
per Palmetto GBA.
➢Per discussions w/
MACs & CMS, MACs
will mail TPE letter
to the practice
location/hospital.
➢EDPMA has
requested that they
also mail to the pay
to address
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MI ACEP Straight Talk Nov. 2017
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TPE Notification Letter Example—MI MAC, WPS
➢MAC will offer
“education” to individual
clinician.
➢Then the clock begins
on appeal rights—same
as Medicare appeals
generally
➢Process is new to the
MACs & to clinicians.
➢CMS to give providers
add’l chances to submit
records for CERT review,
Transmittal 800 June ‘18
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E-GlobalTech Comparative Billing Report
(CBR)
➢7/1/16 thru 6/30/17 DOS
➢3 categories of review:
1. % of 99285s
2. % of E/Ms w/ -25 mod.
3. Ave. allowed charges for Part B svs.
➢ Intent is “education only”
➢“Peers” are all clinicians billing ED E/Ms, e.g. > 130,000 clinicians with allowed charges included in this study.
➢Jan. 2018 webcast
➢ https://www.cbrinfo.net/sites/default/files/2018-01/cbr201709-webinar-recording.mp4
➢General link to the 99285 review:➢ https://www.cbrinfo.net/cbr201709
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MI ACEP Straight Talk Nov. 2017
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Case example: Comparative
Billing Reports (CBRs)
CPT 99285 and -25 modifier
cases
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Case Example: CBR letters
➢Multiple factual & potentially
analytical issues w/ CBRs.
➢Flurry of activity Q1 & 2 2018
but has been quiet since—16K
ED physicians contacted
➢Issues:
➢ # of ED clinicians?
➢ Definition of “peer group”
➢ Medicare Nat’l Summary Data
File comparison?
➢ CBRs leading to Medicare
MAC TPE audits
➢ TPE audits may become full
stat. sample extrapolation
audits or pre-payment reviews.
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MI ACEP Straight Talk Nov. 2017
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Summary of key TPE points: from EDPMA’s RCM
workshop in May 2018
➢2 Medicare MAC (Noridian and FSCO) medical
directors & a VP of medical review from FSCO.
1. MACs are targeting the highest variances from a
peer group;
2. “Education” session w/ clinician is NOT an
opportunity for rebuttal by the clinician/RCM staff;
3. MAC web portals are best practice to submit
records & to track the TPE review—despite what
the MAC letter may say for record submission.
4. e-Global Tech is education only & not referral to
MAC per MAC medical director.
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➢ Critical to know
that recoupment by
the MAC occurs on
Day 41 (unless the
1st appeal is filed in
30 days) even
though there are
another 70+ days to
appeal.
**AIC=Amount in
Controversy
https://www.gpo.gov/f
dsys/pkg/FR-2016-09-
23/pdf/2016-23002.pdf
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Medicare Part B FFS 5 Level Appeal Process:
180 days to file
120 days to file
60 days to file
60 days to file
60 days to file
InitialDetermination
RedeterminationAIC** = $0
60 day time limit
Administrative Law Judge (ALJ)AIC =$160
1
90 day time limit
Department Appeals BoardAIC = $160
90 day time limit
US District Court AIC=$1,600
3
ReconsiderationBy QIC, AIC = $16060 day time limit
First Level of Appeal
Second Level of Appeal
Third Level of Appeal
Fourth Level of Appeal
Fifth Level of Appeal
MI ACEP Straight Talk Nov. 2017
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So what’s the cost/benefit of appealing?
➢Why not just write the check for
overpayments and be done w/ it?
➢Answers:
➢When Part B providers appealed, > 60%
succeeded at 1-4 level appeals. (Source: Part B
News, 10/6/14)
➢Mitigating risks of—
➢Progressive Corrective Action (PCA) & Stat.
Sampling.
➢Extrapolation.
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Extrapolation can mean a small
overpayment becomes multi-claim & year.
➢Extrapolation defined: method of forecasting the
results of an audit sample to the universe of
claims from which the sample was drawn, and
project an error rate, e.g. 5%, across all MCA
claims
➢The Medicare statute does NOT permit
extrapolation unless:
1. “a sustained or high level payment error”, OR
2. “documented educational intervention” has
failed to correct the payment errors. 42 USC
Section 1395ddd(f)(3)
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MI ACEP Straight Talk Nov. 2017
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Reasons for appealing MAC/RAC
findings:
➢The decision to use extrapolation cannot be
challenged on Medicare appeal or in the federal
courts, 42 USC 1395fff (d)(3), 42 CFR 405.926 (p)
and MPIM 8.4.1.2.
➢The extrapolation methodology to determine
the overpayment is subject to challenge on
appeal and in the courts.
➢The MAC/RAC methodology is presumed valid,
and burden of proof is on the provider.
➢CMS Ruling 86-1.
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OIG &
“extrapolation”
➢73 IP & 8 OP
claims
➢IP
overpayment=
$1.3M
➢OP
overpayment=
$15K➢ https://www.modernhealthcare.co
m/article/20180206/NEWS/1802099
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Appeal backlog will be resolved eventually—it’s
the federal gov’t “do as I say, not as I do”
➢After 5 solid years of
non-compliance w/
federal statute, US
District Ct ordered
HHS to come into
compliance w/
federal law by the
end of FY 2022!
➢AHA and hospitals
case was filed in
2014.
43
https://www.aapc.com/blog/44595-
medicare-to-eliminate-appeals-backlog/
CMS’ Part B National Summary Data File for Specialty 93
(EM docs): FP, IM & Peds. are not in these figures
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MI ACEP Straight Talk Nov. 2017
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2017 & historical MI data (note the Maize &
Blue color scheme ;)
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JAMA Internal Medicine Study, Oct. 2018 as data
to show the “shift to the right” ED E/Ms
➢8 years of Aetna patient care data, 20M pts.
➢Low acuity visits to the ED < 36%
➢Retail clinics > 214%
➢Urgent care clinics > 119%
➢Also an ACEP RC White Paper on the
causes/reasons for the ED E/M “shift to the right”
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https://jamanetwork.com/journals/jamainternalmedicine/article-abstract/2698143
MI ACEP Straight Talk Nov. 2017
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Out of network (OON) & balance billing
issues & payor “whack-a-mole”
Hot topics for 2018-19
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What is a “balance bill”?
➢Clinician “charges” vs. the health plans’
“allowable” vs. “in network allowables” and “out
of network (OON) allowables”
➢Applies when patients see an out-of-network
provider, especially at an in-network facility
➢States do not restrict billing patient “cost
sharing”, e.g. co-insurance, deductible or co-
payments
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MI ACEP Straight Talk Nov. 2017
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The difference between:
1. the out-of-network provider’s “usual &
customary” (U&C) charge and
2. the amount reimbursed by the insurance carrier
for an out-of-network service
U&C CPT 99285 Charge: $800
OON Insurance “Allowable” $223
Balance $577
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What is a “balance bill”?
NJ case study:
the “garden state”
➢Coalition of clinicians fought
against this bill for > 10 yrs.
➢No minimum benefit std. (MBS)—
“reasonable reimbursement” as
determined by health plans.
➢Horizon BCBS announced Sept.
that standard was 110% of
Medicare.
➢No EM access to arbitration b/c of
the way the standard was written.
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http://www.roi-
nj.com/2018/06/01/healthcare/mur
phy-signs-out-of-network-bill-still-
the-subject-of-contention/
MI ACEP Straight Talk Nov. 2017
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3 federal bills on OON services that could
impact EM
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Summary of each proposal
➢Sen. Cassidy (R-LA) “discussion draft”
➢Bipartisan Senators’ “Health Care Price Transparency Initiative”—Sens. M Bennet (D-CO), C. Grassley (R-IA), T. Carper (D-DE), T. Young (R-IN) & C. McCaskill (D-MO) (now to be replaced).
➢Why this proposal may have more “juice” vs. others.
➢Reimbursement standards: OON services for EM would be the > of1. Average in network rates; or,
2. 125% of the median allowable benefit based on a non-profit “benchmarking database” specified by the state .
➢“Allowable benefit” is in-network allowables.
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MI ACEP Straight Talk Nov. 2017
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Sen. Hassan (D-NH) & Sen. Shaheen (D-NH) bills
➢Hassan’s Senate bill 3592:
➢Bans OON billing ED care & other
care where Pt notice & consent
not obtained.
➢NO minimum benefit std (MBS).
➢“Baseball arbitration” (ADR)
where the health plan & clinicians
disagree on reimbursement.
➢ADR may consider in-network
rates, Medicare and “Gould
criteria” in determining OON
reimbursement.
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➢Shaeen’s Senate bill 3541
➢OON balance billing banned above a rate determined by the state.
➢State may set rate at:1. 125-200% of Medicare
(higher rate for critical access areas);
2. 80% of charges per a charges database (not defined); or
3. In-network rates.
➢Default rate if not set = Medicare or rate set by feds.
Out of network (OON) Updates: pro-forma on how ED would be impacted under the Cassidy formula
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State: Allowable benefit data from FH for
2018 GA and LA and 2017 for PA
Senator Cassidy's Proposal: 125% of
the allowable benefit
Medicare Fee Schedule (using
highest for
consisitency/comparison)
Cassidy Proposal As a Percentage of
Medicare
LA (high as a % of Medicare)
99283 $269 $63 426%
99284 $450 $119 378%
99285 $756 $176 429%
99291 $275 $281 98%
GA (mid)
99283 $224 $63 355%
99284 $350 $119 294%
99285 $522 $176 296%
99291 $419 $281 149%
PA (low) (2017 FH allowed amounts data)
99283 $123 $63* 195%
99284 $162 $119 136%
99285 $295 $176 168%
99291 $329 $281 117%
*CMS 2018 values were used as FH data
for LA and GA are from 2018
MI ACEP Straight Talk Nov. 2017
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Pro-forma analysis on blended rate formulas—
using state wide FH data
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CPT Levels &
CC
5 states ave.—
OH, GA, CO,
NV & LA
Ave. at 80th percentile
FH & 125% of median
allowable, as % of CMS
Ave. at 60th percentile FH
& 125% of allowable, as
% of CMS
99283 GA, NV & OH 633% 575%
99284 GA, NV & OH 567% 521%
99285 GA, NV & OH 577% 527%
99291 CO, GA & NV 290% 223%
2019 is expected to be very active w/ state
based OON bills
➢GA, MA, NM, NV, OH, PA, VA & WA bills
expected early 2019.
➢Lessons from 2017-18.
➢ACEP has an entire OON toolbox on its website--https://www.acep.org/topics/out-of-network-
billing/#sm.0000qy15nptfcdp211h59u0h5s3nr
➢New laws passed in 2018 in AZ & MO (effective
1/1/19), NJ (8/29/18) and TN.
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MI ACEP Straight Talk Nov. 2017
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Update on Anthem lawsuit & new JAMA study
➢ACEP and MAG sued
Anthem in fed. ct. summer of
2018 over “non-emergent”
diag. list.
➢New JAMA study by Drs.
Chou, Gondi et al. published
Oct. 2018:➢ If Anthem diag. lists were
implemented by commercial health
plans, 1 in 6 ED pts would be
impacted & possibly denied care.
➢ Of the folks impacted by the list,
over 40% of Pts. received
“substantial ED care”
57
https://jamanetwork.com/journals/jama
networkopen/fullarticle/2707430
Use this case the next time a health plan
implements a diagnosis list policy & says
claims will be reviewed by physicians
➢For nearly 3 years, former
Aetna medical director Dr.
Ken Linuma said he never
once read the patient’s
chart.
➢He admitted the same in a
sworn deposition in Gillen
Washington case—who is
suing Aetna for denying
coverage for IVIG
infusions.
➢https://www.cnn.com/2018/02/
11/health/aetna-california-
investigation/index.html
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“And now
this”
59
“I am not a clinician but these injuries sound
like prudent lay-person presentations to me”
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Summary:
➢2019 MPFS has documentation changes—careful that the TP
performance standards do not unintentionally decline.
➢ED admission practices/ hospital observation vs. IP continue to
be “hot topics” in Medicare fraud & abuse enforcement;
➢Learn from the enforcement case studies.
➢MAC TPE audits have suffered growing pains but may have
educational benefit—both ways.
➢Out of network (OON) & balance billing restrictions may be
coming to MI by way of federal law—MI may act to set its own
standard.
➢“Whack-a-mole” with the payors continues!
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Contact information:
Ed Gaines, JD, CCP
Chief Compliance Officer,
Emergency Medicine Div.
Zotec Partners
Greensboro, NC
919-641-4927
Follow me on Twitter:
@EdGainesIII
http://twitter.com/EdGainesIII
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MI ACEP Straight Talk Nov. 2017
32
TO HECK W/ THAT “NEW AGE” STUFF—GO BLUE!!!!
DOESN’T PAUL LOOK GREAT IN THAT HELMET!
63
Appendix—2 NJ reps are trying to repair the
damage from their OON bill
64
https://ww
w.beckersh
ospitalrevi
ew.com/fin
ance/new-
jersey-bill-
aims-to-
clarify-out-
of-network-
billing-
rules-5-
things-to-
know.html
MI ACEP Straight Talk Nov. 2017
33
AHA, HFMA & AHIP Guide on Surprise
Medical Bills
65
http://www.hfma.org/consumer
guide/
Appendix: sample
MAC TPE letter
66
MI ACEP Straight Talk Nov. 2017
34
Appendix: CMS’ effort to
make hospital and physician
charges transparent
67
http://dcmedicalnews.org/ne
wsletter/2018-10-03/4-
2018,%2010-2-
CMS%20FAQs-Req-
Hospital-Public-List-
Standard-
Charges.pdf?mc_cid=1d19a
57568&mc_eid=7c3357bba1