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Medicare+Choice: what lies ahead?

Health plans have continued to exit the Medicare+Choice program in recent years, despite efforts of Congress and the Centers for Medicare and Medicaid Services (CMS) to reform the program. Congress and CMS therefore stand poised to make additional, substantial reforms to the program. CMS has proposed to consolidate its oversight of the program, extend the due date for Medicare+Choice plans to file their adjusted community rate proposals, revise risk-adjustment processes, streamline the marketing review process, enhance quality-improvement requirements, institute results based performance assessment audits, coordinate policy changes to coincide with contracting cycles, expand its fall advertising campaign for the program, provide better employer-based Medicare options for beneficiaries, and take steps to minimize beneficiary costs. Congressional leaders have proposed various legislative remedies to improve the program, including creation of an entirely new pricing structure for the program based on a competitive bidding process.

Actuarial Analysis↗

Costs can and must be a component of surgical audit.

The cost of running a surgical firm at Addenbrooke's Hospital in Cambridge was assessed over a 1 month period in May 1989. The total of 97,380 pounds was much more than expected for a firm of one full-time and one part-time consultant. It related to the month's workload of 101 admissions, 656 inpatient days, 92 operations and 442 outpatient visits. The derivation of a simple formula enabled individual patient episodes to be costed; from this new data and information stored routinely on the firm's audit system. It has been used to cost patients undergoing procedures commonly performed by the firm and also to illustrate the effect of complicated surgery on resources. Audit has been shown to have potential in a clinician's assessment of his resource use. Its future development in this role is strongly advocated.

Aged↗

Avoiding pharmacy fraud through automation and audit.

Pharmacy data offer some of the most reliable and evaluative information in managed care today. As fraud constitutes up to 10% of our total health care expenditures, the author explains how monitoring the pharmacy network for fraud and abuse is an easy way of reclaiming some of these losses.

Electronic Data Processing↗

Auditing and accountability within the public hospital system: the need for structural reforms.

A recent report by the Independent Commission Against Corruption (ICAC) in NSW highlighted that some accounting controls for cash handling in public hospitals are inadequate. Given the number of public hospitals in Australia and the amount of cash being handled, it is essential that efficient accounting and auditing systems are established for these activities. This paper examines several major shortcomings in cash-handling methods used by NSW public hospitals and outlines how the system may be improved. The authors are currently developing a national survey to extend this analysis.

Accounting↗

Implications of the laboratory charges unbundling initiative.

Hospitals across the United States have began to receive demand letters as part of a joint anti-fraud and abuse effort between the HHS Office of the Inspector General and the Department of Justice regarding laboratory charges unbundling. The goal of this initiative is to recover erroneous payments. U.S. attorneys have been given the opportunity to implement initiatives in their own districts. Violations may be punishable by triple damages, additional $10,000 fines for each false claim filed, and exclusion from Federally funded healthcare programs. The initiative gives hospitals the option of limiting the damages to two times the alleged billing error or single damages if they agree to participate in a self-auditing initiative. Through this initiative, hospitals agree to file an audit plan with the government and disclose the results. In order to limit damage exposure, it is important that hospitals have proof of their good-faith attempts to comply with antifraud and abuse laws by adopting compliance plans and installing software edits in their billing programs.

Financial Audit↗

Preventing employee theft: 15 techniques for preventing bookkeeping embezzlement.

Medical practices are unfortunately the target of embezzlement more often than you might think. This article offers practical suggestions for keeping your employees honest and thwarting a would-be embezzler. It describes the common symptoms of an embezzler at work and offers 15 practical techniques for preventing bookkeeping embezzlement. This article also suggests a simple method for conducting mini-audits from time to time and precautions to take to ensure the reliability of computer passwords. The article advocates keeping tighter control of office supplies and a method for spotting telephone abuse. Finally, it offers suggestions for dealing with employees who steal time on the job.

Accounting↗

Notes: a suitable case for audit.

The increasing emphasis on management responsibilities and audit led us to investigate the state of surgical notes in our hospital. Twelve criteria were evaluated regarding information that should be contained in the notes and the absence of this important information was documented. Deficiencies were revealed in all criteria selected. Until hospital patients files are well kept and maintained, retrospective audit whether financial or medical will not be valid. A significant injection of resources is required to redress the situation. Hospitals which have not carried out detailed studies into the contents of their notes need to do so as a matter of urgency.

Humans↗

Auditing for fund-holding success.

Five papers on aspects of fund-holding practice management were entered into the Practice Managers' Forum at the joint IHSM/Radcliffe Medical Press First National Practice Managers' Conference, of which this contribution was judged the best. Its author, Miranda Lonsdale, received the Radcliffe Award for the presentation.

Costs and Cost Analysis↗

The changing role of internal auditors in health care.

Two surveys of directors of internal auditing in health care conducted in 1990 and 1998 found that healthcare internal auditors are spending proportionately more time on management and operational improvement activities and less time on traditional financial/compliance activities. The average staff size has remained relatively constant, but salaries at all levels of experience have risen. More importantly, the tenure of healthcare internal auditors has increased significantly since 1990. The profile of the healthcare internal auditing director also has changed. The director is older, more experienced, and has held the position for twice as long as was the case in 1990. On the other hand, the director is more stressed and less satisfied with compensation.

Career Mobility↗

Why should your practice perform compliance audits based on the latest OIG Work Plan?

Why have compliance audits, or medical record reviews, become an essential part of many progressive medical facilities? Because medical record reviews are known to improve reimbursement, documentation, and internally identify compliance issues that should to be promptly addressed, in order to protect the organization from substantial monetary penalties and legal sanctions by the federal government. This article discusses the importance of auditing based on the areas of focus recently identified in the OIG Work Plan. These include VA physician billing, pathology/clinical laboratory services, identifying referring physicians in Oklahoma that are sanctioned, high level E/M services, consultations, and red flags that are raised due to overuse of modifier -25 and -59.

Fees, Medical↗

The coming changes in tax-exempt health care finance.

On December 30, 1994, the Internal Revenue Service (IRS) published proposed regulations (Proposed Regulations) that if enacted would significantly change the climate and rules of federal income tax law controlling the issuance and maintenance of tax-exempt bonds for governmental and 501(c)(3) health care borrowers. This article (1) summarizes the aspects of the Proposed Regulations dealing with private activity tests, management contracts, allocation and accounting rules, change in use of financed facilities, and antiabuse rules, and (2) summarizes the possible interrelationship of the IRS's audit program for tax-exempt bonds and the Proposed Regulations. The article reviews features of the Proposed Regulations that will affect either the costs or administrative burdens of managing the federal tax compliance of future tax-exempt health care borrowings.

Accounting↗

The role of the Medicare fiscal intermediary and the regional home health intermediary, Part 2.

The Medicare fiscal intermediaries (FIs) are private insurance companies that serve as the federal government's agents in the administration of the Medicare program, including the payment of claims. There are two primary functions of the FI--reimbursement review and medical coverage review. Hospital-based home health agencies relate to the hospital's FI for reimbursement purposes. All home health agencies are assigned to a special FI, the Regional Home Health Intermediary (RHHI), for medical review issues. This may be the same FI or a different one than that audits the hospital's cost report. Freestanding home health agencies deal with separate reimbursement and medical review divisions within a single RHHI's office. The author reviews the role of the Medicare FI and the RHHI and their relationship to home health agencies. Part 1 was featured in the June issue.

Costs and Cost Analysis↗

A profile of family planning audit in England 1994-1997.

Audit has been entered into enthusiastically by most of the multidisciplinary teams giving family planning services but the nature of the subject makes audit particularly difficult in this field. In many cases it has been used as a tool for determining standards rather than a tool for determining compliance to them. If family planning audit and evaluation is to substantially improve in quality, a great deal of work needs to be done, particularly in the formation of appropriate guidelines and in the increased utilisation of audit/research specialists to advise on methodology. It is hoped that the new clinical effectiveness committee of the faculty will take a lead in this; if so it will undoubtedly gain support from faculty members.

England↗

Independent contractor arrangements and IRS audits.

As government auditors begin their challenges, nurse executives need to review their operations to remove any potential audit risks. Although a common practice for many institutions, the use of independent contractor arrangements may be ruled inappropriate. As a result, many individuals may be reclassified as employees, leading to Internal Revenue Service (IRS) assessments of penalties and back payroll taxes. It always is prudent to anticipate IRS actions and shore up any areas that may lead to tax assessments before they are imposed on the institution.

Contract Services↗

The remittance advice, auditing for compliance.

Resubmitting claims can be costly in terms of both time and lost revenue. The remittance advice and return to provider reports received by laboratories from carriers/intermediaries are an excellent source for investigating compliance matters. The Department of Health and Human Services, Office of Inspector General, has estimated that laboratories account for 4.38% of the total improper payments paid by the Medicare program for fiscal year 1998 (1). This article will illustrate how the information in these reports can be used to assist your laboratory in capturing the reimbursement it is entitled to.

Financial Audit↗

The use of cortical bone grafts in ossiculoplasty. III: Audit of costs.

This paper describes the results of a comparative audit of the costs of using artificial prostheses and cortical bone. The costs of using a bone graft have been calculated by estimating the expenses incurred as a result of the additional time required for preparation of the grafts. The mean cost of preparing a graft was 29.10 pounds, while the mean cost of using a prosthesis was 65.01 pounds.

Bone Transplantation↗

Regulatory changes that affect coding for immunotherapy.

BACKGROUND: During the past decade, a variety of federal regulations have had a significant impact on the way allergen immunotherapy is reimbursed and how Current Procedural Terminology (CPT) codes are used for this purpose. As mandated by the US Congress, the Centers for Medicare and Medicaid Services (CMS) through the Office of the Inspector General (OIG) targeted immunotherapy codes for scrutiny, because they are some of the most frequently used codes. OBJECTIVE: To examine how federal regulations have affected reimbursement for allergy immunotherapy and other allergy services. METHODS: A review was performed of the OIG survey of allergy immunotherapy and the OIG recommendations on CPT coding compliance guidelines. RESULTS: A preliminary survey found problems with medical appropriateness of allergen immunotherapy. For this reason, the OIG performed a more comprehensive study of 301 physicians using code 95165 to analyze by medical record and billing data whether the new billing rules were being correctly used and found that only 44% of physicians were following the new definition of a billable dose. In the early 1990s, the federal government served notice of its intent to more aggressively identify and prosecute health care providers who improperly billed and collected for medical services. Through the adoption of the 1991 US Sentencing Commission Guidelines, the government sought to enhance compliance by mandating lesser criminal penalties for violating organizations that nevertheless maintained and operated "effective compliance plans." In 2002, the OIG audited health care providers and recouped dollar 14.4 billion in improper payments by Medicare. Between January and June 2003, Medicare excluded 1,241 individual providers and health care entities due to fraudulent billing practices. CONCLUSIONS: Federal regulations have significantly affected reimbursement for allergy immunotherapy and other allergy services. Allergists need to be aware of these changes and implement the new recommendations into their practices.

Aged↗

Some tax-exempt bond issues could become taxable.

The IRS recently launched a new program to audit healthcare mergers-and-acquisition financing arrangements. To date, the IRS has focused on transactions involving IDSs in which tax-exempt bonds issued on behalf of the participants have been used to prepay the outstanding debt of one or both participants. The IRS is concerned that such tax-exempt financing may involve impermissible advance-refunding of the previous debt, in which case the financing would be deemed taxable and the participants subject to penalties.

Capital Financing↗