June 14, 2013
Issue No. 1
In This Issue
Relaxed Rule for Decendents
Notice of Privacy Practices
BCBS Filing Limits Enforced
Do EHRs Lead To Upcoding?
Continuing Eductation
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New Employee 

IPC welcomes our newest employee, Kathy Martin. Kathy has been in the medical billing field for 8 years. She recently moved from Florida to be closer to her family in the Grand Rapids area.

On January 25, 2013, the Office for Civil Rights (OCR) of the Department of Health and Human Services (HHS) published its Final Rule of modifications to the 1996 HIPAA act. These amendments became effective on March 26, 2013 and will be enforced beginning September 23, 2013.

We are highlighting two of these amendments which we excerpted from the 6/3/13 article by Connie Ditto, Esq., taken from the May/June issue of HBMA Billing.

Relaxed Rule for Decedents
The Final Rule eased the burden on providers regarding the disclosure of a deceased person's PHI to others. Specifically, it clarified that providers may disclose PHI to "family members and others who were involved in the care or payment for care of the decedent prior to death, unless doing so is inconsistent with any prior expressed preference of the individual that is known..." So long as the provider has "reasonable assurances" that the individual was involved in the decedent's care or payment for same, the provider is not required to investigate whether the person who seeks PHI is the "personal representative." HHS declined to place the burden of proof upon the individual seeking the information, but also noted that providers who are not comfortable disclosing PHI to an individual due to questions about the individual's relationship to the decedent are not required to do so.
Notice of Privacy Practices

Providers should be cognizant of both the requirements for revising their Notice of Privacy Practice (NPP) and the manner in which the revised document should be provided to patients. Among other revisions, the NPP now needs to include a statement advising the patient that he or she has a right to be notified of a breach of unsecured PHI. HHS opined that such a statement is meant to "provide helpful context for individuals should they later receive a breach notification," and will not "cause individuals unnecessary concern" or create unfounded fear that providers are not appropriately safeguarding PHI.

Further, although providers are not required to re-issue hard copies of their revised NPP to all patients, providers "must post the revised NPP in a clear and prominent location and have copies of the NPP at the delivery site." Alternatively, providers are permitted to post a summary of the NPP "so long as the full notice is immediately available (such as on a table directly under the posted summary) for individuals to pick up without any additional burden on their part. It would not be appropriate, however, to require the individual to have to ask the receptionist for a copy of the full NPP."

BCBS Filing Limits Strictly Enforced As Of May 24, 2013 

Blue Cross Blue Shield of Michigan requires claims to be submitted within 180 days from the date of service. If a claim is submitted after the submission deadline, BCBS will not offer any special handling or filing extensions, and will deny payment.

Do EHRs Lead To Upcoding?

The OIG's 2012 work plan raised concerns about identical documentation for evaluation and management services, made easier by EHRs' cut-and-paste function . Now CMS is concerned that doctors, either intentionally or unintentionally, are taking advantage of EHR automation to bill higher-level services. EHR advocates state that EHRs increase the accuracy of documentation through the use of templates and other prompting mechanisms. Critics, on the other hand, say that the ease of "cut & paste" documentation from previous visits can cause upcoding. Marilyn Tavenner, Acting CMS Administrator, has stated that providers can expect CMS to undertake "small, targeted audits" to address upcoding.


Bottom line, make sure that what is documented in the EMR was actually done and was medically necessary. Periodically, whether you use an EHR or manual record system, have an outside coding firm perform an audit to verify the accuracy of your documentation and CPT and diagnosis codes billed.

Continuing Education 
IPC Employee, Sandy Reatini, Billing Supervisor, attended the following:
  • 5/15/13 MMBA (Michigan Medical Billers Association) Meeting in Flint: WPS Medicare updates for 2013, tricks of the trade for orthopedic billing, medical record auditing, and 2013 NCII guidlines. 


Please let us know if there are any upcoming events your office is interested in attending with IPC.
About Us
If you have any questions regarding this newsletter, you can contact us at:

         Mary Ellen Duffy
         Patricia Nevala pat@ipcbilling.com

or call us at 616-459-6867 or 800-606-1455

Please feel free to forward this newsletter to your staff and peers.


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