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Page 1: Volume 46 Issue 17 Fall 2016 - HFMA Metro NY · 2019-05-24 · Organization (MCO) Network Agreement Anyhow?” and “Medicare’s Settlement Conference Facilitation (SCF) program.”

www.hfmametrony.org Page 1

Volume 46 Issue 17 Fall 2016

2016 GOLF OUTING

Page 2: Volume 46 Issue 17 Fall 2016 - HFMA Metro NY · 2019-05-24 · Organization (MCO) Network Agreement Anyhow?” and “Medicare’s Settlement Conference Facilitation (SCF) program.”

2016-2017 CORPORATE SPONSORS

PLATINUM

GOLD

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BDO USA, LLP

Betz-Mitchell Associates, Inc.

Cerner

Craneware

Ernst & Young, LLP

Experian Heath/Passport

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KPMG, LLP

MCRC Group

Med-Metrix

Miller & Milone, P.C.

POM Recoveries, Inc.

Promedical

RSM US LLP

RTR Finacial Services, Inc.

Tritech Healthcare Management, LLC

CBHV - Collection Bureau

Hudson Valley, Inc.

CBIZ KA Consulting Services, LLC

Cirius Group, Inc.

Connance

Crowe Horwath LLP

Group J

Health/ROI

Healthcare Retroactive Audits, Inc.

JZanus Consulting, Inc.

NTT Data, Inc.

PhyCare Solutions, Inc.

Professional Claims Bureau, Inc.

Reimbursement Service Group, Inc.

Salucro Healthcare Solutions, LLC

Capio Partners, LLC

Computer Credit, Inc.

Garfunkel Wild P.C.

Long Island Marriott Hotel

MCS Claim Services, Inc.

MDS

Mullooly, Jeffrey, Rooney & Flynn LLP

Nassau Suffolk Hospital Council, Inc.

Navigant Consulting, Inc.

Physicians' Reciprocal Insurers

Veralon

Washington & West, LLC

www.hfmametrony.org Page 2

Page 3: Volume 46 Issue 17 Fall 2016 - HFMA Metro NY · 2019-05-24 · Organization (MCO) Network Agreement Anyhow?” and “Medicare’s Settlement Conference Facilitation (SCF) program.”

PAST PRESIDENT2014-2015 Wendy E. Leo, FHFMA2013-2014 David Evangelista2012-2013 Palmira M. Cataliotti, FHFMA, CPA2011-2012 John I. Coster2010-2011 Edmund P. Schmidt, III, FHFMA2009-2010 Cynthia A. Strain, FHFMA2008-2009 Mary Kinsella, FHFMA2007-2008 Gordon Sanit, CPA, FHFMA2006-2007 Elizabeth Carnevale

EX-OFFICIOAll Past Presidents of the

Metropolitan New York Chapter, HFMAM. Beatrice Grause, R.N., J.D., F.A.C.H.E.,

President, Healthcare Association of New York StateKenneth E. Raske,

President, Greater New York Hospital AssociationKevin W. Dahill,

President & CEO, Nassau-Suffolk Hospital Council

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Chapter Officers and Board of Directors

Metro NY HFMA Newscast Schedule

Electronic Publication Date 1/23/17

Article Deadline for Receipt by Editor 12/19/16

OFFICERS 2016-2017President David WoodsPresident-Elect Maryann J. ReganVice President Mario Di FigliaTreasurer Diane McCarthy, CPA, FHFMASecretary Donna SkuraImmediate Past President Meredith Simonetti, FHFMA

BOARD OF DIRECTORSClass of 2017

Ann M. Amato, CPA, MBA Jason GottleibAlex Balko Patrick S. Semenza, CPA, CHFPCatherine Ekbom

Class of 2018Martin Abschutz, CPA, CGMA Shivam Sohan, FHFMAChristina Milone, Esq. Andrew Weingartner, FHFMA Sean P. Smith, CPA, MBA

Newscast Committee

EDITORS:Marty Abschutz, CPA, CGMA, Editor

James G. Fouassier, JD, Esq., Assistant Editor

COMMITTEE MEMBERS:Kiran Batheja, FHFMAPaulette DiNapoliPhil Holtzman

Mary Kinsella, FHFMAWendy Leo, FHFMA

Andrew NatkinEdmund P. Schmidt, III, FHFMA

John Scanlan, FHFMACynthia Strain, FHFMA

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President’s MessageDavid Woods ...........................................................................................................................Page 5

Editor’s MessageMarty Abschutz, CPA, CGMA...................................................................................................Page 7

Calendar of Events ...............................................................................................................Page 8

New MembersRobin Ziegler ..........................................................................................................................Page 9

Committee Listings 2016-2017 ........................................................................................Page 10

Golf Outing ................................................................................Page 13, 17, 20, 22, 24, 30, 31, 32

Avoiding and Managing CMS Audits J. Stuart Showalter...............................................................................................................Page 14

Improving Registration: Ideas from HFMA Memberson Making a Positive First ImpressionEd Avis..................................................................................................................................Page 18

The True Cost of Non-ComplianceSaud Juman..........................................................................................................................Page 21

HFMA's Online Membership Directory..............................................................................Page 23

HFMA Metro NY 60th Anniversary.....................................................................................Page 25

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Now that the days of summer are gone and fall is upon us, Metro HFMA is in full force toget our Education and Social events scheduled. As of this Newscast, we had some greatseminars and social events. In September, we had the Mid-Year Reimbursement andMedicare Fundamentals seminars. Both provided great education and were well receivedby our attendees. In October, we had a webinar on Charge Capture and Charge Description Master. The big eventin October was the Region 2 Fall Institute in Turning Stone. We had several members from our chapter attendthis two-day event; it was a very successful Institute.

The social programs, as always, continue to Thrive. Our German night in July was a big hit and our Golf Outingwas always a great day!

I attended the HFMA National Fall Presidents meeting in Memphis Tennessee along with our President-ElectMaryann Regan. We had an excellent meeting and spent quality time with our other New York and Puerto Ricochapters. This year was our chapter’s turn to present a candidate for the Region 2 Executive position. Weenthusiastically presented our Past President Kiran Betheja for this role. He was elected by all thePresidents/Presidents Elect in Region 2. Kiran’s vast HFMA experience over the years and his leadership qualitieswill make him an excellent Region 2 Executive for the entire state of New York and Puerto Rico. He will proudlyrepresent our Region with National HFMA. Congratulations Kiran!

On November 3rd, we are having a Skin Cancer awareness dinner at the Davenport Press restaurant in Mineola.This is free to both members and nonmembers. This is part of our successful Knowledge is Power series, whichis bringing health awareness to the community. We have great speakers and presentations. I encourage all of youto attend!

We have been planning and continue to complete our work on the Annual Institute, which is being held on March9 and 10, 2017, at the Marriott Uniondale. We have secured great speakers and panelists with content that isgoing to be great! We also have a Winter Institute on December 1st with breakout and general sessions. Checkour website for all the details to all of these events!

I am also thrilled to announce that the Metropolitan New York Chapter now has an “app” for your smartphone.This app will allow you to see upcoming events, get notifications, import important dates for your calendar andincludes a membership directory, along with other content. This is an exciting and new technology. The app iscalled “Metro NY HFMA”. It is available in both the App Store for the IPhone and Google Play for the androidphones. It’s free, so please download it to stay informed!

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All of the above programs would not be possible without the continuous and hard work ofour dedicated members. Their dedication and commitment to this chapter is outstanding.Their hard work allows us to continue to be educated and informed. I want to thank all ofthese members for everything that they do for our chapter. We are very fortunate to havesuch a great team!

I hope to see you at one of our events. As your President, I want to make sure your membership needs are beingmet. Please contact me at [email protected] if there is anything I can do to improve your experience!

All the Best!

David WoodsPresident

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By Marty Abschutz

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I have been a member of the Metro New York Chapter of HFMA for about 36 years. I continue to be impressed bythe dedication of our volunteers. They and their attitudes are among the things that make Metro NY HFMA special.Among these folks are the current officers, the current Board, past presidents, committee chairs and committeemembers. There are even some members who are dedicated article submitters, like Jim Fouassier, Esq. I believeeveryone agrees that volunteers receive more than they give.

I mention these positions, one of which I hold (Newscast Committee Chair), to point out that there are manyopportunities for any member to become involved. It’s easy. Find an area that you’re interested in or want to findout more about. There is a comprehensive list of committees beginning on page 10 of this issue, in alphabeticalorder. For each committee, the chair (at least) is listed with a preferred means of contacting them, email orphone. If you’re looking for some guidance before contacting a committee chair directly, feel free to reach out toany member of the Board, listed on page 3, or me at (732) 735-1945 (cell), (732) 906-8700, extension 109(office) or [email protected].

One year ago, I mentioned that providers were working on and/or finalizing their next year’s budgets now. Imentioned the implementation of the Allina decision in that context. For example, I believe that many providerswould receive positive, albeit one-time, impacts on their bottom lines, should Allina be fully and fairlyimplemented. It’s one year later; no action appears imminent. I welcome any reader’s thoughts on this issue;please contact me via the email address listed above.

Also, one year ago, we announced that several industry leaders were joining together to form our first NewscastAdvisory Panel: The Intersection of Managed Care, Legal, Finance and Clinical Issues. Many thanks to Ellen Scottfor organizing this group/idea with Jim Fouassier, Esq., Liz Carnevale and Roy Breitenbach, Esq.. The AdvisoryPanel presented two thought provoking articles for your consideration: “What Good is a Managed CareOrganization (MCO) Network Agreement Anyhow?” and “Medicare’s Settlement Conference Facilitation (SCF)program.” We look forward to additional timely articles from our distinguished panel.

Among the things I think about, when editing Newscast and writing this column is, who is reading Newscast andwho is reading this column. We don’t have much of a history of “letters to the editor” at Newscast. Feel free todrop me a note, write a letter and/or an article, using the email address above. The submission deadline forWinter Newscast is December 19, two weeks after our Winter Academy.

Lastly, I extend a personal invitation to our Past President’s Dinner Dance, honoring Immediate Past President,Meredith Simonetti. This year’s event is being held on January 7 at the Sand Castle in Franklin Square, New York.I look forward to seeing you there.

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2016 IMPORTANT DATES

November 16, 2016 Free Webinar-Managing Coding,Audit & CDI

November 18, 2016 Accounting & Audit Update WithumSmith+Brown, PC1411 Broadway, NYC

December 1, 2016 Winter Academy LaGuardia Marriott

January 7, 2017 Past President’s Dinner Sand CastleFranklin Square

March 9, 2017 Joseph A. Levi Annual Institute Long Island Marriot-Uniondale

FREE Webinars (Check www.hfmametrony.org and

www.hfma.org for locations and more)

www.hfmametrony.org Page 8

HFMA Seminars provide timely, in-depth strategies and metrics to help you keep

pace with the healthcare finance topics you care about the most. View all upcoming

HFMA Seminars and register at www.hfma.org/seminars.

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The Metropolitan New York Chapter of HFMA Proudly Welcomes the Following New Members!

By Robin Ziegler, Membership Committee Chair

MetroNY HFMA is pleased to welcome the following new members to our Chapter. We ask our current membership to rollout the red carpet to these new members and help them see for themselves the benefits of HFMA membership. Encouragethem to attend seminars and other Chapter events. We ask these new members to consider joining a Committee to not onlyhelp the Chapter accomplish its work, but to expand their networks of top notch personal and professional relationships.See the list of MetroNY HFMA Committee Chairs, along with their contact information, listed in this eNewsletter.

JUNE 2016

Linda DeHartNYC Health + Hospitals Corporation

Michele M BerriosMilliman

Christopher MancusiGrant Thornton

Elijah KimSouth Nassau Community Hospital

Neha K. SangoiCerner Corporation

Graham TopolFTV Capital

Rajkumar MothiramraqVee Technologies, Inc

Timothy ClearyErnst & Young

JULY 2016

Michelle WongMontefiore Medical Center

Sweta AdhikariGrant Thornton

Lester E. GrantMount Sinai Health System

William BrownNorthwell Health

Christina WongLighthouse Guild

John W. RuthStony Brook University Hospital

Samik P PatelErnst & Young

Frances M LuciveroAetna Inc.

Michael WeaverNorthwell Health

Anyi ChenEnterprise Data & Analytics

AUGUST 2016

Edward Farrell South Nassau Communities Hospital

Jason HenkePWC

Dawn M. LombardiLong Island FQHC, Inc.

Nathalie AllamPWC

Motao SunOptum360

Jeanette TangMCRC Group

Greg Davidson

William C. RiderKPMG

John P. Bryan, CPACitrin Cooperman & Company, LLP

Robert Fitch

Adnan A KhanColumbia University Medical Center

Jamie P. Dromerhauser

Katelyn GleasonEligible Inc.

Anthony V. Argutto

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COMMITTEENAME CHAIR CO-CHAIR VICE CHAIR 1 VICE CHAIR 2 VICE CHAIR 3

ADVISORY COUNCIL Wendy Leo David Evangelista John Coster Cindy Strain [email protected] [email protected] [email protected] [email protected](516) 454-0700 (718) 206-6930 (516) 240-8147 (516) 796-3700

58TH ANNUAL Sean Smith Christian Borchert Andrew Weingartner Bob Jacobs Jim Argutto INSTITUTE [email protected] [email protected] [email protected] [email protected] [email protected]

(516) 562-6013 (315) 530-8079 516-240-8147 (516) 616-0200 ext. 201 (631) 761-1028

AUDITING John Scanlan Gordon Sanit Edmund Schmidt Joe [email protected] [email protected] [email protected] [email protected](718) 283-3911 (516) 918-7065 (516) 255-1666 (914) 681-2130

BYLAWS Donna Skura Maryann Regan Mario Di [email protected] [email protected] [email protected](516) 572-4498 (516) 576-5601 (516) 876-1386

CENTRAL Robin Ziegler Annie Lemoine Chrissy KernREGISTRATION [email protected] [email protected] [email protected]

(516) 338-1100 x314 (516) 326-0808 ext 3312 516-296-1000

CERTIFICATION Jim Petty Kiran Batheja Art Cusack John Scanlan COACHING [email protected] [email protected] [email protected] [email protected]

(516) 876-6022 (917) 603-7670 (718) 283-3911

CERTIFIED MEMBERS Kiran [email protected]

COMMUNITY Josephine Vaglio Christina Milone David Evangelista OUTREACH [email protected] [email protected] [email protected]

(516) 248-2422 (516) 296-1000 (718) 206-6930

CONTINUING CARE Christina [email protected](516) 296-1000

CORP COMPLIANCE/ Ann Amato Laurie Radler Mathew SchwartzINTERNAL AUDIT [email protected] [email protected] [email protected]

(516) 632-3405 (646) 471-7409 (646) 453-1252

CPE’s Edmund Schmidt III John Scanlan [email protected] [email protected]

(516) 255-1666 (718) 283-3911

DCMS/ Robin Ziegler Henry Serra David WoodsBALANCED [email protected] [email protected] [email protected] (516) 338-1100 x314 (516) 705-1895 (212) 979-4566

EXEC. COMM. Maryann Regan Mario Di Figlia David Woods& PLANNING [email protected] [email protected] [email protected]

(516) 576-5601 (516) 876-1386 (212) 979-4566

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COMMITTEENAME CHAIR CO-CHAIR VICE CHAIR 1 VICE CHAIR 2 VICE CHAIR 3

FINANCE/ Alex Balko Pat Semenza Tracy Roland Kwok Chang REIMBURSEMENT/ [email protected] [email protected] [email protected] [email protected] AUDIT (516) 632-3965 (718) 488-3715 (908) 377-5122 (212) 979-4324

FOUNDERS AWARDS Paulette DiNapoli Shivam [email protected] [email protected](718) 518-2064 (516) 576-1801

GENERAL EDUCATION Catherine Ekbom Annie Lemoine Henry Serra Jason Gottlieb Rachele [email protected] [email protected] [email protected] [email protected] [email protected](516) 745-0161 (516) 326-0808 ext 3312 (516) 705-1895 (646) 227-3156 (516) 296-1000

HIM/UR Stacey Levitt Annie [email protected] [email protected](646) 732-5052 (516) 326-0808 x 3312

HISTORIAN

INVESTMENT Mario Di Figlia Diane [email protected] [email protected](516) 876-1386 (516) 349-4643

LEGAL AFFAIRS Christina Milone Fred [email protected] [email protected](516) 296-1000 (516) 393-2250

MANAGED CARE James Fouassier David Evangelista Patrick [email protected] [email protected] [email protected](631) 638-4012 (718) 206-6930 (212) 430-6620

MSP Kiran Batheja Robin [email protected] [email protected]

(516) 338-1100 x314

MEMBERSHIP Robin Ziegler MARKETING [email protected]

(516) 507-5314

MEDICAL GRP MGMT. Josephine Vaglio Andrie Kazamias Art [email protected] [email protected] [email protected](516) 248-2422 (516) 918-7097 (917) 603-7670

MIS Rivka Gross Dan Corcoran[Healthcare [email protected] [email protected]] (732) 551-3338

NEWSCAST Marty Abschutz James [email protected] [email protected]

732-906-8700 x 109 631-638-4012

NOMINATING Meredith [email protected](631) 465-6877

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COMMITTEENAME CHAIR CO-CHAIR VICE CHAIR 1 VICE CHAIR 2 VICE CHAIR 3VICE CHAIR 4

REVENUE CYCLE Christian Borchert Robin Ziegler COMMITTEE [email protected] [email protected](FORMERLY PATIENT (315) 530-8079 (516) 338-1100 x314FINANCIAL SERVICES)

PPDD Meredith [email protected](631) 465-6877

WEBMASTER AND Andrew Weingartner Cindy Strain Shivam SohanPERSONNEL [email protected] [email protected] [email protected] 516-240-8147 (516) 796-3700 (516) 576-1801

PUBLIC RELATIONS Jason Gottlieb& COMMUNICATIONS [email protected]

(212) 297-4549

REGION 2 John Coster Kiran Batheja [email protected] [email protected](516) 240-8147

REGION 2 Mario Di Figlia Shivam SohanCOLLABORATION [email protected] [email protected]

(516) 876-1386 (516) 576-1801

RYAN AWARD Meredith [email protected](631) 465-6877

SOCIAL EVENTS Kiran Batheja John Coster Gordon Sanit John [email protected] [email protected] [email protected] [email protected]

(516) 240-8147 (631) 495-6596 (516) 632-3170

SOCIAL NETWORKING Phil Holtzman Art [email protected] [email protected]

(917) 603-7670

SPONSORSHIP Wendy Leo Maryann [email protected] [email protected](516) 454-0700 (516) 576-5601

YERGER AWARD Dana Keefer Michele Manuel Jonathan [email protected] [email protected] [email protected](315) 938-5624 (212) 857-5269 (212) 274-7230

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Photos selected by Marty Abschutz Photos by Dennis Hodge

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Avoiding and Managing CMS AuditsBy: J. Stuart ShowalterPublished in HFMA's Legal and Regulatory Forum, August 2015

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ROUTINE INTERNAL AND EXTERNAL AUDITING OF MEDICARE CLAIMS IS A CRITICAL STEP INAVOIDING DENIALS AND MANAGING AUDITS EFFECTIVELY WHEN THEY DO OCCUR.

Hospital and health system finance leaders can take important steps—such as self-audits and accurate documentation—to limit denials and avoid CMS audits. This proactive approach is also helpful to successfully navigate the claim appealsprocess.

To Avoid Audits, Perform Audits“To avoid CMS audits you have to do your own audits,” says attorney Michael Schulze, of the law firm Sullivan StolierSchulze, LLC, in Lafayette, Louisiana. “And you have to use the findings to provide ongoing education and training ofcoders, billers, and clinicians.”

This may seem elementary, but Schulze and Joseph Koons, managing director of revenue cycle for Centra Health, Inc.,Lynchburg, Va.—who discussed denials and audits during a recent HFMA Forums webinar—repeatedly stress theimportance of internal and external compliance audits, use of comparative data reports (e.g., Program for EvaluatingPayment Patterns Electronic Report, known as PEPPER reports), and regular training to avoid simple coding mistakesand keep up to date on billing rules. “Make internal and external auditing routine so that it doesn’t get pushed aside bythe daily grind,” Schulze advises.

“The government gets about $8 in return for every $1 it spends on fraud and abuse enforcement, including audits, so theaudit contractors are not going to go away and denials will continue,” Schulze says. Talking about compliance is notenough. Regular internal audits and periodic external compliance checks demonstrate to the entire staff that theprovider is committed to accurate and complete documentation and billing. “It is critical for coders to feel comfortable,to be encouraged, to query physicians for more details when a medical record is incomplete or does not support the codebeing assigned. They can only code what is supported by the record and need to have the provider’s full support whenthey correct a code to a lower level,” Schulze says.

Physician education on proper documentation is also critical. Schulze gave the example of an inpatient psychiatrichospital with physicians routinely listing Alzheimer’s disease as the admitting Axis I diagnosis. “However, the patientswere sent to the hospital because of their disruptive behavior. Unless there was conclusive evidence that the behaviorwas due solely to their Alzheimer’s, the disease would more appropriately be listed on Axis III as a chronic condition.Even though the care was the same and medically appropriate, routinely listing Alzheimer’s on Axis I caused theprovider’s statistics to fall out of the industry norm and triggered an extensive ZPIC audit.”

One caveat: Coders may not intentionally lead a physician to documentation just to enable higher reimbursement; theyonly may ask objective questions such as, “Did you mean … ?” or “Can you be more specific about ... ?”

Denials Will Occur and Appeals Will FollowNo matter how hard we try, however, there will always be claims denials, and the process begins with a request forrecords. Schulze and Koons stress that it is essential to organize the medical records carefully and make it easy for theCMS auditors to find important information in the record. They suggest doing this by taking the following steps.

• Reviewing every chart for completeness and uniformity of format• Stamping every document page with identifying numbers (e.g., Bates stamping—a method for placing identifyingnumbers and date/time marks on images and documents)

• Providing a table of contents of the chart with Bates stamp page ranges• Highlighting relevant portions

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• Using attestations for incomplete sections• Responding to all government requests in a timely manner• Transcribing hard-to-read physician notes

After the records are submitted, a Medicare contractor reviews them—a process that often takes a year or more—andissues an audit results letter and a demand for repayment. Auditors rarely rule in favor of providers’ at this stage, andthus begins the first level of appeals.

First level appeals. This first appeal is a request for redetermination by the auditor, and it can usually be handled in-house. “It may not be cost effective to hire outside counsel at this stage as long as the provider has trained personnel toprepare the appeal,” Schulze says.

He recommends appealing every wrongful denial because the government may later attempt to use those denials toestablish the provider had “imputed knowledge” of possible overpayments. “Providers have to decide if a denial is worthappealing, but they shouldn’t just look at the cost of appealing. Even if they accept the denials due to cost, thegovernment will consider the denials legitimate and may use those denials to argue that the provider should have beenaware of a pattern of improper claims. This could come back to haunt you,” Schulze says.

Second level appeals. Once the redetermination decision has been issued—usually an affirmation of the originaldenial—comes the second level appeal, a request for reconsideration by a Qualified Independent Contractor (QIC).Koons and Schulze recommend engaging the servicers of an experienced healthcare attorney at this stage and includingthe provider’s entire argument and basis for appeal, including statistical arguments if the agency extrapolated the claimsto determine their repayment demand. These points will form the administrative record for a possible administrative lawjudge (ALJ) decision at the next appeal level. Because of the well-publicized backlog of appeals at the ALJ level, Schulzeand Koons are beginning to see greater provider success rates for second-level appeals, but there is still no way for thesystem to keep up with the demand, they say. “We’ve occasionally had cases where we got 90 percent of the denialsoverturned at the second level, but the increased success rates are still pretty sporadic,” Schulze explained.

Third level appeals. The third level appeal is made to the ALJ and is supposed to take approximately 90 days.Unfortunately, providers are experiencing significant delays before their ALJ appeals are heard and the situationcontinues to get worse. For example, in 2013, the average delay was 220 days; 2014, 415 days; and 2015, 661 days. Thesituation shows no signs of improving. The delay jumped to 795 days for the first quarter of 2016 and 861 days for thesecond quarter of 2016.

“The system is broken and providers are being forced to shoulder the burden. They don’t have any choice but to waitbecause so many claims get overturned by the ALJ. But the excessive delays require providers to pay back money theydesperately need while they wait years to win their appeals before the ALJ,” Schulze says. “Many providers are facingbankruptcy because they cannot afford to repay large overpayments due to statistical extrapolations, even under anextended repayment plan, while they wait to get their money back when the ALJ overturns most of the denials.”

Proactive Steps Minimize PitfallsKoons and Schulze concluded the webinar with these recommendations:

• Create a dedicated audit team under the compliance department that includes revenue cycle personnel, billers,coders, compliance and legal staff, and nursing and physician advisers to audit all clinical documentation byphysicians and other clinicians.

• Establish a physician review program with respected physicians who can help improve medical recorddocumentation and advise on appeals; Koons uses employed physicians for this purpose and reports that amongother benefits this has improved his system’s case mix index.

• Use audit tracking software to monitor all appeals because government payers and private insurance have differentprocesses and timelines, and it’s impossible to track them all manually.

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• Use PEPPER Reports—Microsoft Excel files summarizing provider-specific Medicare data for target areas oftenassociated with improper Medicare payments—to help flag potential problem areas to be dealt with before denialsoccur.

• Consider education to be a never-ending journey for clinicians, billers, coders, and other key personnel.• Recognize that the “pay and chase” system of Medicare reimbursement is an unfortunate way of life, but its pitfallscan be minimized.

J. Stuart Showalter, JD, MFS, is a contributing editor for HFMA.

Interviewed for this article:Joseph Koons is managing director, revenue cycle, Centra Health Inc., Lynchburg, VA, and is a member of HFMA’sVirginia-Washington D.C. Chapter.Michael R. Schulze is managing member, Sullivan Stolier Schulze, LLC, Lafayette, LA.

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Photos selected by Marty Abschutz Photos by Dennis Hodge

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Improving Registration: Ideas from HFMA Memberson Making a Positive First ImpressionBy: Ed AvisPublished in HFMA's Revenue Cycle Forum, October 2015

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PATIENT REGISTRATION CAN BE IMPROVED WITH PRACTICAL IDEAS LIKE PROVID ING USEFULINFORMATION AND D IRECTIONS TO UNIQUE AMENITIES SUCH AS VALET PARKING AND PAGERSYSTEMS IN WAITING ROOMS.

A hospital registration area is like the foyer to a home. The experience visitors receive there may significantly impacttheir overall impression of the hospital. How can a hospital improve the registration experience? HFMA membersanswered that question, which was posted recently on the HFMA Forum listserv. Here are the best ideas from thatexchange:

The First Encounter: PreregistrationTwo respondents suggested that preregistration is an important step in creating a pleasant registration experience. Thepreregistration should include useful information that will improve the patient experience and assist patients with theirfinancial responsibilities, such as providing instructions for arrival and providing patients with information about theircopayments and deductibles.

Parking Lot ConnectionSeveral ideas from the listserv responses concern patient arrival. For example, valet parking is a good way to create agood first impression. Other ideas include having volunteers in golf carts drive patients from their cars to the front doorof the hospital and having someone with a tablet computer meet patients in the parking lot and launch the registrationprocess right there.

Pleasant GreetingsGreeting the patients warmly—with smiles and eye contact—is also important. One respondent said that in her hospital,if patients or visitors need directions, a staffer walks those individuals to their destination, rather than just explaininghow to get there or pointing them in the right direction. Also, patients should be moved quickly to a registrar, so thatthey perceive that their waiting time is short.

One respondent mentioned that her hospital uses a pager system to alert patients when it is time for them to be served.The pager makes it unnecessary for staff to call out names, protecting patient privacy.

Comfortable SpacesNaturally, having a pleasant atmosphere in the registration area is important. Among the ideas raised to create apleasant space is playing soft music; displaying fresh flowers and live plants; and offering coffee, water, and snacks.

One respondent noted that she is familiar with a hospital that has an actual shopping mall—with stores and arestaurant—right off the lobby.

Available InformationPatients and family members in the registration area are often scared and confused, so, in some cases, the best way tocreate a good impression is to provide information. Two listserv respondents mentioned that they provide welcomepackets—including a letter from the CEO—to incoming patients. The packet can also include a physician directory, acopy of patients’ rights and responsibilities, contact numbers and e-mail addresses for managers in each department,and other phone numbers to call if there are concerns or problems.

Understanding StaffInteractions between staff and patients and family members play a key role in establishing comfort levels. Staff should bewell educated on hospital matters, and they should carefully explain the paperwork being presented, rather than rushing

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patients to provide their signatures. The staff should also remember that many patients and visitors may be hearingimpaired, so they should speak clearly, enunciate well, and look directly at the person when speaking.

Sometimes patients or family members have concerns that need to be brought to another level. One way to address theseinstances is to establish a dedicated phone line to handle patient complaints or concerns that routes directly to keyexecutives.

For more information on joining HFMA’s Forums and gaining access to the listserv, visit hfma.org/forums.Ed Avis is a freelance writer based in Oak Park, Ill., who contributes regularly to HFMA publications.

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Photos selected by Marty Abschutz Photos by Dennis Hodge

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The True Cost of Non-ComplianceBy: Saud JumanPublished in hfm blog, April 2016

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With the constant emergence of new standards andregulations across all areas of health care, hospital andhealth system leaders are working hard to ensure that theyhave effective compliance programs in place. Compliance isan active process that entails staying abreast of regulations,maintaining relevant policies and procedures, implementingcontinuous training and professional development, anddealing with discipline and breaches when necessary. Theprocess is arduous, but the consequences for noncomplianceare exponentially worse.

According to a 2014 survey, about one-third of healthcareproviders estimate their total annual budget for complianceto be $1 million to 5 million.a Thirty-eight percent state thattheir compliance budget has increased in the past year, and52 percent state that it has stayed the same. The cost ofcompliance makes a compelling argument for investment ina strong program. Across industries, a compliance programcosts about $222 per employee, versus the $820 peremployee for non-compliance.b Two factors are responsiblefor the high costs in the latter case: poor patient outcomesand litigation.

Costs of Poor Patient OutcomesA 2010 study examined the costs of Methicillin-resistantStaphylococcus aureus (MRSA) infections among patientswho acquired the infection as a result of a nurse’s lack ofcompliance with a hand hygiene policy.c The study found thata 200-bed hospital incurs $1,779,283 annually in MRSA-infection-related expenses, directly attributable to handhygiene noncompliance. A 1 percent increase in handhygiene compliance resulted in annual savings of $39,650for the hospital.

Costs of LitigationIn 2014, New York-Presbyterian Hospital and ColumbiaUniversity paid a combined $4.8 million to the Office of CivilRights (OCR) to settle a 2010 HIPAA violation. The breachoccurred when a physician tried to deactivate a personalcomputer that was connected to the hospitals’ sharednetwork. The protected health information (PHI) of 6,800patients, including vital signs, medications, and lab testresults, was compromised. The OCR’s investigation foundthat neither hospital had conducted an adequate riskassessment or documented a risk management plan for theirIT systems that access PHI. Neither did NewYork-Presbyterian Hospital have appropriate policies and

procedures in place for authorizingaccess to its database. The hospitalspaid the settlement, and both agreedto a corrective action plan.

In addition to the financial costs of noncompliance, there areintangible costs as well. A lack of compliance can lead to aloss of accreditation, resulting in a detrimental impact onthe hospital’s reputation. If a provider has had a breach ofPHI of more than 500 residents of a state, media outletsmust be notified, further damaging a hospital’s reputationand potentially bringing about a loss of trust among patients,staff, and the wider community. Recent research found that65 percent of patients would consider changing providersafter a HIPAA data breach.d

A well-organized approach to managing compliance is themost critical component to mitigating risk exposure. Overthe past five years, both the industry and most leadinganalysts have deemed effective compliance programs andstrategies such as policy management to be the nucleus of asound governance, risk, and compliance strategy.

Implementing an electronic, cloud-based policy managementprogram is one proactive method to invest in compliance.Such a system can aid a hospital each step of the way, fromwriting policies and procedures that reflect current standardsand regulations, to training and disciplining employees, andmanaging breaches. There are, unfortunately, no shortcuts toexecuting an effective compliance program. It requirescontinuous monitoring, evaluation, and improvement. But intoday’s healthcare environment, an investment in compliancepays off in spades.

Saud Juman is the President and CEO of PolicyMedical inRichmond Hill, Ontario, Canada.

Footnotesa. “State of Compliance 2014,” pwc, 2014.b. Carroll, G., “Study: Non-Compliance Problems Cost 3X MoreThan a Strong Compliance Program,” Fast Track, Jan. 21, 2013.c. Cummings, K.L., Anderson, D.J., Kaye, K.S., “Hand HygieneNoncompliance And The Cost Of Hospital-Acquired Methicillin-Resistant Staphylococcus Aureus Infection,” PubMed, April 2010.d. “65% of Patients Would Avoid Companies That Suffered a HIPAABreach,” HIPAA Journal, March 24, 2015.

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HFMA'S ONLINE MEMBERSHIP DIRECTORY

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Have you visited HFMA's Online Membership Directory lately? Log in at www.hfma.org/login/index.cfm. When youselect "HFMA Directory," not only can you search for members of your chapter, you can also search for all yourHFMA colleagues by name, company, and location-regardless of chapter! Using an online directory instead of aprinted directory ensures that you always have the most up-to-date contact information.

While accessing HFMA's Online Membership Directory, you can view your current contact information and makeedits to your profile. You can also see products you have ordered, events you have registered for, your CPE credits,your Founders points, and more!

It's vital that HFMA has your correct information, so please take a moment to review your record now. By doingso, you'll ensure that HFMA continues to provide you with valuable information and insights that further yoursuccess.

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