The Compliance Guy

Terry and Sean take on the giant headache of split/shared and incident-to services. This one gets a bit heated for legitimate reasons.

You're gonna love this one!

The entire team is back for this episode! There was a lot to discuss with so many issues coming to light in the areas of coding, billing, documentation, and compliance. Don't miss one minute of this one!

What is a compliance plan and how to build one that is effective and meets OIG and DOJ requirements!

This was an epic episode that you do not want to miss. Scott, Terry, Stephanie and Christine joined Sean to discuss the False Claims Act, Anti-Kickback Statute, Template issues, and so much more!

Terry and Sean take on Telehealth access. Clients are getting letters about not having Telehealth available for disabled patients, which is required under the Federal Disabilities Act. Physicians telling patients they don't have in-person options for care, ONLY Telehealth is not okay.

The panel was back at it with a great breakdown of the Medicare Physician Fee Schedule Rule Changes for 2024... as always it was a lively discussion about the proposed rule changes and their impact on providers.

Topics Included:

1. Split/shared services – the definition of substantive portion will remain the same as it is now through 12/31/2024... Time will not be the controlling factor. HX, EX, and MDM can be used to make this determination of the substantive portion.

2. Extend flexibilities for certain assessments furnished via audio-only communication, through the end of CY 2024. If finalized, opioid treatment programs (OTPs) would be allowed to bill Medicare when video is not available, using technology permitted by the Drug Enforcement Administration (DEA) and the Substance Abuse and Mental Health Administration (SAMHSA). This extension would equalize telehealth flexibilities across providers of care and negate potential service disruptions due to the end of the COVID-19 public health emergency (PHE).

3. CMS proposes several additions to covered telehealth services under the MPFS, as well as an extension of several telehealth provisions from the Consolidated Appropriations Act (CAA) of 2023. Proposed changes include the add-on of health and well-being coaching services on a temporary basis (specific diagnoses and licensure/certifications will apply), as well as a refined process to review requests to add services to the Medicare Telehealth Services List. Telehealth provisions extended through December 31, 2024, will include:

• The temporary expansion of the scope of sites where telehealth is furnished from, to include any location in the U.S. where a beneficiary may reside; for Medicare and MA patients, but States would also have to agree to comply.

• A change in definition of telehealth providers to include qualified audiologists, speech-language pathologists, occupational therapists, and physical therapists; They are already on the Temp list through 2024

• Continued payment for telehealth services provided by federally qualified health centers (FQHCs) and rural health centers (RHCs); limited to BH services

• Delaying requirements for beneficiaries to meet with practitioners six months before initiating mental health telehealth services; Unless they have a narcotic prescription then they would not qualify if a new patient after Nov 2023

• Allowing physicians in teaching environments to use video and audio communications when a resident is furnishing Medicare telehealth services; and But the supervising provider would have to be somewhere in the inpatient hospital setting and available if needed.

• Continued payment and coverage of telehealth services that are included on the Medicare Telehealth Services List.

4. There is a proposed reduction to the 2024 conversion factor that would reduce provider reimbursement. CMS is urging Congress to create a permanent fix for this issue but as it stands now, the proposed rate reduction stands. CMS is also proposing significant increases in payment for primary care and other kinds of direct patient care with the HCPCS add on G2211.

5. The proposed rule includes a new benefit category wherein family therapists, marriage therapists, and mental health counselors would be able to bill Medicare (Physician supervision necessary). Additionally, CMS proposes changes in payment and coding to account for resources utilized in the delivery of care involving a multidisciplinary clinical team and other staff members.

6. The Proposed Rule has significant implications for other virtual care and care management services, including Remote Physiologic Monitoring (“RPM”) and Remote Therapeutic Monitoring (“RTM”) services. Below is a summary of key provisions in the Proposed Rule relating to RPM, RTM, and other virtual care management services, along with opportunities and challenges for stakeholders in the space.

This is a systemic problem facing the industry and the MACs, OIG, DOJ and others who audit and investigate are hyper aggressive when it comes to recoveries! Learn the regulations and your obligations to refund money you are not entitled to!

The panel was back for a great discussion on today's most pressing issues facing healthcare professionals:

Sean and Terry take on some spicy issues (literally and figuratively) in this episode. Not knowing the coding rules can land you in some hot water and lead to significant claw backs and/or overpayment demands. Don't miss this outstanding episode with one of the industries foremost coding and billing SMEs!

The all star panel was back for another outstanding episode. There was a lot of debate in this one and the fact is all of the positions laid out were solid and accurate. Providers need to be proactive in their compliance when it comes to accurate coding but when things aren't perfect it takes a team to create a solid defense. Do not miss this one as it was hands-down one of the best debates of the season!