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Rural Health Clinics

PQRS - Double Standard


In the 2016 Medicare Physician Fee Schedule, CMS sought to clarify the definition of "eligible professionals" or EPs for purposes of the Physician Quality Reporting System (or PQRS) initiative. RHC services were clearly exempt from the PQRS initiative but the regulations were unclear as to whether services provided by EPs outside the RHC benefit (submitted via a 1500 claim form) would still be subject to the PQRS initiative. To address this uncertainty, CMS wrote that "EPs who practice in RHCs and/or FQHCs would not be subject to the PQRS payment adjustment."  

At first glance, this was a welcome clarification for the RHC community. However, we were receiving reports from RHCs that they were nevertheless receiving PQRS paperwork and being subject to the PQRS payment adjustments. In response, we decided to investigate the discrepancy to see why certain RHCs were seemingly still subject to PQRS. Unfortunately, the results of our investigation revealed that PQRS eligibility is still going to be an issue that we need to solve. The good news is that we found out what the problem is. The bad news is that we will need CMS to change their processes to fix it. read more 

Proposed Chronic Care Mgm Benefit 

On July 8, 2015 CMS published the proposed rule for the 2016 Medicare Physician Fee Schedule. They took comments on it until Sept. 10th.  CMS will likely issue the final rule (official policy) around November 1, 2015 with an EFFECTIVE DATE for the new policy of Jan. 1, 2016. We believe the following provisions are of interest to RHCs.

As a part of their broader goal to integrate and coordinate services, CMS is proposing to extend the Chronic Care Management benefit to RHCs. Beginning on January 1, 2016 RHCs who furnish a minimum of 20 minutes per month of chronic care management (CCM) services to qualifying patients may begin billing for these services.  RHCs would also be subject to all the other requirements of providing CCM services such as having up-to-date EHR software, maintaining an electronic beneficiary care plan, and beneficiary consent.  You can find a primer on the current CCM benefit here.   read more
2015 NARHC Fall Institute

The RHC Conference --  15 Breakouts, 22 Sessions


AGENDA: Starting a New RHC; Maximizing Front End Collections; Survey & Cert; 

Legislative Update; RHC Change of Ownership Status & CHOWs; Telemedicine;

RHC Billing 101 and Advanced; 7 Provider Based Requirements; Task Management; Cost Reports 101 and Advanced; How to Manage A Small Practice; ICD-10-now what?

Top HIPAA Hazards & How to Avoid Them; Updates to Shortage Areas; Annual Evaluation & Peer Review, Going Beyond the Requirements;  Meaningful Use 1, 2, & 3 - Conquering Your MU Challenges!; etc.   read more

Funding Opportunities 

1.   The 2016 National Health Service Corps (NHSC) Students to Service Loan Repayment Program application cycle is now open!  All fourth-year medical students (both allopathic & osteopathic) planning to pursue primary care  are eligible to apply. Students may receive up to $120,000 in tax free loan repayment in return for three years of full-time service at an NHSC-approved site in a Health Professional Shortage Area (HRSA) after residency. 

2.   On Thursday, September 24th, the Delta Regional Authority will join with HRSA to host a free Federal Health Funding Opportunities Workshop in Memphis, TN.  Prospective applicants for HRSA grants in the Delta region will get detailed information on upcoming funding opportunities, how to apply, and strategies for writing a responsive application.  Attendance is free and includes breakfast and lunch.   read more 

Physician Fee Schedule 2016


In the 2014 Medicare Physician Fee Schedule (MPFS), the Centers for Medicare and Medicaid Services (CMS) introduced a new payment to cover non-face-to-face Chronic Care Management (CCM) services. Prior to the publication of the Medicare physician fee schedule, CMS contacted NARHC to inform us that CCM benefits would not be extended to Rural Health Clinics (RHCs) until 2016 due to the incompatibility between the CCM payment structure and the RHC reimbursement structure. CMS expressed interest in collaborating with NARHC to find a way to extend the CCM services to RHCs.
During the 2014 comment period, NARHC submitted multiple payment options to CMS that we believed best captured the interest of RHCs. Upon evaluating our comments, CMS again reached out to us with their ideas on how to extend CCM benefits to RHCs. After consulting with over a dozen stakeholders on the billing and operational side of the RHCs, NARHC provided CMS a final rank-ordered list of payment options that were the most attractive.  read more 
Locum Tenens 

Locum tenens is a billing arrangement that allows a temporary physician to come into a practice on a short-term basis and bill using the billing number of the physician he/she is replacing.  In the case of the RHC, a locum tenens physician can come into the practice and the practice can bill for services rendered using the RHC billing number.  However, because the RHC bills for an RHC encounter you are not really using the billing number of the physician who is temporarily away.  So in a technical sense, there really is no "locum tenens" billing for RHC services (non-RHC services, yes, but RHC services, no). 
Also, Medicare rules only provide for a physician to serve as the "locum" provider.  There is no mechanism in the Medicare policy for a PA or NP to serve as a locum provider for Medicare billing purposes.     read more 
NARHC Membership Sale

If your clinic is a 1st-time NARHC member, join now to receive the remaining months of 2015 (free) plus all 12 months of 2016 for the one-year price! The 1st-time rate is also discounted! Associations, Consultants and Governmental entities are also welcome to join, however, the sale is just for 1st-time RHCs. For rates see the Membership Application. If unsure of member status, call us at 866-306-1961 for a quick lookup.

NARHC also offers a group discount (add. RHCs after the first join for $130 ea.) & discounted Joint Memberships with 3 State Assns (CA, MO, TX)! 
   read more 
Medicaid Enrollees More Likely to Frequent RHCS
A recent experiment conducted by researchers from the University of Pennsylvania provided evidence to determine that Rural Health Clinics (RHCs) offer more appointments to Medicaid enrollees than any other non-safety net provider. The researchers suggest that the cost-based reimbursement structure is the leading explanation to why RHCs dive into the Medicaid pool more than others.  
First, the researchers aimed to identify whether practice location in an urban or rural setting affected the allowance of appointments for Medicaid enrollees. They found clear evidence that obtaining an appointment for a Medicaid enrollee was easier in a rural setting than in an urban setting. Rural providers offered appointments to Medicaid enrollees 80% of the time, while urban providers were less than 60% of the time (Figure 1). read more 
Helping Paul Help Himself

LIVE WELL PROGRAM - Paul, a patient at the St. Helena Family Health Center, smiled ear to ear as he spoke of his transformation. He was smiling, outgoing, and amazingly, his body was more up-and-down-straight than it had been and he seemed to be moving with ease. He even looked younger than he had in the past, when he had been stooped over and used a cane due to his severe chronic pain when walking or standing. "I owe it all to the clinic's Live Well Program. I really mean that, I owe it all to Live Well!"   

Experiencing severe lower back pain for years, partially due to scoliosis, Paul's continual pain caused him to limp. Getting up out of bed or a chair was horrifically painful, and he couldn't stand for long periods of time. His life seemed to be dictated by his pain. He also sank into a deep depression due to all of the troubling health issues and pain. Distressed because he had been on pain meds for so long and he was still dealing with the pain and side effects of meds.       read more 
Transitional Care Management within the RHC
There has been much confusion with the Transitional Care Management CPT codes 99495 and 99496.  There are several requirements for Clinics to be eligible to bill these codes.  MLN ICN 908628 is the CMS Publication that gives all the requirements for these services to be billed. Some of the key components included in these are: 
  • There must be interactive contact with the beneficiary/or caregiver and the provider within 2 business days following the discharge to the community setting;
  • Depending on complexity, the patient must be seen by the provider within 7 or 14 days of discharge;
  • A review of the discharge summary, continuity of care documents, diagnostic tests & treatments reviewed;
  • Interaction with other care professionals;
  • Provide education to beneficiary, family, guardian and/or caregiver;
  • Identify and communicate with agencies and community services used by the beneficiary;
  • And there are others.       read more  
Social Engineering: A Hacking Story
Typically when we think of hacking, we think of technical hacks. Some hooded, socially rejected fiend sitting in the dark corners of the world pumped up on way too much caffeine plotting the demise of your systems through some cleverly thought out computer virus. Although these types of hacks do occur, at a surprisingly high prevalence in the healthcare industry, the scarier type of hack is social engineering. This is a real threat that is often not addressed in staff training sessions or our operating procedures. And that is just how the social engineers of the world want it.
So what is social engineering, any way? Social engineering is the charming way of hacking into your data. Hackers rely on human interaction, often trickery, wit, and charm, to break into otherwise secure environments. Because it relies on the weakest link in any technical chain, the human element, it is one of the biggest threats in security.  Let's look at an example of how a social engineer hacker may gain access to your systems: read more
Top 10 Questions Regarding PB Clinics

1.  What is a provider-based clinic?  
Provider-based refers to a Medicare billing status and process for physician services that are provided in a hospital outpatient clinic. A provider-based clinic must meet Medicare provider-based regulations.

2.  Must a provider-based clinic be on the main campus of the provider?  
No, a provider-based clinic may be on the same campus as the main provider or located off campus. The CMS definition of campus requires the clinic to be within 250 yards of the main buildings.    read more 

Cost Reporting - It's Never Too Early to Start Preparing


Besides being the greatest basketball player to ever live, Michael Jordan once said, "It's not the will to win that matters, it's the will to prepare to win that is important." That sentiment is true when it comes to preparing your Medicare cost report as well. We have several clients that wait until they get a letter from Medicare cutting off their Medicare payments to think about the cost report & then everything is a panic to complete the report as quickly as possible & get the Medicare money turned back on.

Not only is this stressful & slows cash flow, as it normally results in missed opportunities to increase reimbursement for the clinic. Medicare Bad Debt, Influenza and Pneumococcal logs take time to complete accurately and are often lost in this process. Plus, the ability to accrue bonus payments to owners is lost as well. (They must be accrued & paid within 75 days of year-end).  read more  


Although it is getting late, we thought we'd share some recent information from CMS on finalizing plans for using ICD-10 codes for services provided on or after October 1, 2015. REMEMBER -  all health insurance claims (Medicare, Medicaid, Commercial, etc.) with a date-of-service of October 1, 2015 and later, must use ICD-10 codes.  Failure to use ICD-10 on claims with a date-of-service of October 1 or later will likely result in a rejection of your claim.    read more 
In This Issue
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NARHC Fall Institute
Oct. 27-29, 2015 (T-Th)
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St. Louis, Missouri
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