With the July 12, 2018 release of its proposed Medicare Physician Fee Schedule for 2019, CMS further opened the door for use and reimbursement of Remote Patient Monitoring (or Remote Physiologic Monitoring, "RPM") services. In doing so, CMS recognizes the role that new communications technologies play in increasing patient engagement and reducing unnecessary costs.
Read MoreThis article discusses how you can lower your risk through email encryption, thereby saving your healthcare practice or organization from an expensive data breach. Email encryption can help your organization protect against the most common form of data breach and better comply with HIPAA standards.
Read MoreTwo Final Rules issued by CMS in November 2017 opened up entirely new avenues for reimbursement of Remote Patient Monitoring services in 2018, creating the potential for better patient outcomes and a boost to a medical practice's bottom line.
Read MoreLast week, CMS issued a Proposed Rule suggesting changes for Year 2 of the Quality Payment Program ("QPP"), established under the Medicare Access and CHIP Reauthorization Act of 2015. The changes are aimed at reducing administrative and financial burdens of the QPP on physician practices, particularly small independent practices and practices serving rural communities. Per CMS, the Proposed Rule "continues the slow ramp-up of the Quality Payment Program by establishing special policies for Program Year 2 aimed at encouraging successful participation in the program while reducing burden, reducing the number of clinicians required to participate, and preparing clinicians for the CY 2019 performance period."
Read MoreBefore signing an employment contract, it is crucial to understand the details of your compensation package. Often, things are not as straightforward as they may appear, and small details may make a big difference to your take-home bottom line and your lifestyle. Before you sign on the dotted line, consider both the cash and non-cash components and evaluate what is most important to you.
Read MoreIn Part Three of the MACRA series, you’ll learn about Advanced Alternative Payment Models (APMs) and the requirements for participating in this track, along with how doing so will affect your Medicare payments for 2017 and beyond.
Read MoreHave you decided which MACRA participation option your practice will choose in the 2017 transition year? What you choose now (and how you implement) determines your payment adjustment for Medicare Part B billings in 2019 and beyond. In the second blog post of our MACRA series, we talk about the Merit Based Incentive Payment System (MIPS), and what it means for physicians.
Read MoreThe Final MACRA Rule relaxed the more stringent proposed requirements for 2017, so whether you choose to dip your toe in the water or take the full-on MACRA plunge, now is the time to get MACRA-ready and avoid reimbursement penalties. What does MACRA mean for your practice? That's a question we can help answer.
Read MoreLast week, Nixon Law Group attended the Virginia Medical Group Management Association (VMGMA)‘s fall meeting in Williamsburg, and we were lucky enough to sit in on a session by the dynamic and talented Elizabeth Woodcock (of Woodcock & Associates). It was a whirlwind session on the key changes in the 2017 MPFS Proposed Rule, and we wanted to pass along all of the juicy details.
Read MoreAs physician revenues decline, and medical practices are feeling the pressure of the shift to value-based payment, more physicians are choosing to add ancillary services to their practices to boost revenue. Ancillary services are healthcare services provided by a clinician that are in addition to or complementary to basic medical or surgical services. Examples include medication dispensing, radiography, weight-loss services, in-office diagnostic testing, nutrition counseling, alternative treatments, such as acupuncture and massage, physical therapy, immunotherapy, mental health counseling, urgent care, cosmetic (“med spa”) services, and many more.
Read MoreDespite the risk of experiencing a HIPAA breach exceeding 89%, fewer than half of healthcare organizations have formal incident response plans and procedures. When an actual or suspected breach occurs, it is vital for covered entities and business associates to have a simple, streamlined, and expeditious plan to respond. These breaches can be anything from a lost thumb drive or laptop to a sophisticated cyber-attack, but a good breach response plan will be flexible enough to work in a variety of circumstances. There are standard responses that the Department of Health and Human Services’ (HHS) Office of Civil Rights (the government entity that polices HIPAA compliance) (OCR) expects to see when health data has been compromised. These include protocols for investigation, mitigation, and notification of affected individuals.
Read MoreHealthcare reform and the shift from fee-for-service to value-based reimbursement has brought a host of new complexities to the day-to-day practice of medicine. As a result, more and more physicians are choosing to be employed by a hospital or health system, rather than owning and running their own practice.
While physician employment is not a new concept, the relationship between employed physicians and their employers is shifting as the model for healthcare reimbursement shifts. Employers not only expect their physician employees to meet or exceed RVU (“Relative Value Unit”) production goals, but also to move the needle on certain quality metrics that reflect the overall health of the patient population. This new paradigm creates unique challenges and risks for employed physicians, and is all the more reason for physicians considering employment to pay close attention to what their employment contracts actually require of them.
Read MoreOn May 23, 2016, the Department of Labor passed long-awaited overtime pay rules, modifying the Fair Labor Standards Act (FLSA) for the first time in 12 years. The overtime rules apply to all industries across the country, but will like have a major impact on the healthcare industry, especially independent physician and other clinician employers. The rule significantly increases the amount of money an employee must be paid for that employee to qualify as exempt from the overtime pay rules. This means a much larger pool of employees that now qualify for overtime pay (an additional 4.2 million Americans), and likely significant cost increases for employers. Some healthcare employers will be hit harder than others.
Read MoreIn the latest article in Diagnostic Imaging, NLG Partner Rebecca E. Gwilt offers advice on how medical practices can manage vendor relations. Read the full article here: http://www.diagnosticimaging.com/partnerships/how-be-efficient-vendor-relations
Read MoreThe biggest takeaway from this proposed Rule? Physicians should start planning for this change IMMEDIATELY to best position their practice for financial sustainability. This rule establishes the new Quality Payment Program (QPP) framework, which consists of two new pathways for provider evaluation and payment—the Merit-based Incentive Payment System (MIPS) and participation in Advanced Alternative Payment Models (APMs). The QPP stems from the changes passed as part of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), passed in April of last year. Participation in one of the QPP pathways will form the new basis for the level of payment for services Medicare Part B providers will receive. CMS will begin collecting data beginning in 2017. They will analyze the data for one year, and then use the data to adjust Medicare payments for eligible providers starting January 1, 2019.
Read MoreThe CMS Center for Medicare and Medicaid Innovation (CMMI) has spent the last 6 years testing out a variety of models for value-based care and payment--the Medicare Shared Savings Program (MSSP) and other ACO models, the Bundled Payments for Care Improvement (BPCI) Initiative, the Comprehensive Care for Joint Replacement Model, and various Medicaid and CHIP initiatives. As the Administration doubles down on its commitment to shift payments away from fee-for-service (FFS), it continues to innovate, building programs to align incentives to person-centered, comprehensive, high quality health care. In that vein, in July of this year, CMS will begin taking applications from practices for participation in a new CMMI program: the CPC+ program.
Read MoreContracts are long and complicated, often missing or obscuring key information a provider needs to make an informed decision about whether to agree to the contract’s terms. In addition, insurance companies are incredibly resistant to modifying their contracts. Contract negotiation employees often say “no” to even minor changes, expecting that the provider will back down. It takes a significant amount of pushing back to gain access to the staff with the power to make changes. Many providers, we know, simply negotiate the fee schedule, and sign the payer contract without a full understanding of its content. We think that is a mistake—these contracts can have legal and financial impacts unrelated to the fee schedule rates, which outlive the contract itself. But, it's not always clear what parts of these gargantuan documents medical practices should be looking for to reduce their risk. In this post, we describe specific types of provisions to read carefully and consider, how easy it will be to change them, and why you may be agreeing to more than the language inside the contract:
Read MoreLearn what kinds of questions you and your medical practice team should be asking when negotiating insurance contracts
Read MorePQRS… VPM... MU… MIPS. These letters represent a complex world of quality reporting requirements that physicians must adhere to if they want to maximize their reimbursement and ensure the sustainability of their practice.
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