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

How do I Know if a Physiatry Practice is Busy Enough to Add a New Doctor?

A physiatry resident recently asked me this question.  It reminds me that on occasion I’ve been told by PM&R doctors that the reason they’re calling me to find a new position is because the practice they’re at isn’t busy enough to support them.  Here are some ways to possibly identify beforehand whether a physical medicine and rehabilitation practice you’re considering joining is busy enough to support you:

  1. Ask why they’re adding a new physiatrist.
  2. Make sure there’s a salary as opposed to an incentive based compensation.  Also, that the salary is the major chunk of your compensation as compared to the incentive portion.
  3. Ask who the referral sources will be.  Are they already servicing these referral sources?  How do they expect extra work from them for you?
  4. Find out the reputation of the PM&R practice.  Again, if you’re not familiar with the area, then this might be difficult to do.
  5. Ask about the physiatry turnover at the practice.  When was the last time they added a PM&R doctor?  If it was recently, then maybe they can’t support another doctor.
  6. Ask about the practice’s financial situation.
  7.  Ask for the books.  This is a simple, yet often times, difficult request to make.
  8. Survey the waiting room.  Is it busy?
  9. What marketing are they doing or plan to do?
  10. Ask how long the waiting list is for an appointment?
  11. Ask the practice what are their growth plans and vision for the future.

Hiring Trends in Physiatry 2019

Most physiatry fields are in demand.

The request for PM&R doctors to provide work in subacute facilities continues to rise.

Physical medicine and rehabilitation physicians who enjoy inpatient work can find such work easily in most areas.  Many facilities are including internal medicine physicians as staff to lessen the workload demands on inpatient physiatrists.

There is a continued demand for physiatry subspecialists in traumatic brain injury, spinal cord injury and pediatric rehab.

Interventional PM&R positions continue to be available as so many different subspecialties include these services in their practice.

General outpatient or sports medicine physical medicine positions don’t seem to be as great.

More employers are providing affiliation as an employee to satisfy physiatrists’ interests.

Physiatry Billing – No Magic Bullet

What is a magical way to improve your billing and collection function? Unfortunately, there is none – no hidden secret, no “silver bullet.” However, adherence to several fundamentals will work just as well.

How to maximize upfront billings:

Capture all performed services! For outpatient services, medical offices usually employ a pre-printed superbill which can easily be misplaced. Suggestion: Match each patient on the appointment schedule to a corresponding superbill.

For each patient admitted to a rehab facility, there is usually an initial charge, regular followups, and ultimately a discharge code. Suggestion: Any gap in inpatient billings should be brought to the provider’s attention.

Simple data entry errors can cost the practice thousands of dollars. Suggestion: Have a second person, not the data entry person, check all data entry.

How to maximize collections:

Followup, followup, followup!

Pursue vigorously by telephone or in writing all insurance denials, and non-responses. Many billing personnel find calling insurance companies to be stressful and time-consuming, when in reality they are usually helpful in resolving problem claims. TELEPHONE FOLLOWUP IS A KEY COMPONENT OF THE COLLECTION FUNCTION. Suggestions: When calling the insurance carrier to reprocess the denied claim, get a reference number. When calling about a claim with no response, try to fax the claim.

If a telephone call cannot resolve the denied claim, then a written appeal should be sent. Suggestion: Design a preprinted Appeal Form which can be filled in with the necessary information.

Sometimes, the patient’s insurance information is incorrect. Although it is very easy to simply send a bill to the patient, it is not the most effective way. You have a better chance of collecting money from the insurance company than from the patient. Suggestion: Research thoroughly the insurance problem by calling the patient, and by calling the insurance company. Billing the patient should be the last resort.

As has been demonstrated, billings can be maximized by capturing all services performed.

Bruno Stillo,CPA is the owner of Physiatry Billing Specialists, 800-835-4482, physiatrybillman@aol.com

Who Owns the Practice?

The answer to this question will guide your practice life with any group.   For several years, while managing physician relations for a local hospital, I recruited physicians for the hospital and affiliated medical practices.   It game me an opportunity to view physician recruitment from both sides of the contracts negotiated.   I think it beneficial to share some of my experiences and personal insights from those times.   I once tried to recruit a physician who was moving back to her hometown.   In the world of physician recruitment, we might call this “a perfect geographic match.”   Ironically, she chose to sign-on with a local group rather than the hospital I was recruiting for because she said she wanted to go into “private practice” which seemed to represent an idealized practice autonomy.   I asked her who owned the practice group.   She didn’t know.

*Private practice refers to a privately-owned practice, especially one operating under s system of free enterprise or laissez-faire captalism.   It describes a physician-owned practice, one that is not owned by an entity such as a hospital, and it is broadly used today to refer to solo and/or partnership practices of varying structures.   Unless you hold some level of practice ownership, you are an employee and you need to identify your employers before you sign a contractual agreement.

*       Identify the group’s short-term and long-term goals.   This will help you decide if your goals match the goals of the group.   If you want a busy outpatient practice then you must step in to fill a vacancy in a busy, established practice or your must build it. How will the group help you to do that?

I brought in one physiatrist who interviewed with the hospital CEO and administrators to consider an opportunity to either take over an established hospital-based and staff-supported inpatient/outpatient practice or to become a hospital employee with benefits.   Benefits were the dealmaker, but at dinner the CEO offered an unplanned glimpse into the practice environment when he asked the physician her thoughts about his idea to restructure the inpatient unit.   It was a very astute physician who later told me that the CEO wasn’t really asking for an opinion;he was simply trying to determine if she would buck him.

*       You are primed to be an employee in a system when you can identify and happily live within an organizational structure that neither seeks nor desires your input.

I met with a physician who had just given notice to his group that he was leaving.   He was extremely frustrated and had no alternative practice plan in place.   Two years earlier he had signed a contract to join that group with the understanding that he would be offered a partnership.   Time passed with minimal partnership discussion and he became so disgruntled that he finally made the decision to leave.   As I spoke with him, it became clear that the particulars of that partnership had never been provided.

*       A well-organized group will provide you with key information even before you ask.   A group that is not organized will barely be able to respond to your questions.   All groups fall somewhere along that continuum and you will want to gauge the level of the group’s organization since it will play a major role in your practice satisfaction.

Most physicians have a primary desire to practice medicine.   Most would choose to forego the cumbersome paperwork and the persistence required to advocate for the patient when arguing with insurers.   One physiatrist told me of the time spent in justifying the need for a wheelchair for a quadriplegic patient.

One physiatrist expressed an interest in building a part-time practice performing only EMGs. That physician was obviously well-informed about medical billing and he desired to build a practice with only high-level billable codes. If you entered into practice with this physiatrist on production-based compensation, what type of practice could you expect to build and how much money might you earn monthly?

    • Determine the primary needs of the patient population in the practice area.

As an employee, you will receive financial compensation based on a salary guarantee, production, or a combination of both. A salary guarantee is an amount you can bank on, literally, and it may be a great way to start up your practice. However, no group will want to continue to pay you more   than you earn. It just isn’t good business. That means it is expected that your gross charges will increase as you build your practice. Your earning potential will typically be tied to the revenue you generate (production-based) for your group and this is an important point to consider as you begin your contract negotiations.

  • Production is typically not the best option for a start-up practice for several reasons. It takes an investment of time and money to build a practice and this may be one of the most underestimated aspects of medical practice start-up.
Retirement benefits within a group practice may exceed those available in hospital-owned practices, a notable advantage. Group practices tend to invest the maximum allowable amount, $30,000 annually, into each retirement plan for each physician in the group. In some groups that money is self-directed so each physician can elect his or her own investment options independently of the group. Hospitals, however, have a different set of governmental guidelines as not-for-profit or for-profit entities, and are thereby limited in the amount that they can invest in the retirement plan for their employed physicians. In addition, there may be limited investment options for physicians in those plans. This is an important point to include in physician compensation when comparing practice opportunities and negotiating salary compensation.

By Kathy Jeffries, MyraPhyx A Physician Resource Group, myraphyx@mchsi.com, 573-680-3105

National Provider Identifier

NPI, stands for national provider identifier.   CMS initiated this reform to simplify filing claims.   The rest of the carriers are being forced to follow suit.   The NPI will replace all numbers that you were previously using to file claims, i.e., your Medicare numbers, BC/BS numbers, etc.
The website NPPES (https://nppes.cms.hhs.gov?NPPES/Welcome.do) is where you go to create your login and password, and get your NPI number(s) issued.   If you enter your information incorrectly, you will get denied on every claim you submit.   The NPPES site has to match what your local intermediary has on file for you.   Your clearinghouse has to match everything in their electronic file to send to the local intermediary.
Article contributed by Ken Lee, PRS, Inc., a physiatry practice management company to include billing services, kenlee@prsinc.com, 1-800-324-4777

Burn-out among physiatrists high

A recent slideshow on MedScape says that burn-out is a major issue for physicians.  44% of physicians report burn-out.  Believe it or not, physiatry is the third highest specialty reporting burn-out.  It is only preceded by urology and neurology.

For more information, visit https://www.medscape.com/slideshow/2019-lifestyle-burnout-depression-6011056#4

Action needed by 12/31/18 – MIPS Reporting for Physiatrists Working in Free-Standing Facilities

As part of MIPS reporting,  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 providers, whose practice is in a free-standing rehab facility (such as Healthsouth), there is no capability of using an EMR system which satisfies CMS’ physician requirements – Healthsouth’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.” 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.
The Promoting Interoperability Hardship Exception application can be found at:
https://cmsqualitysupport.service-now.com/exception_application.do
The deadline is December 31, 2018, so there is still time to submit this simple application.

This information has been provided by Bruno Stillo, CPA, MBA, President, Physiatry Billing Specialists, 800-835-4482,
www.physiatrymedicalbilling.com
physiatrybillman@aol.com

The Stark Law

The Stark Law says that you can’t be in an arrangement that encourages referrals to entities that you own or have an investment interest.  In group practices, the law places constraints on your compensation for in-house referrals.  It states that your compensation can not be related to the utilization of the in-house referrals.  The law allows for allocation that are determined before the services were available and meets certain requirements. Much has been written about the Stark Law which you can find on the web.

Medicare’s Quality Improvement Program – Information for Physiatry

Medicare Concept

Starting in 2017, CMS has instituted a Quality Payment Program (QPP) which incorporates prior PQRS/EHR programs.

Medicare

Under the new QPP program, all Medicare Part B clinicians are responsible to report various categories:

  1. Quality(old PQRS)
  2. Advancing Care(old EHR)
  3. Improvement Activities, and
  4. Cost(begins 2018)) as follows:

-All physicians must report, whether they are solo practitioners, or employed by another entity.

-Clinician must have more than $30,000 in Medicare allowed charges AND must provide care to more than 100 Medicare patients a year, or they are exempt,

-Clinicians include physicians, physician assistants, nurse practitioners, clinical nurse specialists, and certified registered nurse anesthetists.

-Newly enrolled physicians are exempt during their first year of practice.

Penalties will be assessed as follows:

Failure to properly report in 2017 will cause a 4% penalty in 2019.

Failure to properly report in 2018 will cause a 5% penalty in 2020.

Failure to properly report in 2019 will cause a 7% penalty in 2021.

Failure to properly report in 2020 will cause a 9% penalty in 2022.

Incentives are also available for the above years for successful reporting:

Successful reporting in 2017 may result in an incentive of up to 4% in 2019.

Successful reporting in 2018 may result in an incentive of up to 5% in 2020.

Successful reporting in 2019 may result in an incentive of up to 7% in 2021.

Successful reporting in 2020 may result in an incentive of up to 9% in 2022.

This information was provided by Bruno Stillo, CPA, MBA, Physiatry Billing Specialists,
800-835-4482,www.physiatrymedicalbilling.com, physiatrybillman@aol.com