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Letter from the NARHC Executive Director
Preventive Services in the RHC Setting
by Bill Finerfrock
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As part of the Affordable Care Act, Congress expanded the scope and type of preventive services that could be covered by Medicare. Subsequent to the adoption of that policy, CMS published various documents indicating that these preventive services were billable as "stand alone" visits when performed by a physician, PA or NP in a federally certified Rural Health Clinic.
Earlier this year, CMS lawyers concluded that because of the way the new preventive services benefit was established in the Medicare statute, RHC visits solely for the purpose of receiving one of the stand-alone preventive services would NOT constitute an RHC visit and therefore could not be billed for and paid by Medicare. Unfortunately, there was nothing in writing expressing this new policy and it was difficult to understand (particularly in light of the various published statements to the contrary) whether this was a carrier specific issue or a Medicare-wide problem.
In late May, one of the CMS Contractors published what it stated was the "official" policy of CMS. Preventive services would not be billable in the RHC setting because they were not considered "medically necessary." As if to add further inflame the issue, the Contractor indicated that if these preventive services were performed in a non-RHC setting they would be considered "medically necessary." read more
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CMS recently published several rule changes which implement Reform in RHC Regulations. The following is a synopsis of changes which will most affect RHCs.
Effective JULY 1st, 2014:
- Independent Contractor Rule: --- §491.8(a)(3) was revised to permit an RHC to have an NP or PA provide services under contract to the RHC, so long as the RHC has at least ONE employee who is an NP or PA. This rule clears the way for RHCs to contract with mental health providers as well. This was an issue before and slowed the growth of this much needed service.
Effective JULY 11th, 2014:
- Onsite Physician Rule: --- §491.8(b) has been revised to delete the requirement formerly at §491.8(b)(2) for a physician to be present in the RHC or FQHC at least once every 2 weeks. Instead, whatever the State Regulations require must be followed. This recognizes that many of the physician's required functions may be performed remotely via electronic means, but does not remove the requirement that a practitioner, whether physician or non-physician practitioner, must be present at all times the RHC or FQHC operates. Provisions formerly at §491.8(b)(1)(i) - (iii) have been renumbered to §491.8(b)(1) - (3), but are otherwise the same. read more
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West Virginia Medicaid - Being Vigilant
Prior to 2001, Medicaid RHC payments were directly linked to the Medicare RHC payment rate. Whatever a clinic's Medicare rate was, as determined by the clinic's cost report--that automatically became the RHC's Medicaid rate. In 2001, Congress decoupled the RHC Medicare and Medicaid rates and established a process for independently calculating the RHC Medicaid rate. Under this process, states had the option of either establishing a clinic-specific "default" rate or developing an alternative payment model for RHCs in the state.
West Virginia opted to develop an Alternative Payment Model which was acceptable to the RHC community in West Virginia (the federal law stipulated that if the state opted for the alternative, it had to be agreed to by the RHC community in that state). That same law established a similar process for Federally Qualified Health Centers.
Subsequent to adoption of the RHC payment model, some FQHCs in West Virginia sued the state over their Medicaid payments & the case took several years to make its way through the court system but late last year, the Court ruled that West Virginia had erred in how they calculated the FQHC payments & Health Centers were owed millions of dollars in back payments. read more
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NARHC 2014 Fall Institute
OCTOBER 22-24, 2014 -- Reno, Nevada
A conference "For and About" RHCs
22 Sessions, 13 Breakouts: Legislative Update, Scope of Practice Issues, Starting a New RHC, The Early Years of the RHC, Management Issues (for PBs & Independents), Expansion through RHC Acquisition (the Transaction, Asset Valuation, Physician Compensation, CHOW, Medicare/Medicaid Rate Setting & Implementation of Billing as an RHC), Establishing Quality (PCMH, Process Improvement, Quality Initiatives, & Patient Satisfaction), Practice Management (Cost, Operational, Benchmarking), Survey & Recertification, All Things Compliance, Stage 2 Meaningful Use, RHC Billing (Basic & Adv), Cost Reporting (for PBs & Independents), Insurance Credentialing, MAC Discussions (Novitas, Cahaba, Noridian, Ask the Experts (possible topics: Time Studies, Audit Timelines & How to Survive One, Bad Debt Documentation, Differences between Certification & Accreditation, Medicare Secondary Payer Info. & the EMR).
Early Bird rates in effect now!!! NARHC members save even more. Earn CEU credit. We'd love to have you! read more
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So, now I have to do this, too?
PRINCIPALS OF OUTPATIENT DIAGNOSIS CODING
The advent of EHRs has presented a challenge for providers which even pushes the limits of EHR implementation and adoption-- CODING! Until now coding was in a world of its own. The provider was responsible for making an assessment or formulating an impression but the job of finding the appropriate code fell to a coder or a biller. Now, the diagnosis code is selected within the record. The challenges are many.
Coding correctly can be problematic because most of us are unaware that there are Official Guidelines for ICD-9 Coding which are published by the Center of Disease Control (CDC). The guidelines have not been revised since 2011 in anticipation of
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Top Ten Documentation Assessment Findings:
SIGNIFICANT COMPLIANCE CONCERNS OR REVENUE OPPORTUNITIES?
The following Top Ten Revenue Cycle Opportunities pertains to consistent observations found during coding & documentation improvement (CDI) assessments. Highlighted are those that represent significant compliance concerns or revenue opportunities. You can perform a quick self-analysis for your organization by ensuring the answer to the following questions is, "YES"!
1) Does your EHR have built-in mechanisms to prevent inappropriate use?
2) Is your clinical staff documenting infusion start and stop times?
3) Does documentation for E/M services paint a true picture? read more
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Behavioral Health in the RHC:
GREAT IDEA!
The provision of behavior health services in the RHC is a fantastic service to offer, especially in a rural area where these services are usually very limited. By offering behavioral health in the RHC, the perceived stigma of seeing a counselor is greatly reduced. No one knows why the patient is in the RHC: physical or behavior needs. The patients are in a clinic, not a mental health agency. With the change in the outdated co-insurance and maximum benefit rules from CMS, it is now more economically feasible to offer these services. read more
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NARHC Board of Directors
CANDIDATES WANTED: 3 OPENINGS
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3-Year Term: January 2015 - December 2017. Candidates must be current NARHC members. The ideal candidate will have leadership ability and extensive Rural Health Clinic knowledge. The candidate will assist in growing the NARHC Association Membership by being an advocate and it is hoped that he/she will cultivate a relationship with their particular State Association. It is preferred but not mandatory that candidates be located in a state not already represented on the Board.
Board members are expected to attend the 2 NARHC conferences (2½ days long in March & October) and be present on 1-hr./mo. conference calls. Additionally, members should plan to serve on the occasional subcommittee. Time commitment is usually 2-4 hours/month. read more
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RHC Goes Green During Facility Expansion
In 2012, Riverside Family Medicine (RFM), a single-provider Rural Health Clinic in Southern Louisiana had far outgrown its 1440 square foot facility. We were desperately in need of a larger space and decided to build a new facility. As CFO, I was particularly concerned about the fiscal impact of increasing staff & physical space without an immediate revenue increase. A self-proclaimed student of green building techniques & technology, I embarked on a quest to design the most eco-friendly & economical practice possible. Initially, I hoped our new clinic would be the first LEED (Leadership in Energy & Environmental Design) certified RHC in the state, but once aware of the cost of certification we opted to established our own goals. The overall aim was to simply implement as many energy efficient, eco-friendly components as possible, while simul-taneously requiring each component provide a rigorous return on investment. read more
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CHOW & HPSA Designation
A CASE STUDY
A small physician group may move within their town (Town "A") to go to work for the community hospital in the hospital's out-patient clinic. The physician group is in a certified RHC, and their relocation will move them across the county line into another county that has is a current HPSA shortage area. They are moving about four miles from their present location near downtown to the outskirts of Town "A".
The hospital does not want to pursue having them as a RHC, maybe because it is a critical access hospital and it may not have the expenses to shift into a provider based RHC. So it does not want to do a CHOW. read more
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Novitas Address Change
Effective July 25, 2014, mail received at the Novitas Solutions Camp Hill P.O. Boxes/Addresses will no longer be forwarded to the Mechanicsburg P.O. Boxes/Addresses. You can locate the appropriate address on the Contact Us page of their website, www.novitas-solutions.com. Please start using the appropriate Mechanicsburg P.O. Boxes/Addresses now.
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Discounted Employment Screening
NARHC MEMBER BENEFIT
CertifiedHealthcare offers NARHC member organizations a 20% (or greater) discount on background screening, drug testing, employment verification, and related services. This NARHC partner works with a wide range of employers, more than half of the nation's colleges and universities, various not for profit organizations, healthcare institutions, law firms and others. Certified-Healthcare's services are available through an online system for applicant tracking with a fast turnaround time. read more
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Health Insurance Coverage of
Low-Income Rural Children Increases
Prior to the passage of the Children's Health Insurance Program (CHIP), about one in four low-income rural and urban children (family income below 200% of the federal poverty level) were uninsured in a given month. Using data from the Medical Expenditure Panel Survey, this study found that in the years following CHIP's implementation health insurance coverage and continuity increased among low-income children-particularly for those living in rural areas. By CHIP's maturity, coverage for rural children improved so much that their uninsured rate dropped below that of urban children (14% compared to 20%, respectively). read more
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Rx for Rural Childhood Safety:
KEEP MEDICINES UP AND AWAY AND OUT OF SIGHT
Every year, more than 60,000 young children end up in emergency departments after getting into medicines or vitamins that were left within reach. According to the Centers for Disease Control and Prevention (CDC), this number has increased by 20 percent in recent years - spanning rural communities to cities. read more
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Preventing Acetaminophen Overdose
More than 50 million Americans use an acetaminophen-containing medicine each week. And while the vast majority use it safely and appropriately, acetaminophen overdose is a leading cause of acute liver failure. While many overdoses are intentional (e.g. suicide attempt), nearly half are associated with unintentional overdoses-people accidentally exceeding the total 4,000mg maximum daily dose. Research shows three common dosing mistakes underlie unintentional acetaminophen overdoses: read more
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Upcoming Events
NARHC Fall Institute
October 22-24, 2014
Atlantis Casino Resort Spa
Reno, Nevada
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