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MIPS in a Minute – Hospital-based Physiatrists

The Medicare MIPS Program is unnecessarily complex and unwieldy for hospital-based physiatrists, who often have minimal support staff. Failure to report MIPS in 2024 can result in a 10% Medicare PENALTY in 2026. However, successfully reporting MIPS in 2024 can result in a 10% BONUS in 2026! The 10% penalty or bonus has a tremendous impact on hospital-based physiatry practices, because 60% to 70% of patients have Medicare as their primary insurance. There are many resources available – from the CMS MIPS Help Desk to private registry companies. However, in my experience, they lack understanding of hospital-based practices, and are focused primarily on outpatient practices. This article will outline the steps I recommend for hospital-based physiatrists to achieve success in meeting the requirements of Medicare’s MIPS program, and thereby earn a lucrative bonus.

article about medicare billing for physiatrists with picture of medicare card

Reporting for Past Years

First, establish a chronology of how your practice has dealt with MIPS reporting in past years.

– Based on reporting for 2022, are you receiving a Medicare penalty or bonus in 2024? Ask your billing personnel for a current Medicare Remittance Advice, and you will know instantly.

– Based on reporting for 2023, will you receive a penalty or bonus in 2025? You should check a Remittance Advice for the upcoming 2025 year.

Current Year Reporting (2024)

Reporting MIPS in 2024, which will result in a penalty or bonus in 2026, involves the following 4 categories:

  1. Quality (30%) – This category is the most important, and the one you can easily control. I recommend reporting a Specialty set via a Registry.
  2. Improvement Activities (15%) – There is a comprehensive list of available Improvement Activities to report. Since you are probably already performing these activities, all you need to do is select 2 of them.
  3. Promoting Interoperability – aka EHR- (25%) – You are probably classified as a “small practice” by Medicare, which means that you do not need to report this category and the 25% will be redistributed to the other 3 categories.
  4. Cost (30%) – Cost is calculated by Medicare so there is nothing for you to report.

The summary above is a general outline and provides an overview of the MIPS program. With some effort, hospital-based physiatrists can not only meet the requirements of the MIPS program, but also earn a lucrative bonus!

This article was contributed by Mr. Bruno Stillo, Physiatry Billing Specialists, 800-835-4482, http://physiatrymedicalbilling.com/
They specialize in Inpatient Physiatry Medical Billing for 20 years. All of their clients are on staff at acute care rehabilitation facilities. If you are starting a new practice, they can set up everything for you. If you have an existing practice, and want to improve your billing system, they can clean up your old receivables, and ensure that new billings are done professionally.

Physiatry Supervision of Ancillary Staff

A physiatrist asked me recently about the supervision of ancillary staff.  He was asked to start supervising ancillary staff as part of his job.  He asked me how much he should be paid additionally to do this.  He had a concern about the litiguous position it might put him.  I’m not familiar with this subject so I asked a Bruno Stillo, a colleague and owner of Physiatry Billing Specialists, and he also was not familiar with this circumstance.  A reference on this subject was found on the web, https://www.michaeljohnsonlegal.com/physician-compensation-supervision-npp/  It says that physician supervision is VERY profitable to employers and that as a physician you should not provide this supervision without a fair compensation.  You should have the foresight include language when you’re negotiating a contract to exclude this supervision.

Physiatrist working with a physician's assistant

Employers may offer to allow you to record your time spent supervising and pay you on an hourly basis. However, if you look closely, the hourly rate they are willing to pay is often lower than what you make per hour already, such that adding more time to your day would result in a diminished marginal rate of compensation. Said another way, if your first 40 hours (likely more) of work in a week pays you $175/hour, and the hourly rate for supervision your employer offers to pay is $150/hour, then it is not in your best financial interests to do agree to do more work.

The article goes on to discuss other compensation methods.  Their bottom line is to be careful and to not be taken advantage of.

Potential COVID-19 Hardship Exception Extended to 2021 MIPS

CMS is offering the option of obtaining a COVID Exception from reporting for MIPS for 2021, according to the following stated criteria from CMS:
Can I Apply for an Extreme and Uncontrollable Circumstances Exception?
Yes. If you believe you have been affected by an extreme and uncontrollable circumstance (such as the public health emergency triggered by the COVID-19 pandemic), you can apply for this exception whether reporting traditional MIPS or the APM Performance Pathway (APP).
Extreme and uncontrollable circumstances are defined as rare events entirely outside of your control and the control of the facility in which you practice. These circumstances would:
 –  Cause you to be unable to collect information necessary to submit for a MIPS performance category;
  –  Cause you to be unable to submit information that would be used to score a MIPS performance category for an extended period of time (for example. if you were unable to collect data for the quality performance category for 3 months), and/or,
  – Impact your normal processes, affecting your performance on cost measures and other administrative claims measures.
In order to apply for this Exception, go to:
  https://qpp.cms.gov/mips/exception-applications
–  Go to the Section “Extreme and Uncontrollable Circumstances Exception Application Window is Now Open” and hit Apply
– Select ALL 4 program categories (Quality, Promoting Interoperability, Improvement Activities and Cost).
If approved, you should receive an instantaneous email confirming Approval.

If you get approved, it’s one less headache for your practice in 2021!

This article was contributed by Bruno Stillo, Physiatry Billing Specialists, 800-835-4482, www.physiatrymedicalbilling.com
[email protected]

6 out of 10 People Choose a Doctor Based on a Convenient Location

location buildingWhen a patient chooses a doctor or a hospital, the decision process is often driven, not by quality factors, but by simple geography. Check out these surprising and insightful numbers…

Three recent surveys seem to agree; “location” is a highly significant consideration. What’s more, according to Healthgrades data, “convenient location” is more than twice as important to consumers selecting a physician or a hospital than success rates or outcome data.

Here are some of data points that I recently shared in my marketing talk at the Cleveland Clinic Patient Experience Summit. Many hospital marketers, CEOs and healthcare/patient experience pros at the Summit were shocked that people choose hospitals based upon location and friendly staff vs. quality.

Choice of Physician: Consumers who have selected a physician in the past three years are more concerned about convenient location (62%); friendly office staff (56%); than success rates (22%).

Source: 2014 Healthgrades American Hospital Quality Report to the Nation

And, for the still-to-be-convinced crowd, the findings run parallel to a prior Healthgrades study about consumer choices:

Factors Most Often Considered When Selecting a Physician

  • Whether my physician is covered by my health insurance plan (72%)
  • The physician’s office location (69%)
  • Which hospital he/she is affiliated with (49%)
  • How long it takes to get an appointment with that physician (47%)
Source: Consumer Research: America’s Readiness to Choose a Doctor or Hospital; Healthgrades; Prepared by Harris Interactive; October, 2012

And a third survey—this one by the American Osteopathic Association (AOA)—similarly revealed “location” as one the five most important factors adults consider when choosing a physician for themselves or a loved one:

  • Acceptance of insurance plan (83.3%)
  • Bedside manner/empathy (60.5%)
  • Proximity of office to home, work or school (57.4%)
  • Convenient office hours (42.9%)
  • Medical specialty (37.5%)

And where do consumer/patients find information? The AOA survey reports that adults use the following top five resources when finding a physician:

  • Word of mouth, i.e. family, friends, coworkers (65.9%)
  • Insurance provider directory (51.9%)
  • Physician rating websites, i.e. Vitals, Healthgrades (22.8%)
  • Hospital website (10.8%)
  • Consumer review websites, i.e. Yelp (10.5%)

The selection of a physician or medical facility nearly always employs a combination of reasons. And an increasingly informed and engaged public means more people are shopping carefully…and often, close to home.

Taken from https://healthcaresuccess.com/blog/hospital-marketing/6-10-people-choose-doctor-based-convenient-location.html#

When you want to add a physiatrist or are looking for a PM&R position, please visit the Openings page on my website, https://farrhealthcare.com/openings/

Business Consultants/Guide to Starting Your Own Medical Practice

8 Myths About Being a Self-Employed Physiatrist

Do you dream of being a self-employed physiatrist but feel like you don’t have the money, knowledge, or skills to get a practice going? Your concerns might be unfounded and grounded in some of the common myths about self-employment. Imagine being able to increase your income and have a more flexible schedule. These benefits are a real possibility when you are your own boss. So, let’s start exposing the eight myths for what they really are.

1. Self-employed means working long hours. Many people who work for themselves do work long hours, but this is frequently a choice. They simply love what they do. Many people can start practices that generate income even while they aren’t working. If you choose a practice that includes passive recurring income, you won’t necessarily have to spend a lot of time working once you get going.

2. Being an employee is less risky. This is one of the biggest myths. Employees get laid off all the time. And what if you need to raise some extra cash quickly? That’s tough to do when you’re working for someone else, and your income is fixed. Being self-employed gives you more control over your income and the assets of the practice. Control helps reduce risk.

3. Self-employment means putting all your eggs in one basket. If you’re an employee, how many patients do you have to lose in the practice in order to lose your paycheck? This can be as little as one patient. But if you have a number of patients, they all have to fire you for you to lose all of your income.

4. Self-employment equals stress. When you work for yourself, you can create whatever work environment you choose. You can have greater stability over the long term, and you have more control over your hours. You can also choose a practice that isn’t inherently stressful. Generally, you can make it whatever you want it to be, which will make your stress level only as high as you find acceptable.

5. Being self-employed is lonely. Working for yourself can be a much more pleasant lifestyle if you choose. With more flexibility, you can often rearrange your schedule to suit your social life. When you work for someone else, your coworkers tend to be your social life. Over time, that can get old.

6. Self-employment means doing everything yourself. While you’re the one that has to ensure that everything gets done, that doesn’t mean you have to do everything yourself. Hire people to do the work for you. Your time should be spent growing and expanding the practice, not doing the grunt work.

7. Running your own practice is complicated. Yes, there is quite a bit to know, but none of it is difficult. There are books and experts available to help you along the way. Nothing is overly complex about insurance, payroll taxes, and bookkeeping. It’s just new to you. Plus, you only have to learn information once. Then you can start as many practices as you like.

8. You can’t start a practice without a lot of money. That largely depends on the practice. A website and accompanying social media platforms can cost less than $100 a year. Your home phone or cell phone is already paid for as part of your monthly expenses. A tank of gas isn’t that expensive, relatively speaking, nowadays, plus they have electric vehicles. And ads are inexpensive also. There are a lot of inexpensive ways to start and market a practice. You could market directly to other doctors and/or set up free educational webinars that describe your services.

Where there’s a will, there is a way. Don’t let a bunch of myths stop you from taking the plunge into self-employment. You can even start a practice on the side and continue working your regular job until your new practice brings in enough income to replace it. Now that we’ve separated myths from facts, what are you going to do? Put on your thinking cap and figure out a way to make your dream a reality. There’s no time like the present to take control of your life.

This article was contributed by Hassan Akinbiyi, M.D., https://drhassanrehab.com/about-dr-hassan/

ProMedica Partners has released a new step-by-step guide about starting your own medical practice.  They gathered the best quality resources, references, tools, & information you need to open your own practice, all in one place.  One of the items in this blog on their website provides information about the possible need to hire a practice startup consultant.   “Though consultants can be expensive, their fees can be well worth it, if you utilize their services effectively. Start with a professional association such as the NSCHBC, and also ask colleagues for reference, especially others in your specialty.”  To find out more of their comprehensive information on this subject, Check out part 2 of the new guide here

This information is courtesy of ProMedica Partners, https://promedicapartners.com/

7 Types of Insurance to Protect Your Medical Practice

7 Types of Insurance to Protect Your Medical Practice

If you’re a family physician who manages your own private practice, then you are well aware of the challenges that come with being a business owner. You’re the judge, jury and executioner when it comes to laying the ground rules for how you want your practice to operate. But if you’ve recently acquired your own independent practice, there are a few things you need know – namely how you can protect your practice from various risks.

From day one of opening your practice, you expose yourself to certain liabilities, which is why it’s important to have the right types of insurance in place. One lawsuit or catastrophic event could be enough to wipe out a small business before it even has a chance to get off the ground. In this post, we’re reviewing the types of protection an independent family physician practice needs in order to protect everything you and your staff have worked so hard to achieve.

  1. Professional Liability Insurance

Professional liability insurance, or malpractice insurance, protects your practice in the unfortunate event that you are sued by a patient who claims negligence or that you failed to perform your job properly, resulting in harm.

While there is no one-size-fits-all policy, professional liability coverage helps cover the costs of legal defense and settlements, which can run into the hundreds of thousands of dollars. Since many small physician practices won’t have the resources to cover expensive claims, malpractice insurance is a must.

  1. Property Insurance

When you first opened your practice, you probably invested a lot of time and money in getting the right equipment, medical supplies, furniture and other necessary fixtures to make your business inviting to patients. However, if there was a natural disaster, how would you replace these items?

That’s where property insurance comes in. It protects the property you use in case it becomes lost or damaged due to common issues such as fire or theft. Property insurance covers both the physical building of your practice and personal property that is vital to the operation of your business (office furnishings, inventory, computers, etc.). Whether you own or lease your space, property insurance should not be neglected.

  1. Business Auto Insurance

Some physicians who are on their own have the flexibility to make house calls. This is especially common for concierge doctors who often drive to a patient’s home. If you use your own car for business purposes, you may want to consider business or commercial vehicle insurance. Most personal auto insurance policies won’t cover damages to cars involved in an accident used mainly for business purposes. A business auto policy covers cars owned by a business.

This insurance pays any costs resulting from bodily injury or property damage for which your business is legally liable. Depending on your coverage, your policy may pay for repairs or replace your vehicle due to damage from accidents, theft, and/or other events.

  1. Workers Compensation Insurance

As a business owner, you probably hired a few hard-working, dedicated employees. If any one of them were to become seriously injured, how would you be able to run your practice? In all states (with the exception of Texas) an employer must have workers compensation insurance, depending on the number of hired employees.

This insurance pays for medical care and replaces a portion of lost wages for an employee who is injured during the course of employment, regardless of who was at fault. Even if your employees perform low-risk or low-impact work, slip-and-falls or other medical conditions such as carpal tunnel syndrome could result in expensive claims.

If a worker dies as a result of their injuries, the insurance then compensates the employee’s family. This is definitely a type of insurance you don’t want to overlook, especially for the livelihood of your staff members.

  1. Business Interruption Insurance

Depending on where you practice, your business may be more prone to natural disasters such as earthquakes, hurricanes or tornadoes. If a disaster or catastrophic event occurs, it is likely that your business’s operations will be interrupted. To help your practice get back up and running, consider a business interruption insurance policy.

This coverage is different from property insurance in that it covers incomes lost due to a disaster-related closing of a business or due to the need for structural rebuilding of the practice. However, BII can also be combined with a property insurance policy – this package is known as a Business Owner’s Policy.

  1. Life Insurance

While it may not seem directly related to your practice, life insurance is another form of financial protection that is often left on the backburner. If you were to pass away, who would provide for your loved ones’ future? Who would treat your patients?

Life insurance offers a death benefit to your appointed beneficiaries in the event that you can no longer financially provide for them. This type of insurance is very important because it allows peace of mind for you, your family, and your business partners. Life insurance is a great way to unburden your loved ones due to the loss of your income. If you need assistance protecting your family’s financial future, the AAFP Insurance Program is here to help.

  1. Practice Overhead Insurance

If you were unable to practice medicine due to an injury or illness, you’d probably consider Individual Disability Insurance. While this is a form of protection you should certainly have in your back pocket, think about your practice. If you’re out of the office, who will see your patients?

Practice overhead insurance steps in if you are temporarily out of the office due to a disability. It helps cover certain expenses such as utility bills, rent, salaries, taxes and other office costs. Don’t risk losing your income or control of your practice due to an injury.

 

By having the right types of insurance in place, your medical practice can avoid a major financial loss due to lawsuits or catastrophic events.

Taken from the AAFP, 2015, https://www.aafpins.com/2015/12/7-types-of-insurance-to-protect-your-medical-practice/

Promoting Interoperability Hardship Exception Deadline 12-31-2020

As part of MIPS reporting for Performance Year, Eligible Providers are required to report under the “Promoting Interoperability” category (formerly known as Advancing Care which was formerly known as EHR(Electronic Health Records). For most hospital-based rehab providers, whose practice is in a free-standing rehab facility (such as Encompass Health), there is probably no capability of using an EHR system which satisfies CMS’ physician requirements – Encompass Health’s system does not meet physician reporting requirements.

In order to avoid losing 25% of points in the MIPS Scoring system, these providers can submit  a very simple Hardship Exception indicating:

-“Lack of Control over the availability of CEHRT,” or

– “Eligible Clinician in a Small Practice”(under 15 clinicians).

If approved, the application will move the 25% scoring from “Promoting Interoperability” to “Quality,” thus avoiding a loss of 25% scoring in the MIPS program.

Additional information regarding this exception can be found at:

https://qpp.cms.gov/mips/exception-applications#promotingInteroperabilityHardshipException-2020

This article was contributed by Bruno Stillo, CPA, MBA, Physiatry Billing Specialists, 800-835-4482,www.physiatrymedicalbilling.com
[email protected]

Vacation Time for Senior Physiatrists

A physiatrist contacted me today asking about the average number of vacation days for a senior physiatrist. My guesstimate is about 6 weeks. As I said to him, the number of vacation days as a benefit are often negotiable especially when you are a senior physiatrist and not tied to a particular number.
There is not alot of information available on this subject. I couldn’t find any information specific to career level and the number of vacation days. In general across all levels, an article from the August 27, 2018 New England Journal of Medicine says that Paid Time Off benefits are getting more generous but less flexible. “PTO has become much more clearly defined in recent years,” Ms. Caldwell said. Organizations today are stating the exact number of permitted days off (four to six weeks annually is the common range now), defining what constitutes paid vs. unpaid leave, and being firm on what happens with accrued leave that isn’t taken.”
A sampling of some of the vacation times of positions I’m representing but are not specific to senior physiatrists include 6 weeks an inpatient position in NH), 4 weeks (an interventional position in MA), 4 weeks (a Medical Director, Rehab position in MN), 6 weeks (an interventional position in MN), 3 weeks (inpatient in NV), and 4 weeks in RI (inpatient, consults and interventional).

New Medicare Proposal Would Allow Non-Physician Practitioners to Perform Some Inpatient Work Done by Physiatrists

This proposed rule would update the prospective payment rates for inpatient rehabilitation facilities (IRFs) for Federal fiscal year (FY) 2021. As required by statute, this proposed rule includes the classification and weighting factors for the IRF prospective payment system’s case-mix groups and a description of the methodologies and data used in computing the prospective payment rates for FY 2021. We are proposing to adopt the most recent Office of Management and Budget statistical area delineations and apply a 5 percent cap on any wage index decreases compared to FY 2020 in a budget neutral manner. We are also proposing to amend the IRF coverage requirements to remove the post-admission physician evaluation requirement and codify existing documentation instructions and guidance. Additionally, we are proposing to amend the IRF coverage requirements to allow non-physician practitioners to perform certain requirements that are currently required to be performed by a rehabilitation physician.

For more information visit https://www.federalregister.gov/documents/2020/04/21/2020-08359/medicare-program-inpatient-rehabilitation-facility-prospective-payment-system-for-federal-fiscal